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Case 1:15-cv-07433-LAP Document 1331-28 Filed 01/05/24 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ween nee eee eee 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 to “Motion to Compel” Work Product and Attorney-Client Communication with Philip Barden 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 “Motion to Compel” Work Product and Attorney-Client Communications with Philip Barden. 2. Attached as Exhibit A (filed under seal) are true and correct copies of excerpts from Ms. Maxwell’s Initial F. R.C.P. 26(a)(1)(A) Disclosures, dated February 24, 2016. I declare under penalty of perjury that the foregoing is true and correct. Executed on March 2, 2017. s/ Laura A. Menninger Laura A. Menninger