gov.uscourts.nysd.447706.423.0.pdf

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ---------------------------------------------------X ........................................... VIRGINIA L. GIUFFRE, Plaintiff, v. 15-cv-07433-RWS ..... GHISLAINE MAXWELL, Defendant. --------------------------------------------------X Declaration of Laura A. Menninger in Support of Defendant’s Renewed Motion to Compel Settlement Agreement I, Laura A. Menninger, declare as follows: 1. I am an attorney at law duly licensed in the State of New York and admitted to practice in the United States District Court for the Southern District of New York. I am a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit this Declaration in support of Ms. Maxwell’s Renewed Motion to Compel Settlement Agreement. 2. Attached as Exhibit A (filed under seal) is a true and correct copy of Plaintiff’s Response And Objections To Defendant’s First Set Of Discovery Requests To Plaintiff, served March 16, 2016. 3. Attached as Exhibit B (filed under seal) are true and correct copies of conferral communication between counsel, including a true and correct copy of Jeffrey Epstein’s written waiver of claims concerning settlement agreement’s confidentiality provision dated August 16, 2016. 4. Attached as Exhibit C (filed under seal) is a true and correct copy of the Complaint in Jane Doe 102 v. Jeffery Epstein, Case 9:09- cv-80656- KAM, filed in the United States District Court for the Southern District of Florida, on May 4, 2009. 5. Attached as Exhibit D (filed under seal) is true and correct copy of Plaintiff’s Fourth Revised Rule 26(a) Disclosures served on June 24, 2016. I declare under penalty of perjury that the foregoing is true and correct. Executed on September 6, 2016. s/ Laura A. Menninger Laura A. Menninger CERTIFICATE OF SERVICE I certify that on September 6, 2016, I electronically served this Declaration of Laura A. Menninger in Support of Defendant’s Renewed Motion to Compel Settlement Agreement via ECF on the following: 2 Sigrid S. McCawley Paul G. Cassell Meredith Schultz 383 S. University Street BOIES, SCHILLER & FLEXNER, LLP Salt Lake City, UT 84112 401 East Las Olas Boulevard, Ste. 1200 [email protected] Ft. Lauderdale, FL 33301 [email protected] [email protected] J. Stanley Pottinger Bradley J. Edwards 49 Twin Lakes Rd. FARMER, JAFFE, WEISSING, EDWARDS, South Salem, NY 10590 FISTOS & LEHRMAN, P.L. [email protected] 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 [email protected] /s/ Nicole Simmons Nicole Simmons 3