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    United States District Court Southern District of New York

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    Jennifer Van Laar
    This document is a declaration by Laura A. Menninger in support of Ghislaine Maxwell's Motion for Rule 37(B) &(C) Sanctions for Failure to Comply with Court Order and Failure to Comply with Rule 26(A). The declaration includes exhibits of correspondence between Menninger and Virginia Giuffre's attorneys regarding discovery requests and responses. Menninger declares that the exhibits are true and correct copies.

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    United States District Court Southern District of New York

    Uploaded by

    Jennifer Van Laar
    117 views4 pages
    This document is a declaration by Laura A. Menninger in support of Ghislaine Maxwell's Motion for Rule 37(B) &(C) Sanctions for Failure to Comply with Court Order and Failure to Comply with Rule 26(A). The declaration includes exhibits of correspondence between Menninger and Virginia Giuffre's attorneys regarding discovery requests and responses. Menninger declares that the exhibits are true and correct copies.

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    Document 34 Epstein Unsealed

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    1320-34

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    This document is a declaration by Laura A. Menninger in support of Ghislaine Maxwell's Motion for Rule 37(B) &(C) Sanctions for Failure to Comply with Court Order and Failure to Comply with Rule 26(A). The declaration includes exhibits of correspondence between Menninger and Virginia Giuffre's attorneys regarding discovery requests and responses. Menninger declares that the exhibits are true and correct copies.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    117 views4 pages

    United States District Court Southern District of New York

    Uploaded by

    Jennifer Van Laar
    This document is a declaration by Laura A. Menninger in support of Ghislaine Maxwell's Motion for Rule 37(B) &(C) Sanctions for Failure to Comply with Court Order and Failure to Comply with Rule 26(A). The declaration includes exhibits of correspondence between Menninger and Virginia Giuffre's attorneys regarding discovery requests and responses. Menninger declares that the exhibits are true and correct copies.

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    Case 1:15-cv-07433-LAP Document 1320-34 Filed 01/03/24 Page 1 of 4

    UNITED STATES DISTRICT COURT


    SOUTHERN DISTRICT OF NEW YORK

    --------------------------------------------------X

    ............................................
    VIRGINIA L. GIUFFRE,

    Plaintiff,
    v. 15-cv-07433-RWS
    GHISLAINE MAXWELL,

    Defendant.

    --------------------------------------------------X

    Declaration Of Laura A. Menninger In Support Of Defendant’s Motion


    For Rule 37(B) &(C) Sanctions For Failure To Comply With Court Order
    And Failure To Comply With Rule 26(A)

    I, Laura A. Menninger, declare as follows:

    1. I am 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. 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

    Defendant’s Motion for Rule 37(b) &(c) Sanctions for Failure to Comply with Court Order and

    Failure to Comply with Rule 26(a).

    2. Attached as Exhibit A is a true and correct copy of excerpts from Plaintiff’s

    Response and Objections to Defendant’s First Set of Discovery Requests to Plaintiff, served

    March 16, 2016.


    Case 1:15-cv-07433-LAP Document 1320-34 Filed 01/03/24 Page 2 of 4

    3. Attached as Exhibit B is a true and correct copy of excerpts from Plaintiff’s

    Amended and Supplemental Response and Objections to Defendant’s First Set of Discovery

    Requests to Plaintiff, served March 22, 2016.

    4. Attached as Exhibit C is a true and correct copy of Addendum to Plaintiff’s Rule

    26 Initial Disclosures, served March 22, 2016.

    5. Attached as Exhibit D is a true and correct copy of Plaintiff, Virginia Giuffre’s

    Revised Disclosure Pursuant to Fed. R. Civ. P. 26, served March 11, 2016.

    6. Attached as Exhibit E is a true and correct copy of the transcript of the hearing

    held before this Court on April 21, 2016.

    7. Attached as Exhibit F is a true and correct copy of Plaintiff’s Second Amended

    Supplemental Response and Objections to Defendant’s First Set of Discovery Requests to

    Plaintiff, served April 29, 2016.

    8. Attached as Exhibit G (filed under seal) is a true and correct copy of excerpts

    from the Deposition of Virginia Giuffre taken in the above captioned matter on May 3, 2016, and

    designated by Plaintiff as Confidential under the Protective Order.

    9. Attached as Exhibit H (filed under seal) is a true and correct copy of excerpts

    from the Deposition of Lynn Trude Miller taken in the above captioned matter on May 24, 2016,

    and designated by Plaintiff as Confidential under the Protective Order.

    10. Attached as Exhibit I (filed under seal) is a true and correct copy of medical

    records bates labeled GIUFFRE005498-005569, produced by Plaintiff on June 1, 2016.

    11. Attached as Exhibit J (filed under seal) is a true and correct copy of medical

    records bates labeled GIUFFRE005492-5496, produced by Plaintiff on May 25, 2016.

    2
    Case 1:15-cv-07433-LAP Document 1320-34 Filed 01/03/24 Page 3 of 4

    12. Attached as Exhibit K (filed under seal) is a true and correct copy of excerpts

    from the Deposition of Dr. Steven Olsen taken in the above captioned matter on May 26, 2016,

    and designated by Plaintiff as Confidential under the Protective Order.

    13. Attached as Exhibit L is a true and correct copy of a letter from Laura A.

    Menninger to Sigrid McCawley dated April 25, 2016 concerning discovery.

    14. Attached as Exhibit M is a true and correct copy of a letter from Sigrid McCawley

    to Laura A. Menninger and documents produced by Plaintiff bates labeled GIUFFRE005370-

    5430, produced by Plaintiff on May 12, 2016.

    15. Attached as Exhibit N is a true and correct copy of a letter from Sigrid McCawley

    to Laura A. Menninger enclosing documents based labeled GIUFFRE005607-5613, produced by

    Plaintiff on June 14, 2016.

    By: /s/ Laura A. Menninger


    Laura A. Menninger

    3
    Case 1:15-cv-07433-LAP Document 1320-34 Filed 01/03/24 Page 4 of 4

    CERTIFICATE OF SERVICE

    I certify that on June 20, 2016, I electronically served this Declaration Of Laura A.
    Menninger In Support Of Defendant’s Motion For Rule 37(B) &(C) Sanctions For Failure To
    Comply With Court Order And Failure To Comply With Rule 26(A) via ECF on the following:

    Sigrid S. McCawley Paul G. Cassell


    Meridith Schultz 383 S. University Street
    BOIES, SCHILLER & FLEXNER, LLP Salt Lake City, UT 84112
    401 East Las Olas Boulevard, Ste. 1200 cassellp@law.utah.edu
    Ft. Lauderdale, FL 33301
    smccawley@bsfllp.com
    mschultz@bsfllp.com
    J. Stanley Pottinger
    Bradley J. Edwards 49 Twin Lakes Rd.
    FARMER, JAFFE, WEISSING, EDWARDS, South Salem, NY 10590
    FISTOS & LEHRMAN, P.L. StanPottinger@aol.com
    425 North Andrews Ave., Ste. 2
    Ft. Lauderdale, FL 33301
    brad@pathtojustice.com
    /s/ Nicole Simmons
    Nicole Simmons

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