EFTA00605141.pdf

Case 1:15-cv-07433-RWS Document 229 Filed 06/20/16 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. GHISLAINE MAXWELL, Defendant. X 1S-cv-07433-RWS Declaration Of Laura A. Menninger In Support Of Defendant's Response in Opposition to Extending Deadline to Complete Depositions and Motion for Sanctions for Violations of Rule 45 I, Laura A. Menninger, declare as follows: I. 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 Defendant's Response in Opposition to Extending Deadline to Complete Depositions and Motion for Sanctions for Violations of Rule 45. 2. Attached as Exhibit A (filed under seal) 3. Attached as Exhibit B (filed under seal) is a true and correct copy of Confidential under the Protective Order drafted by Plaintiff, designated by Plaintiff as EFTA00605141 Case 1:15-cv-07433-RWS Document 229 Filed 06/20/16 Page 2 of 3 4. Attached as Exhibit C is a report by former FBI director, Louis Freeh. 5. Attached as Exhibit D (filed under seal) 6. Attached as Exhibit E are true and correct copies of May 23, 2016 correspondence from Meredith Shulz and May 25, 2016 correspondence from myself. 7. Attached as Exhibit F are true and correct copies of Notices of Subpoena with attachments for Jean Luc Brunel, served on February 16, 2016 and May 23, 2016, as well as correspondence regarding Mr. Brunei's deposition from counsel, Bradley Edwards. 8. Attached as Exhibit G is a Motion to Quash filed by counsel for Jeffrey Epstein in Broward County, Florida in Edwards and Cassell v. Dershoivitz, Case No. 15-0000072 on September 10, 2015. 9. Attached as Exhibit H is a true and correct copy of the Notice of Deposition and Subpoena for Jeffrey Epstein, served on counsel on April 27, 2016. 10. Subpoena for 11. Attached as Exhbit I are true and correct copies of the Notices of Deposition and and , served on counsel on April 27, 2016. Attached as Exhibit J (filed under seal) 12. Attached as Exhibit K (filed under seal) are Notices of Deposition and Subpoena for and a letter of production from Sigrid McCawley of June 17, 2016, designated as Confidential by Plaintiff under the Protective Order. 2 EFTA00605142 Case 1:15-cv-07433-RWS Document 229 Filed 06/20/16 Page 3 of 3 13. Attached as Exhibit' (filed under seal) is the certificate of service forU 14. Attached as Exhibit M is a true and correct copy of my correspondence to Plaintiff's counsel of May 25, 2016. 15. Attached as Exhibit N is a Notice of Subpoena and Deposition for Sharon Churcher on June 16, and the certificate of service dated June 4. By: Is/Laura A. Menninger Laura A. Menninger CERTIFICATE OF SERVICE I certify that on June 20, 2016, I electronically served this Declaration Of Laura A. Menninger In Support Of Defendant's Response in Opposition to Extending Deadline to Complete Depositions and Motion for Sanctions for Violations of Rule 45 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 smccawley@bsfllp.com mschultz@bsfllp.com Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, ■. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad@pathtojustice.com Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 cassellp@law.utah.edu J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 StanPottinger@aol.com Is/ Nicole Simmons Nicole Simmons 3 EFTA00605143