## COMPOSITE
# EXHIBIT 7
(File Under Seal)
From: Erika Sent: Friday, April 29, 2016 6:19 PM To: Imenninger@hmflaw.com; jiiia@hmflaw.com Cc: Sigrid McCawley; Meredith Subject: v. Maxwell, Case no. 15-cv-07433-RWS Attachments: 2016-04-29 Supp. Response Letter to Counsel re April 25, 2016 Letter.pdf; Releases.pdf; GIUFFRE5350.pdf; GIUFFRE5351-5353.pdf; GIUFFRE5339-5341.pdf; GIUFFRE5342-5346.pdf, GIUFFRE5347-5349.pdt 2016-04-29 Second Amended Supplemental Responses and Objections.pdf; 2016-04-29 Revised Supplemental Privilege Log.pdf
Dear Counsel,
Please see attached Correspondence from Sigrid McCawley.
Thank you.
ERIKA LEGAL ASSISTANT IiOa ELL \\ \\ LEI 401 E. Las Olas Blvd.. Suite 12(X) Fort Lauderdale. FL 33301-2211 Telephone: 954-356-0011 Facsimile: 954.356.0022
4th EA5 Cl AS 50..LEVARD • SUITE I200. FC" T \_AL:DERDALE, FL 333012211• PH 954.356 00 I • FAX 954 356 0022
Sigrid S. McCawley, Esq. E-mail: smccawley@bsflIp.com
April 29, 2016
#### Via Electronic Mail
Laura A. Menninger, Esq. Jeffrey Paglitoi. HADDON, &a, P.C. 150 East 10 Avenue Denver, Colorado 80203
> Re: v. Maxwell, Case no. 15-ev-07433-RWS
Dear Ms. Menninger:
As a follow-up to my April 27, 2016 letter, I am providing you today with copies of the releases you requested as follows:
- Release for U.S. Tax and Australian Tax Records;
- Releases for any additional school records;
- Releases for the eight requested employers;
Kindly provide us with any copies of materials you receive in response to these Releases. All documents should be treated as Confidential until we have had an opportunity to review and any social security information should be redacted and not disclosed to anyone.
In addition, we are nroviding you with additional retainer letters from Counsel that have represented labelled Giuffit005350-Giuffre005353.
We are providing herewith additional medical records that we received, labelled Giuffre005339 - Giuffre005349.
Finally, we are providing you with Responses to Interrogatories 1, 3, 4, 9, and 12 as set forth in the Second Amended Supplemental Responses and Objections to Defendant's Fi f Discovery Requests, attached hereto. We expect to be able to provide you with verification page on Monday. We have also included a revised supplemental privilege log.
Letter to Laura Menninger, Esq. and Jeffrey Pagliuca, Esq.\
April 29, 2016\
Page 2
SSM:ep\
Enclosures








| Student Name:
Virginia Guiffre (formerly [REDACTED]) | |
| -------------------------------------------------------------- | --- |
| [REDACTED] | |
| [REDACTED] | |
| Telephone | |
The Family Educational Rights and Privacy Act of 1974, as amended, protects the privacy of educational records, establishes the rights of students to inspect and review their educational records, and provides guidelines for the correction of inaccurate or misleading data through informal and formal hearings. This release applies to the disclosure of educational records.
I hereby authorize Survivors Charter School to release the education records of Virginia Guiffre (formerly [REDACTED])
**To: Laura Menninger, HADDON, [REDACTED] & [REDACTED], PC, 150 East 10th Avenue, Denver, CO 80203. Tel: 303-831-7364; Fax: 303-832-2628**
These records are being released for the purpose of litigation in the case captioned *Virginia Guiffre v. Ghislaine Maxwell*, 15-CV-07433-RWS, in the United States District Court for the Southern District of New York.
The authorization includes all information in my educational records, including truancy records, attendance records, disciplinary records, grades, house, classes, financial information, graduation records, or any other records or information relating to my attendance at this educational facility.
\*\*\*\*\*
The above information will be released with my full consent. I understand that this authorization remains in effect unless specifically revoked. It will be necessary to send a written letter to revoke this authorization prior to the expiration date I have indicated, if I choose to end it sooner.
*[Handwritten signature and initials]*
Virginia Guiffre (file/a [REDACTED]) - Student Allowing Release of Information
**Student Name:**
Virginia Guiffre (formerly Virginia Roberts)
[Redacted Student Name]
[Redacted Student Name] Telephone
The Family Educational Rights and Privacy Act of 1974, as amended, protects the privacy of educational records, establishes the rights of students to inspect and review their educational records, and provides guidelines for the correction of inaccurate or misleading data through informal and formal hearings. This release applies to the disclosure of educational records.
