Giuffre_Maxwell_Batch1_p00623.png

Case 1:15-cv-07433-LAP Document 1320-28 Filed 01/03/24 Page 30 of 32 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ween eee eee eee xX VIRGINIA L. GIUFFRE, Plaintiff, : v. : 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. cece x 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: 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. lama 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) is a true and correct copy of excerpts from the Deposition of Rinaldo Rizzo on June 10, 2016, and designated by Plaintiff as Confidential under the Protective Order. 3. Attached as Exhibit B (filed under seal) is a true and correct copy of The Billionaire Playboys Club book manuscript drafted by Plaintiff, designated by Plaintiff as Confidential under the Protective Order