gov.uscourts.nysd.447706.1200.12_1.pdf

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 SUPPLEMENT TO MOTION FOR ADVERSE INFERENCE INSTRUCTION BASED ON NEW INFORMATION 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’s Supplement to Motion for Adverse Inference Instruction Based on New Information. 3. Attached hereto as Exhibit 1 is a true and correct copy of July 29, 2016, Correspondence from Ty Gee. 4. Attached hereto as Sealed Exhibit 2 is a true and correct copy of Excerpt from April 22, 2016, Deposition of Ghislaine Maxwell. 5. Attached hereto as Sealed Exhibit 3 is a true and correct copy of Excerpt from July 22, 2016, Deposition of Ghislaine Maxwell. 6. Attached hereto as Sealed Exhibit 4 is a true and correct copy of Excerpts from June 10, 2016, Deposition of .  7. Attached hereto as Sealed Exhibit 5 is a true and correct copy of Excerpts from June 21, 2016, Deposition of Detective Joseph Recarey. 8. Attached hereto as Sealed Exhibit 6 is a true and correct copy of Excerpts from May 18, 2016, Deposition of 9. Attached hereto as Sealed Exhibit 7 is a true and correct copy of Excerpts from June 1, 2016, Deposition of Juan Alessi. 10. Attached hereto as Sealed Exhibit 8 is a true and correct copy of the sworn testimony of . 11. Attached hereto as Exhibit 9 is a true and correct copy of Rule 45 Subpoena to Microsoft. I declare under penalty of perjury that the foregoing is true and correct. /s/ Sigrid S. McCawley______________ Sigrid S. McCawley, Esq. Dated: August 8, 2016. Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid S. McCawley Sigrid S. McCawley (Pro Hac Vice) Meredith Schultz (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 Bradley J. Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake City, UT 84112 (801) 585-52021 1 This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. 3  CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 8th day of August, 2016, 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 to all parties of record via transmission of the Electronic Court Filing System generated by CM/ECF. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: [email protected] [email protected] /s/ Sigrid S. McCawley Sigrid S. McCawley 4