An attorney affidavit seeking arrest of a material witness, Dec. 2021

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK¶

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X¶

UNITED STATES OF AMERICA,¶

Plaintiff,¶

v. 20-CR-330-AJN¶

GHISLAINE MAXWELL,¶

Defendant.¶

X¶

AFFIDAVIT OF LAURA A. MENNINGER UNDER 28 U.S.C. 3144¶

I, Laura A. Menninger, 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, declare the following is true and correct under penalty of perjury pursuant to 28 U.S.C. § 3144:¶

• 1. I am a member of the law firm Haddon, . P.C., counsel of record for Defendant Ghislaine Maxwell (“Maxwell”) in the above captioned case.
• 2. is a material witness in this case for the defense. As described in Ms. Maxwell’s December 16, 2021 letter to this Court opposing the government’s motion to preclude from testifying, which Ms. Maxwell incorporates by reference, has relevant, material, and exculpatory testimony to provide in Ms. Maxwell’s defense.
• 3. was served with a trial subpoena, issued by this Court’s Clerk, on November 30, 2021.
• 4. is refusing to appear and testify as the subpoena commands.
• 5. We made diligent efforts to contact and even to put her on call for the testimony.
• 6. has not responded to our attempts to contact her.
• 7. She has not appeared as commanded by the subpoena.
• 8. Because has refused to comply with the subpoena, it is “impracticable to secure the presence of the person by subpoena” under the statute. § 3144.
• 9. And because the trial is ongoing, and because is not responding to our attempts to contact her, her testimony “can[not] adequately be secured by deposition.” § 3144.
• 10. Accordingly, under 28 U.S.C. § 3144, this Court can order arrest.

I hereby certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements are willfully false, I am subject to punishment.¶

Dated: December 17, 2021. New York, New York¶

s/ Laura A. Menninger¶

Laura A. Met in er HADDON, AND P.C. 150 East 10th Avenue Denver, CO 80203 303.831.7364¶