https://archive.org/download/gov.uscourts.nysd.447706/gov.uscourts.nysd.447706.165.0.pdf

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
--------------------------------------------------X
VIRGINIA L. GIUFFRE,
Plaintiff,
v.
GHISLAINE MAXWELL,
Defendant.
15-cv-07433-RWS
--------------------------------------------------X
Declaration Of Laura A. Menninger In Support Of
Motion To Compel All Attorney-Client Communications and Attorney
Work Product Placed At Issue by Plaintiff and Her Attorneys
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
   Ms. Maxwell’s Motions to Compel All Attorney-Client Communications and Attornty Work
   Product Placed At Issue by Plaintiff and Her Attorney.
2. Attached as Exhibit A is a true and correct copy of excerpts categorically logged
   entries from Plaintiff Giuffre's Revised Supplemental Privilege Log dated April 29, 2016.
3. Attached as Exhibit B is a true and correct copy of Plaintiff Giuffre’s Discovery
   Second Amended Supplemental Response to Interrogatory No. 3 concerning her attorney
   representations, dated April 29, 2016.
   ..........................................
   ......
   Case 1:15-cv-07433-LAP Document 165 Filed 05/26/16 Page 1 of 4

2

1. Attached as Exhibit C (filed under seal)
2. Attached as Exhibit D is a true and correct copy of the Order in the CVRA Case
   dated April 6, 2015.
3. Attached as Exhibit E is a true and correct copy of the Motion for Summary
   Judgment in the Edwards and Cassell v. Dershowitz, Case No. 15-00072, In and for the
   Seventeenth Judicial District, Broward County, Florida (“Dershowitz Case”) dated November
   25, 2015.
4. Attached as Exhibit F is a true and correct copy of the Complaint in the
   Dershowitz Case dated January 6, 2015.
5. Attached as Exhibit G is a true and correct copy of the Notice of Serving Answers
   to Interrogatories in Dershowitz Case dated March 13, 2015.
6. Attached as Exhibit H (filed under seal)
7. Attached as Exhibit I is a true and correct copy of the Declaration of Virginia
   Giuffre in the Dershowitz Case dated November 20, 2015.
8. Attached as Exhibit J (filed under seal)
   Case 1:15-cv-07433-LAP Document 165 Filed 05/26/16 Page 2 of 4

3

1. Attached as Exhibit K (filed under seal)
2. Attached as Exhibit L is a true and correct copy of the October 16, 2015
   Deposition of Paul G. Cassell taken in the Edwards and Cassell v. Dershowitz, In and for the
   Seventeenth Judicial District, Broward County, Florida matter.
3. Attached as Exhibit M is a true and correct copy of the press release issued by the
   parties in the Dershowitz Case on April 8, 2016.
4. Attached as Exhibit N is a true and correct copy of the interview of Virginia
   Roberts by Edwards and Scarola in the Epstein v. Rothstein, Edwards, and L.M, In and for the
   Fifteenth Judicial District, Palm Beach County, Florida (“Epstein Case”).
5. Attached as Exhibit O is a true and correct copy of the May 17, 2011 Notice of
   Filing of the interview in the Epstein Case.
6. Attached as Exhibit P is a true and correct copy of a portion of the ECF Docket
   Sheet in the CVRA Case.
7. Attached as Exhibit Q is a true and correct copy of the document produced by
   Plaintiff in this matter as GIUFFRE000862-000887.
   By: /s/ Laura A. Menninger
   Laura A. Menninger
   Case 1:15-cv-07433-LAP Document 165 Filed 05/26/16 Page 3 of 4

4
CERTIFICATE OF SERVICE
I certify that on May 26, 2016, I electronically served this Declaration Of Laura A.
Menninger In Support Of Motion To Compel All Attorney-Client Communications and Attornty
Work Product Placed At Issue by Plaintiff and her Attorney via ECF on the following:
Sigrid S. McCawley
Meridith Schultz
BOIES, SCHILLER & FLEXNER, LLP
401 East Las Olas Boulevard, Ste. 1200
Ft. Lauderdale, FL 33301
[email protected]
[email protected]
Paul G. Cassell
S.J. Quinney College of Law, University of
Utah
383 S. University Street
Salt Lake City, UT 84112
[email protected]
Bradley J. Edwards
FARMER, JAFFE, WEISSING, EDWARDS,
FISTOS & LEHRMAN, P.L.
425 North Andrews Ave., Ste. 2
Ft. Lauderdale, FL 33301
[email protected]
/s/ Nicole Simmons
Nicole Simmons
Case 1:15-cv-07433-LAP Document 165 Filed 05/26/16 Page 4 of 4