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Case 1:15-cv-07433-LAP Document 1331-20 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 MEREDITH SCHULTZ IN SUPPORT OF PLAINTIFF’S MOTION TO COMPEL ALL WORK PRODUCT AND ATTORNEY CLIENT COMMUNICATIONS WITH PHILIP BARDEN I, Meredith Schultz, declare that the below is true and correct to the best of my knowledge as follows: 1. Iam a Counsel 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 Order granting my Application to Appear Pro Hac Vice. 2. I respectfully submit this Declaration in Support of Plaintiff's Motion to Compel Communication All Work Product and Attorney Client Communications with Philip Barden. 3. Attached hereto as Sealed Composite Exhibit | is a true and correct copy of Defendant’s February 9, 2016; May 16, 2016; and August 1, 2016 Privilege Log. 4. Attached hereto as Sealed Exhibit 2 is a true and correct copy of January 6, 2017, Declaration of Philip Barden. 5. Attached hereto as Sealed Exhibit 3 is a true and correct copy of Excerpts from April 22, 2016, Deposition of Ghislaine Maxwell. 6. Attached hereto as Sealed Exhibit 4 is a true and correct copy of January 2, 2015, E-mail Correspondence (RG(UK)_00009).