Draft: efta02804610

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¶