gov.uscourts.nysd.447706.47.0.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 RESPONSE TO PLAINTIFF’S MOTION TO COMPEL PRODUCTION OF DOCUMENTS SUBJECT TO IMPROPER PRIVILEGE 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 and Foreman. P.C., counsel of record for Defendant Ghislaine Maxwell (“Maxwell”) in this action. I respectfully submit this declaration in support of Maxwell’s Response to Plaintiff’s Motion to Compel the Production of Documents Subject to Improper Privilege. 2. Attached as Exhibit A is a true and correct copy of the statement dated January 2, 2015, issued by Ross Gow on behalf of Ghislaine Maxwell. 3. Attached as Exhibit B is a true and correct copy of the attorney profile for Brett D. Jaffe of Alston & Bird, formerly of Cohen & Gresser, LLP.  4. Attached as Exhibit C is a true and correct copy of the attorney profile for Mark S. Cohen of Cohen & Gresser, LLP. 5. Attached as Exhibit D is a true and correct copy of the profile for Philip Barden of Devonshires Solicitors. 6. Attached as Exhibit E is a true and correct copy of Affidavit of Ghislaine Maxwell and two pertinent exhibits. I declare under penalty of perjury that the foregoing is true and correct. Executed on March 7, 2016 in Denver, Colorado. By: /s/ Laura A. Menninger Laura A. Menninger 2