## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

X

Plaintiff,

v.

GHISLAENE MAXWELL,

Defendant.

X

15-cy-07433-RWS

## Declaration Of Laura A. Menninger In Support Of Motion To Compel All Attorney-Client Communications and Attorney Work Product Placed At Issue by Plaintiff and Her Attorneys

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 Ms. Maxwell's Motions to Compel All Attorney-Client Communications and Attomty Work Product Placed At Issue by Plaintiff and Her Attorney.

1. Attached as Exhibit A is a true and correct copy of excerpts categorically logged entries from Plaintiff Revised Supplemental Privilege Log dated April 29, 2016.

1. Attached as Exhibit B is a true and correct copy of Plaintiff Discovery Second Amended Supplemental Response to Interrogatory No. 3 concerning her attorney representations, dated April 29, 2016.

1. Attached as Exhibit C (filed under seal) [REDACTED]

[REDACTED]

[REDACTED]

[REDACTED]

5. Attached as Exhibit D is a true and correct copy of the Order in the CVRA Case dated April 6, 2015.

1. Attached as Exhibit E is a true and correct copy of the Motion for Summary Judgment in the [REDACTED] *and Cassell v. Dershowitz*, Case No. 15-00072, In and for the Seventeenth Judicial District, Broward County, Florida (“Dershowitz Case”) dated November 25, 2015.

1. Attached as Exhibit F is a true and correct copy of the Complaint in the Dershowitz Case dated January 6, 2015.

1. Attached as Exhibit G is a true and correct copy of the Notice of Serving Answers to Interrogatories in Dershowitz Case dated March 13, 2015.

1. Attached as Exhibit H (filed under seal) [REDACTED]

[REDACTED]

[REDACTED]

10. Attached as Exhibit I is a true and correct copy of the Declaration of [REDACTED]

[REDACTED] in the Dershowitz Case dated November 20, 2015.

11. Attached as Exhibit J (filed under seal) [REDACTED]

[REDACTED]

12. Attached as Exhibit K (filed under seal) [REDACTED]

[REDACTED]

[REDACTED]

13. Attached as Exhibit L is a true and correct copy of the October 16, 2015 Deposition of Paul G. Cassell taken in the [REDACTED] *and Cassell v. Dershowitz*, In and for the Seventeenth Judicial District, Broward County, Florida matter.

01. Attached as Exhibit M is a true and correct copy of the press release issued by the parties in the Dershowitz Case on April 8, 2016.

01. Attached as Exhibit N is a true and correct copy of the interview of [REDACTED] by [REDACTED] and Scarola in the *Epstein v. Rothstein*, [REDACTED], *and L.M.*, In and for the Fifteenth Judicial District, Palm Beach County, Florida (“Epstein Case”).

01. Attached as Exhibit O is a true and correct copy of the May 17, 2011 Notice of Filing of the interview in the Epstein Case.

01. Attached as Exhibit P is a true and correct copy of a portion of the ECF Docket Sheet in the CVRA Case.

01. Attached as Exhibit Q is a true and correct copy of the document produced by Plaintiff in this matter as GIUFFRE000862-000887.

By: *ls/ Laura A. Menninger*\
Laura A. Menninger

## CERTIFICATE OF SERVICE

I certify that on May 26, 2016, I electronically served this Declaration Of Laura A. Menninger In Support Of Motion To Compel All Attorney-Client Communications and Attornty Work Product Placed At Issue by Plaintiff and her Attorney via ECF on the following:

Sigrid S. McCawley Meridith BOIES, \$CHILLER & 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 S.J. Quinney College of Law, University of Utah 383 S. University Street Salt Lake City, UT 84112 cassellp@law.utah.edu

Is/ Nicole Nicole