## United States District Court Southern District of New York

Plaintiff, Case No.: 15-cv-07433-RWS

v.

Ghislaine Maxwell,

Defendant.

## DECLARATION OF SIGRID MCCAWLEY IN SUPPORT OF PLAINTIFF'S MOTION TO EXCLUDE PHILIP BARDEN FROM TESTIFYING AT TRIAL, TO EXCLUDE DEFENSES BASED UPON CERTAIN DOCUMENTS AND TO EXCLUDE THEIR PRESENTATION AT TRIAL, FOR AN ADVERSE INFERENCE JURY INSTRUCTION, AND FOR ATTORNEY'S FEES

I, Sigrid McCawley, declare that the below is true and correct to the best of my knowledge as follows:

- 1. I am a Partner 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 Exclude Philip Barden from Testifying at Trial, To Exclude Defenses Based upon Certain Documents and to Exclude Their Presentation at Trial, For an Adverse Inference Jury Instruction, and For Attorney's Fees.
    - 3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of
    - 4. Attached hereto as Sealed Composite Exhibit 2 are true and correct copies of
- 5. Attached hereto as Sealed Exhibit 3 is a true and correct copy of

I declare under penalty of perjury that the foregoing is true and correct.

Dated: May 1, 2017.

Respectfully Submitted,

BOLES, SCHILLER & FLEXNER LLP

By: /s/ Sigrid McCawley

Sigrid McCaS (Pro Hac Vice)

Meredith (Pro Hac Vice)

Boles Schiller & Flexner LLP

401 E. Las Olas Blvd., Suite 1200

Ft. Lauderdale, FL 33301

(954) 356-0011

David Boies

Boies Schiller & Flexner LLP

333 Main Street

Armonk, NY 10504

a FISTOS & LEHRMAN, P.L.

J.it (Pro Hac Vice)

. JAFFE, WEISSING,

425 North Andrews Avenue, Suite 2

Fort Lauderdale, Florida 33301

(954) 5242820

Paul G. Cassell (Pro Hac Vice)

S.J. Quinney College of Law

University of Utah

383 University St.

Salt Lake City, UT 84112

(801) 585-5202'

This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation.

## CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 1st day of May 2017, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served to all parties of record via transmission of the Electronic Court Filing System generated by CM/ECF.

Laura A. Menninger, Esq.

Jeffrey Pagliuca,

HADDON, & P.C.

150 East 10 Avenue

Denver, Colorado 80203

Tel: (303) 831-7364

Fax: (303) 832-2628

Email: Imenninger@hmflaw.com

jnagliucagimflaw.com

/s/ Sigrid McCawley

Sigrid McCawley