## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

X

Plaintiff,

v.

GHISLAINE MAXWELL,

Defendant.

X

15-cv-07433-RWS

## Declaration Of Laura A. Menninger In Support Of Defendant's Sur Sur Reply In Support of Motion for Rule 37(b) & (c) Sanctions

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, & P.C., counsel of record for Defendant Ghislaine Maxwell ("Maxwell") in this action. I respectfully submit this declaration in support of Reply to Plaintiffs Opposition to Defendant's Motion To Reopen Plaintiff's Deposition.

1. Attached as Exhibit U (filed under seal) are true and correct copies of excerpts

1. Attached as Exhibit V (filed under seal) are true and correct copies of Exhibit 6

1. Attached as Exhibit W (filed under seal) are true and correct copies of Exhibit 7

1. Attached as Exhibit X (filed under seal) is a true and correct copy of a letter from Laura A. Menninger to Meredith dated July 14, 2016.

Dated: July 25, 2016

By: Is/ Laura A. Menninger

Laura A. Menninger

## CERTIFICATE OF SERVICE

I certify that on July 25, 2016, I electronically served this Declaration Of Laura A. Menninger In Support Of Defendant's Sur Sur Reply In Support of Motion for Rule 37(b) & (c) Sanctions via ECF on the following:

Sigrid S. McCawley Meredith Bows, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 smccawley@bsfllp.com mschultz@bsfllp.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 Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 StanPottinger@aol.com

Is/ Nicole

Nicole