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Case 18-2868, Document 285, 08/09/2019, 2628246, Page1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK wenn eee eee een ene eee xX VIRGINIA L. GIUFFRE, Plaintiff, : v. : 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. wenn eee eee eee eee X Declaration of Laura A. Menninger in Support of Defendant’s Reply in Support of Motion for Summary Judgment I, Laura A. Menninger, declare as follows: 1. Iam 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. Iam a member of the law firm Haddon, Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell in this action. I respectfully submit this Declaration in support of Ms. Maxwell’s Reply in Support of Motion for Summary Judgment.! 2. In Defendant’s Memorandum of Law in Support of Motion for Summary Judgment (filed Jan. 9, 2017), I included numbered paragraphs corresponding to undisputed facts from the movant’s perspective as contemplated by Local Civil Rule 56.1(a), together with the citation to admissible evidence as required by Fed. R. Civ. P. 56(c). See Doc. 541, passim. ‘At trial, defendant intends to produce either the custodian of record relevant to any disputed document or a certification in compliance with either Fed. R. Evid. P. 803 and/or 902. See Fed. R. Civ. P. 56(c). Apart from deposition testimony, the majority of non-deposition documents herein were either produced by plaintiff or obtained with releases signed by plaintiff.