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Case 1:15-cv-07433-LAP Document 1320-34 Filed 01/03/24 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ween eee X VIRGINIA L. GIUFFRE, Plaintiff, : v. : 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. een x Declaration Of Laura A. Menninger In Support Of Defendant’s Motion For Rule 37(B) &(C) Sanctions For Failure To Comply With Court Order And Failure To Comply With Rule 26(A) 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. lam 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 Motion for Rule 37(b) &(c) Sanctions for Failure to Comply with Court Order and Failure to Comply with Rule 26(a). 2. Attached as Exhibit A is a true and correct copy of excerpts from Plaintiff's Response and Objections to Defendant’s First Set of Discovery Requests to Plaintiff, served March 16, 2016.