gov.uscourts.nysd.447706.1090.25_2.pdf

Case 1:15-cv-07433-LAP Document 1090-25 Filed 07/30/20 Page 1 of 3 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 Response in Opposition to Extending Deadline to Complete Depositions and Motion for Sanctions for Violations of Rule 45 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 (“Maxwell”) in this action. I respectfully submit this declaration in support of Defendant’s Response in Opposition to Extending Deadline to Complete Depositions and Motion for Sanctions for Violations of Rule 45. 2. Attached as Exhibit A (filed under seal) is a true and correct copy of excerpts from the Deposition of Rinaldo Rizzo on June 10, 2016, and designated by Plaintiff as Confidential under the Protective Order. 3. Attached as Exhibit B (filed under seal) is a true and correct copy of The Billionaire Playboys Club book manuscript drafted by Plaintiff, designated by Plaintiff as Confidential under the Protective Order Case 1:15-cv-07433-LAP Document 1090-25 Filed 07/30/20 Page 2 of 3  Case 1:15-cv-07433-LAP Document 1090-25 Filed 07/30/20 Page 3 of 3 13. Attached as Exhibit L (filed under seal) is the certificate of service for 14. Attached as Exhibit M is a true and correct copy of my correspondence to Plaintiff’s counsel of May 25, 2016. 15. Attached as Exhibit N is a Notice of Subpoena and Deposition for Sharon Churcher on June 16, and the certificate of service dated June 4. By: /s/ Laura A. Menninger Laura A. Menninger CERTIFICATE OF SERVICE I certify that on June 20, 2016, I electronically served this Declaration Of Laura A. Menninger In Support Of Defendant’s Response in Opposition to Extending Deadline to Complete Depositions and Motion for Sanctions for Violations of Rule 45 via ECF on the following: Sigrid S. McCawley Paul G. Cassell Meridith 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