## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

X Plaintiff, v. GHISLAINE MAXWELL, Defendant.

15-cv-07433-RWS

## Declaration of

declare as follows: 1. I am an attorney at law duly licensed in the State of New York. 2. I am familiar generally with the subject matter of this action, No. 15-cv-07433-RWS (S.D.N.Y.). 3. Before, during and subsequent to April 2015, I was representing in specific ongoing legal matters. As of that time, and Ghislaine Maxwell were parties to a to which I am a party as 4. As legal counsel, I consider and • lawyers and Ms. Maxwell and her lawyers to have a -under the with respect to the plaintiff allegations relating to in "sexual trafficking" and related matters. 5 During the course of my representation of my communication with Ms. Menninger, including email communication, has involved the exchange of information that I deem to be attorney work product because it implicates my or Ms. Menninger's or both of our

mental impressions, conclusions, opinions and/or theories concerning legal matters within the

[REDACTED]

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

Executed on August 19, 2016.

[REDACTED]

## CERTIFICATE OF SERVICE

I certify that on August 19, 2016, I electronically served this Declaration of via ECF on the following:

Sigrid S. McCawley Meredith BOIES. SCHILLER & FLEXNER. LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale. FL 33301 smccawley@bsfilp.com mschultz@bsfilp.com

JAFFE, WEISSING, FISTOS & LEHRMAN, P.L. 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 brad@pathtojustice.com

Paul G. Cassell 383 S. University Street Salt Lake City, UT 84112 cassellp@law.utah.edu

J. Stanley Porringer 49 Twin Lakes Rd. South Salem, NY 10590 StanPottinger@aol.com

/s/ Nicole

Nicole