Giuffre_Maxwell_Batch3_p00265.png

Case 1:15-cv-07433-LAP Document 1327-20 Filed 01/05/24 Page 1 of 4 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 SUPPLEMENT TO MOTION FOR ADVERSE INFERENCE INSTRUCTION BASED ON NEW INFORMATION I, Sigrid S. McCawley, declare that the below is true and correct to the best of my knowledge as follows: 1. Iam 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's Supplement to Motion for Adverse Inference Instruction Based on New Information. 3. Attached hereto as Exhibit 1 is a true and correct copy of July 29, 2016, Correspondence from Ty Gee. 4. Attached hereto as Sealed Exhibit 2 is a true and correct copy of Excerpt from April 22, 2016, Deposition of Ghislaine Maxwell. 5. Attached hereto as Sealed Exhibit 3 is a true and correct copy of Excerpt from July 22, 2016, Deposition of Ghislaine Maxwell. 6. Attached hereto as Sealed Exhibit 4 is a true and correct copy of Excerpts from June 10, 2016, Deposition of Rinaldo Rizzo.