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Case 1:15-cv-07433-LAP Document 1328-1 Filed 01/05/24 Page 1 of 3 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 Jeffrey S. Pagliuca In Support Of Defendant’s Response in Opposition to Plaintiff’s Motion to Enforce the Court’s Order and Direct Defendant to Answer Deposition Questions Filed Under Seal I, Jeffrey S. Pagliuca, declare as follows: 1. I am an attorney at law duly licensed in the State of Colorado and admitted to practice in the United States District Court for the Southern District of New York pro hac vice. I am 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 Response In Opposition to Plaintiffs Motion to Enforce the Court’s Order and Direct Defendant to Answer Deposition Questions Filed Under Seal. 2. Attached as Exhibit A (filed under seal) are true and correct copies of excerpts from the deposition of Virginia Giuffre, designated as Confidential under the Protective Order. 3. Attached as Exhibit B are true and correct copies of Bates stamped documents GM_00523-00528.