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Extracted Text (OCR)
Case 1:15-cv-07433-LAP Document 1330-18 Filed 01/05/24 Page 1 of 3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
ae xX
VIRGINIA L. GIUFFRE,
Plaintiff, :
Vv. : 15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
veneer eeeeeneenene Xx
Declaration of Laura A. Menninger in Support of Defendant’s Response
in Opposition to Plaintiff's Motion to Reopen Defendant’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 in this action. I respectfully submit this Declaration in support of
Ms. Maxwell’s Response to Plaintiff's Motion to Reopen Defendant’s Deposition.
2. Attached as Exhibit A (filed under seal) are true and correct copies of excerpts from
the April 22, 2016 deposition of Ghislaine Maxwell, designated Confidential under the
Protective Order.
3. Attached as Exhibit B (filed under seal) are true and correct copies of
communication between Mr. Gow and Ms. Maxwell Bates stamped GM_01036-01044.
Extracted Information
Dates
Document Details
| Filename | Giuffre_Maxwell_Batch5_p00260.png |
| File Size | 208.5 KB |
| OCR Confidence | 92.8% |
| Has Readable Text | Yes |
| Text Length | 1,197 characters |
| Indexed | 2026-02-04 12:44:51.954515 |