gov.uscourts.nysd.447706.1090.11.pdf

Case 1:15-cv-07433-LAP Document 1090-11 Filed 07/30/20 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. ______________________________/ NON-REDACTED DECLARATION OF SIGRID S. MCCAWLEY IN SUPPORT OF PLAINTIFF VIRGINIA GIUFFRE’S RESPONSE TO MOTION TO COMPEL ATTORNEY-CLIENT COMMUNICATIONS AND ATTORNEY WORK PRODUCT MATERIALS I, Sigrid S. McCawley, declare that the below is true and correct to the best of my knowledge as follows: 1. I am an associate 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 Order granting my Application to Appear Pro Hac Vice. 2. I respectfully submit this Declaration in support of Plaintiff Virginia Giuffre’s Response in Opposition to Defendant’s Motion to Compel Attorney Client Communications and Attorney Work Product Materials. 3. Attached hereto as Exhibit 1, is a true and correct copy of Emergency Petition (CVRA Complaint) filed in Jane Doe 1 v. United States, No. 9:08-cv-80736 (S.D. Fla. July 7, 2008.  Case 1:15-cv-07433-LAP Document 1090-11 Filed 07/30/20 Page 2 of 5 4. Attached hereto as Exhibit 2, is a true and correct copy of the Jane Does’ 3 and 4 Corrected Joinder Motion (filed under seal). 5. Attached hereto as Exhibit 3, Response to Motion to Intervene (filed under seal). 6. Attached hereto as Exhibit 4, Order denying Jane Doe 3’s motion to join. 7. Attached hereto as Exhibit 5, is a true and correct copy of the Complaint in Edwards and Cassell v. Dershowitz. 8. Attached hereto as Exhibit 6 is a true and correct copy of Motion to Compel. 9. Attached hereto as Exhibit 7 is a true and correct copy of Response in Opposition to Motion to Compel. 10. Attached hereto as Exhibit 8 is a true and correct copy of Reply in Support of Motion to Compel. 11. Attached hereto as Exhibit 9 is a true and correct copy of Sur-Reply in Support Opposition to Motion to Compel 12. Attached hereto as Exhibit 10 is a true and correct copy of Order Denying Motion to Compel. 13. Attached hereto as Exhibit 11 is a true and correct copy of Composite Exhibit of Deposition Excerpts from the Deposition of Virginia Giuffre, at 22-23, 131-32; 173-74; 183; 200- 12 (filed under seal). 14. Attached hereto as Exhibit 12 is a true and correct copy of Notice of Withdrawal of Summary Judgment Motion. 15. Attached hereto as Exhibit 13 is a true and correct copy of Affidavit of Ms. Giuffre (May 30, 2016).  Case 1:15-cv-07433-LAP Document 1090-11 Filed 07/30/20 Page 3 of 5 16. Attached hereto as Exhibit 14 is a true and correct copy of Deposition excerpt of Paul Cassell, Volume I, dated Oct. 16, 2015, at 39:24 – 40:2. 17. Attached hereto as Exhibit 15 is a true and correct copy of Transcript of Scarola/Edwards interview on April 7, 2011. 18. Attached hereto as Exhibit 16 is a true and correct copy of Common interest agreement. I declare under penalty of perjury that the foregoing is true and correct. /s/ Sigrid McCawley Sigrid McCawley  Case 1:15-cv-07433-LAP Document 1090-11 Filed 07/30/20 Page 4 of 5 Dated: June 1, 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 Tel: (954) 356-0011 Email: [email protected] David Boies Boies, Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Paul G. Cassell (Pro Hac Vice) Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah 383 S. University St. Salt Lake City, UT 84112-0730 (801) 585-5202 (phone) (801) 585-2750 (fax) Email: [email protected] Bradley Edwards (Pro Hac Vice) Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Tel: (954) 524-2820 Fax: (954) 524-2822 Email: [email protected]  Case 1:15-cv-07433-LAP Document 1090-11 Filed 07/30/20 Page 5 of 5 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on May 4, 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 this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. Laura A. Menninger, Esq. Jeffrey Paliuca, 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, Esq.