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Case 1:15-cv-07433-LAP Document 1218-23 Filed 07/15/21 Page 1 of 5
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 MCCAWLEY IN SUPPORT OF
PLAINTIFF’S RESPONSE IN OPPOSITION TO MOTION TO INTERVENE (DE 362)
I, Sigrid 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 Response in
Opposition to Motion to Intervene (DE 362).
3. Attached hereto as Exhibit 1 is a true and correct copy of January 22, 2015,
Local 10 News Article.
4. Attached hereto as Sealed Exhibit 2 is a true and correct copy of Flight Logs.
5. Attached hereto as Exhibit 3 is a true and correct copy of March 18, 2000, Article
from the NewsRoom.
6. Attached hereto as Sealed Exhibit 4 is a true and correct copy of Excerpts from
January 16, 2015, Deposition of Virginia Giuffre.
7. Attached hereto as Exhibit 5 are a true and correct copies of July 7, 2016, Radar
Case 1:15-cv-07433-LAP Document 1218-23 Filed 07/15/21 Page 2 of 5
Online Article.
8. Attached hereto as Sealed Exhibit 6 is a true and correct copy of Excerpts from
September 8, 2009, Deposition of Juan Alessi.
9. Attached hereto as Exhibit 7 is a true and correct copy of January 22, 2015, Local
10 News Article.
10. Attached hereto as Sealed Composite Exhibit 8 are excerpts from the Deposition
of .
11. Attached hereto as Composite Sealed Exhibit 9 is a true and correct copy of
Excerpts the depositions of .
12. Attached hereto as Sealed Composite Exhibit 10 is a true and correct copy of
Deposition Excerpts from Detective Joseph Recarey and the Article “How Alan Dershowitz
Bullied Rape Victims to Protect a Serial Child Molester.”
13. Attached hereto as Exhibit 11 is a true and correct copy of the June 2, 2016
Notice of Appeal.
14. Attached hereto as Exhibit 12 is a true and correct copy of November 12, 2015
Order on Motion to Quash.
15. Attached hereto as Exhibit 13 is a true and correct copy of Excerpts from January
16, 2015, Deposition of Virginia Giuffre.
16. Attached hereto as Exhibit 14 is a true and correct copy of December 18, 2015,
Emergency Motion to Seal Hearing Transcript.
17. Attached hereto as Exhibit 15 is a true and correct copy of Order on Emergency
Motion to Seal.
18. Attached hereto as Exhibit 16 is a true and correct copy of the Motion for
Sanctions.
Case 1:15-cv-07433-LAP Document 1218-23 Filed 07/15/21 Page 3 of 5
19. Attached hereto as Exhibit 17 is a true and correct copy of the Supplement to
Motion for Sanctions.
20. Attached hereto as Exhibit 18 is a true and correct copy of excerpts from the
March 17, 2016, Hearing Transcript.
21. Attached hereto as Exhibit 19 is a true and correct copy of excerpts from the
April 21, 2016, Hearing Transcript
22. Attached hereto as Exhibit 20 is a true and correct copy of January 22, 2015,
Local 10 News Article.
23. Attached hereto as Exhibit 21 is a true and correct copy of the article from CNN
International, New Day, January 6, 2015.
24. Attached hereto as Exhibit 22 is a true and correct copy of the article from
Australian Broadcasting System (ABC), January 6, 2015.
25. Attached hereto as Exhibit 23 is a true and correct copy of the article from
Newsmax, April 8, 2015.
I declare under penalty of perjury that the foregoing is true and correct.
/s/ Sigrid S. McCawley______________
Sigrid S. McCawley, Esq.
Case 1:15-cv-07433-LAP Document 1218-23 Filed 07/15/21 Page 4 of 5
Dated: August 29, 2016.