I hereby authorize [Redacted] Palm Beach Community High School to release the education records of Virginia Guiffre (formerly [Redacted])
**To: Laura Menninger, HADDON, [Redacted] & [Redacted], PC, 150 East 10th Avenue, Denver, CO 80203. Tel: 303-831-7364; Fax: 303-832-2628**
These records are being released for the purpose of litigation in the case captioned *Virginia Guiffre v. Ghislaine Maxwell*, 15-CV-07433-RWS, in the United States District Court for the Southern District of New York.
The authorization includes all information in my educational records, including truancy records, attendance records, disciplinary records, grades, house, classes, financial information, graduation records, or any other records or information relating to my attendance at this educational facility.
\*\*\*\*\*
The above information will be released with my full consent. I understand that this authorization remains in effect unless specifically revoked. It will be necessary to send a written letter to revoke this authorization prior to the expiration date I have indicated, if I choose to end it sooner.
Virginia Guiffre (f/k/a [Redacted]) - Student Allowing Release of Information
| Student Name:
Virginia Guiffre (formerly [REDACTED]) | |
| -------------------------------------------------------------- | --------- |
| [REDACTED] | Telephone |
The Family Educational Rights and Privacy Act of 1974, as amended, protects the privacy of educational records, establishes the rights of students to inspect and review their educational records, and provides guidelines for the correction of inaccurate or misleading data through informal and formal hearings. This release applies to the disclosure of educational records.
I hereby authorize Forest [REDACTED] High School to release the education records of Virginia Guiffre (formerly [REDACTED])
**To: Laura Menninger, HADDON, [REDACTED] & [REDACTED], PC, 150 East 10th Avenue, Denver, CO 80203. Tel: 303-831-7364; Fax: 303-832-2628**
These records are being released for the purpose of litigation in the case captioned *Virginia Guiffre v. Ghislaine Maxwell*, 15-CV-07433-RWS, in the United States District Court for the Southern District of New York.
The authorization includes all information in my educational records, including truancy records, attendance records, disciplinary records, grades, house, classes, financial information, graduation records, or any other records or information relating to my attendance at this educational facility.
\*\*\*\*\*
The above information will be released with my full consent. I understand that this authorization remains in effect unless specifically revoked. It will be necessary to send a written letter to revoke this authorization prior to the expiration date I have indicated, if I choose to end it sooner.
\_\_\_\_\_\
Virginia Guiffre (f/k/a [REDACTED]) - Student Allowing Release of Information
| Student Name:
Virginia Guiffre (formerly [REDACTED]) | |
| -------------------------------------------------------------- | --- |
| [REDACTED] | |
| [REDACTED] | |
| Telephone | |
The Family Educational Rights and Privacy Act of 1974, as amended, protects the privacy of educational records, establishes the rights of students to inspect and review their educational records, and provides guidelines for the correction of inaccurate or misleading data through informal and formal hearings. This release applies to the disclosure of educational records.
I hereby authorize Crestwood Middle School to release the education records of Virginia Guiffre (formerly [REDACTED])
**To: Laura Menninger, HADDON, [REDACTED] & [REDACTED], PC, 150 East 10th Avenue, Denver, CO 80203. Tel: 303-831-7364; Fax: 303-832-2628**
These records are being released for the purpose of litigation in the case captioned *Virginia Guiffre v. Ghislaine Maxwell*, 15-CV-07433-RWS, in the United States District Court for the Southern District of New York.
The authorization includes all information in my educational records, including truancy records, attendance records, disciplinary records, grades, house, classes, financial information, graduation records, or any other records or information relating to my attendance at this educational facility.
\*\*\*\*\*
The above information will be released with my full consent. I understand that this authorization remains in effect unless specifically revoked. It will be necessary to send a written letter to revoke this authorization prior to the expiration date I have indicated, if I choose to end it sooner.
*[Handwritten signature]*\
Virginia Guiffre (f/k/a [REDACTED]) - Student Allowing Release of Information
| Employees Name:
Virginia Guiffre (formerly [REDACTED] ) | | [REDACTED] |
| ----------------------------------------------------------------------------------------------------------------------------- | --- | ---------------------------------------------------------------------- |
| | | Telephone |
| | | [REDACTED] |
I hereby authorize Roadhouse Grill to release information from the employment, payroll, workers compensation, and personnel records of Virginia Guiffre (formerly UM
To: Laura Menninger, HADDON,11.&fflp PC, 150 East 101° Avenue, Denver, CO 80203. Tel: 303-831-7 ; ax: 3
These records are being released for the purpose of litigation in the case captioned Virginia Guiffre v. Ghislaine Maxwell, 15-CV-07433-RWS, in the United States District Court for the Southern District of New York.
