gov.uscourts.nysd.447706.21.0.pdf

Case 1:15-cv-07433-RWS Document 21 Filed 12/10/15 Page 1 of 4 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF PLAINTIFF’S OPPOSITION TO DEFENDANT’S MOTION TO STAY I, Sigrid S. McCawley, declare that the below is true and correct to the best of my knowledge as follows: 1. I am a partner with the law firm of Boies, Schiller & Flexner LLP and duly licensed to practice in Florida and before this Court pursuant to this Court’s September 29, 2015 Order granting my Application to Appear Pro Hac Vice. 2. I respectfully submit this Declaration in support of Plaintiff Virginia Giuffre’s Opposition to Defendant Maxwell’s Motion to Stay. 3. Attached hereto as Exhibit 1, is a true and correct copy of the Government’s September 3, 2008 Victim Notification Letter. 4. Attached hereto as Composite Exhibit 2, is a true and correct copy of flight logs for Jeffrey Epstein’s private jet, and a summary chart reflecting flights where Ms. Giuffre and Defendant were listed as passengers, and a chart listing the airport codes. 5. Attached hereto as Exhibit 3, is a true and correct copy of a picture of Prince Andrew, Ghislaine Maxwell and Virginia Roberts Giuffre. 1  Case 1:15-cv-07433-RWS Document 21 Filed 12/10/15 Page 2 of 4 6. Attached hereto as Exhibit 4, is a true and correct copy of Excerpts from the July 29, 2009 and August 7, 2009 Deposition Transcripts of Alfredo Rodriguez. 7. Attached hereto as Composite Exhibit 5, is a true and correct copy of the Palm Beach Police Reports dated March 14, 2005 and July 28, 2006. 8. Attached hereto as Exhibit 6, is a true and correct copy of Excerpts from the September 8, 2009 Deposition Transcript of Juan Alessi. 9. Attached hereto as Exhibit 7, is a true and correct copy of Juan Alessi’s November 21, 2005 Sworn Statement. 10. Attached hereto as Composite Exhibit 8, is a true and correct copy of the Notice of Deposition of Ghislaine Maxwell, Subpoena and Cancellation Payment Notice, and January 13, 2015 Daily Mail, “Bill Clinton pictured with Jeffrey Epstein’s social fixer at Chelsea’s wedding AFTER severing links with disgraced pedophile.” 11. Attached hereto as Exhibit 9, is a true and correct copy of Plaintiff’s First Request for Production of Documents to Defendant, dated October 27, 2015. I declare under penalty of perjury that the foregoing is true and correct. /s/ Sigrid S. McCawley______ Sigrid S. McCawley, Esq. 2  Case 1:15-cv-07433-RWS Document 21 Filed 12/10/15 Page 3 of 4 Dated: December 10, 2015 Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Boies, Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 David Boies Boies, Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Ellen Brockman Boies, Schiller & Flexner LLP 575 Lexington Ave New York, New York 10022 (212) 446-2300 3  Case 1:15-cv-07433-RWS Document 21 Filed 12/10/15 Page 4 of 4 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on December 10, 2015, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. Laura A. Menninger, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: [email protected] /s/ Sigrid S. McCawley Sigrid S. McCawley 4