Respectfully Submitted,
BOIES, SCHILLER & FLEXNER LLP
By: /s/ Sigrid McCawley
Sigrid 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
4
Case 1:15-cv-07433-LAP Document 1218-23 Filed 07/15/21 Page 5 of 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 29th 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/ Meredith L. Schultz
Meredith L. Schultz
5
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 MCCAWLEY IN SUPPORT OF
PLAINTIFF’S RESPONSE IN OPPOSITION TO MOTION TO INTERVENE (DE 362)
I, Sigrid 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 Response in
Opposition to Motion to Intervene (DE 362).
3. Attached hereto as Exhibit 1 is a true and correct copy of January 22, 2015,
Local 10 News Article.
4. Attached hereto as Sealed Exhibit 2 is a true and correct copy of Flight Logs.
5. Attached hereto as Exhibit 3 is a true and correct copy of March 18, 2000, Article
from the NewsRoom.
6. Attached hereto as Sealed Exhibit 4 is a true and correct copy of Excerpts from
January 16, 2015, Deposition of Virginia Giuffre.
7. Attached hereto as Exhibit 5 are a true and correct copies of July 7, 2016, Radar
Case 1:15-cv-07433-LAP Document 1218-23 Filed 07/15/21 Page 2 of 5
Online Article.
8. Attached hereto as Sealed Exhibit 6 is a true and correct copy of Excerpts from
September 8, 2009, Deposition of Juan Alessi.
9. Attached hereto as Exhibit 7 is a true and correct copy of January 22, 2015, Local
10 News Article.
10. Attached hereto as Sealed Composite Exhibit 8 are excerpts from the Deposition
of .
11. Attached hereto as Composite Sealed Exhibit 9 is a true and correct copy of
Excerpts the depositions of .
12. Attached hereto as Sealed Composite Exhibit 10 is a true and correct copy of
Deposition Excerpts from Detective Joseph Recarey and the Article “How Alan Dershowitz
Bullied Rape Victims to Protect a Serial Child Molester.”
13. Attached hereto as Exhibit 11 is a true and correct copy of the June 2, 2016
Notice of Appeal.
14. Attached hereto as Exhibit 12 is a true and correct copy of November 12, 2015
Order on Motion to Quash.
15. Attached hereto as Exhibit 13 is a true and correct copy of Excerpts from January
16, 2015, Deposition of Virginia Giuffre.
16. Attached hereto as Exhibit 14 is a true and correct copy of December 18, 2015,
Emergency Motion to Seal Hearing Transcript.
17. Attached hereto as Exhibit 15 is a true and correct copy of Order on Emergency
Motion to Seal.
18. Attached hereto as Exhibit 16 is a true and correct copy of the Motion for
Sanctions.
Case 1:15-cv-07433-LAP Document 1218-23 Filed 07/15/21 Page 3 of 5
19. Attached hereto as Exhibit 17 is a true and correct copy of the Supplement to
Motion for Sanctions.
20. Attached hereto as Exhibit 18 is a true and correct copy of excerpts from the
March 17, 2016, Hearing Transcript.
21. Attached hereto as Exhibit 19 is a true and correct copy of excerpts from the
April 21, 2016, Hearing Transcript
22. Attached hereto as Exhibit 20 is a true and correct copy of January 22, 2015,
Local 10 News Article.
23. Attached hereto as Exhibit 21 is a true and correct copy of the article from CNN
International, New Day, January 6, 2015.
24. Attached hereto as Exhibit 22 is a true and correct copy of the article from
Australian Broadcasting System (ABC), January 6, 2015.
25. Attached hereto as Exhibit 23 is a true and correct copy of the article from
Newsmax, April 8, 2015.
I declare under penalty of perjury that the foregoing is true and correct.
/s/ Sigrid S. McCawley______________
Sigrid S. McCawley, Esq.
Case 1:15-cv-07433-LAP Document 1218-23 Filed 07/15/21 Page 4 of 5
Dated: August 29, 2016.
Respectfully Submitted,
BOIES, SCHILLER & FLEXNER LLP
By: /s/ Sigrid McCawley
Sigrid 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
4
Case 1:15-cv-07433-LAP Document 1218-23 Filed 07/15/21 Page 5 of 5
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 29th 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/ Meredith L. Schultz
Meredith L. Schultz
5