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Caged 2Osic0QPARBSaRWHopunanchiay Filed 02/04/26 Page 2 of 23
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
Vv.
Ghislaine Maxwell,
Defendant.
DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF PLAINTIFE’S
RESPONSE TO DEFENDANT’S MOTION FOR PROTECTIVE ORDER
I, Sigrid S. 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 Virginia Giuffre’s
Response to Defendant’s Motion for Protective Order.
3. Attached hereto as Exhibit 1, is a true and correct copy of Plaintiff's February 5,
2016 Notice of Taking Videotaped Deposition of Defendant Ghislaine Maxwell.
4. Attached hereto as Exhibit 2, is a true and correct copy of the Re-Notice of
Taking Videotaped Deposition of Defendant Ghislaine Maxwell.
5. Attached hereto as Exhibit 3, is a true and correct copy of Defendant’s counsel,
Laura Menninger’s February 25, 2016 Email Correspondence to Sigrid McCawley.
DOJ-OGR-00002444
Extracted Information
Document Details
| Filename | DOJ-OGR-00002444.jpg |
| File Size | 546.8 KB |
| OCR Confidence | 92.8% |
| Has Readable Text | Yes |
| Text Length | 1,293 characters |
| Indexed | 2026-02-03 16:23:35.808790 |