I specifically authorize the release of the following: all employment applications, payroll/salary records, letters of commendation or discipline, performance evaluation, vacation records, absenteeism records, medical records, requests for accommodations, and/or any and all records in my personnel files, however maintained.
This authorization is valid until the 180 day after it is signed, unless it is otherwise revoked.
The undersigned, have read and authorize the release of such information as herein contained. I have the right to revoke this authorization in writing at any time except to the extent that action has been taken in reliance upon it. I understand that when this information is used to disclose pursuant to this authorization, it may be subject to re-disclosure by the recipient and may no longer be protected. I hereby release and hold harmless the above named facility and its parent company from all liability and damages resulting from the lawful release of my protected health information.
Date 01 I Itb
Employees Name:
Virginia Guiffre (former))
I hereby authorize Mar-A-Lano Resort & Spa to release information from the employment, payroll, workers compensation, and personnel records of Virginia Guiffre (formed
To: Laura Menninger, HADDON,Mill PC, 150 East 10th Avenue, Denver, CO 80203. Tel: 303-831-7364; Fax: 303-832-2628
These records are being released for the purpose of litigation in the case captioned Virginia Guiffre v. Ghislaine Maxwell, 15-CV-07433-RWS, in the United States District Court for the Southern District of New York.
I specifically authorize the release of the following: all employment applications, payroll/salary records, letters of commendation or discipline, performance evaluation, vacation records, absenteeism records, medical records, requests for accommodations, and/or any and all records in my personnel files, however maintained.
th This authorization is valid until the 180 day after it is signed, unless it is otherwise revoked.
The undersigned, have read and authorize the release of such information as herein contained. I have the right to revoke this authorization in writing at any time except to the extent that action has been taken in reliance upon it. I understand that when this information is used to disclose pursuant to this authorization, it may be subject to re-disclosure by the recipient and may no longer be protected. I hereby release and hold harmless the above named facility and its parent company from all liability and damages resulting from the lawful release of my protected health information.
Date O )(2% ko
| Employees Name:
Virginia Guiffre (formerly [REDACTED]) | | [REDACTED] |
| ---------------------------------------------------------------- | --- | ---------- |
| | | Telephone |
| | | [REDACTED] |
I hereby authorize Manpower Logistics to release information from the employment, payroll, workers compensation, and personnel records of Virginia Guiffre (formerly 1
To: Laura Menninger, HADDON,3111 &111. PC, 150 East 10th Avenue, Denver, CO 80203. Tel: 303-831-7 ; as: 3
These records are being released for the purpose of litigation in the case captioned Virginia Guiffre v. Ghislaine Maxwell, 15-CV-07433-RWS, in the United States District Court for the Southern District of New York.
I specifically authorize the release of the following: all employment applications, payroll/salary records, letters of commendation or discipline, performance evaluation, vacation records, absenteeism records, medical records, requests for accommodations, and/or any and all records in my personnel files, however maintained.
ih This authorization is valid until the 180 day after it is signed, unless it is otherwise revoked.
The undersigned, have read and authorize the release of such information as herein contained. I have the right to revoke this authorization in writing at any time except to the extent that action has been taken in reliance upon it. I understand that when this information is used to disclose pursuant to this authorization, it may be subject to re-disclosure by the recipient and may no longer be protected. I hereby release and hold harmless the above named facility and its parent company from all liability and damages resulting from the lawful release of my protected health information.
Date 0(4 ) a% II°
| Employees Name:
Virginia Guiffre (formerly [REDACTED])
| [REDACTED] | | -------------------------------------------------------------------- | ---------- | | Telephone | [REDACTED] | I hereby authorize Mannwav Logistics to release information from the employment, payroll, workers compensation, and personnel records of Virginia Guiffre (formerly To: Laura Menninger, HADDON, Denver, CO 80203. Tel: 303-831-7364; Fax: 303-832-2628 PC, 150 East it Avenue, These records are being released for the purpose of litigation in the case captioned Virginia Guiffre v. Ghislaine Maxwell, 15-CV-07433-RWS, in the United States District Court for the Southern District of New York. 1 specifically authorize the release of the following: all employment applications, payroll/salary records, letters of commendation or discipline, performance evaluation, vacation records, absenteeism records, medical records, requests for accommodations, and/or any and all records in my personnel files, however maintained. th This authorization is valid until the 180 day after it is signed, unless it is otherwise revoked. The undersigned, have read and authorize the release of such information as herein contained. I have the right to revoke this authorization in writing at any time except to the extent that action has been taken in reliance upon it. I understand that when this information is used to disclose pursuant to this authorization, it may be subject to re-disclosure by the recipient and may no longer be protected. I hereby release and hold harmless the above named facility and its parent company from all liability and damages resulting from the lawful release of my protected health information. Date 04 I a.8 1 ty | Employees Name: