gov.uscourts.nysd.447706.206.0.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 MEREDITH SCHULTZ IN SUPPORT OF MS. GIUFFRE’S MOTION FOR A PROTECTIVE ORDER REGARDING THE SUBPOENA TO APPLE, INC. SEEKING PRODUCTION OF ALL OF MS. GIUFFRE’S SENT AND RECEIVED EMAILS AND RELATED DATA I, Meredith L. Schultz, 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 March 28, 2016, Order granting my Application to Appear Pro Hac Vice. 2. I respectfully submit this Declaration in support of Plaintiff Virginia Giuffre’s Motion for a Protective Order Regarding the Subpoena to Apple, Inc. Seeking Production of All of Ms. Giuffre’s Sent and Received Emails and Related Data. 3. Attached hereto as Exhibit 1 is a true and correct copy of the June 10, 2016, letter to Ms. Menninger. 4. Attached hereto as Exhibit 2 is a true and correct copy of the Notice of Service of Rule 45 Subpoena upon Apple, Inc. 1  I declare under penalty of perjury that the foregoing is true and correct. Dated: June 13, 2016 /s/ Meredith L. Schultz _ Meredith Schultz, Esq. (Pro Hac Vice) 2  CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 13th day of June, 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 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 3