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Case 1:15-cv-07433-LAP Document 1325-16 Filed 01/04/24 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ween eee X VIRGINIA L. GIUFFRE, Plaintiff, : Vv. : 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. veneer eeeeeneenene Xx Declaration Of Laura A. Menninger In Support Of Reply to Plaintiff’s Opposition to Defendant’s Motion To Reopen Plaintiff’s Deposition 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 Reply to Plaintiffs Opposition to Defendant’s Motion To Reopen Plaintiffs Deposition. 2. Attached as Exhibit O (filed under seal) are true and correct copies of select pages of Plaintiff's medical records bates labeled GIUFFRE 5089, 5316-18, 6631, designated as Confidential under the Protective Order. 3. Attached as Exhibit P (filed under seal) are true and correct copies of excerpts from the deposition of Anthony Figuera, designated as Confidential under the Protective Order.