136-07.pdf

Type: pdf
Source set: house-oversight-doj
Pages: 23
Text status: Searchable text available
OCR confidence: 0.9047258896899888

Extracted text

Case 1:20-cr-00330-AJN Document 136-7 Filed 02/04/21 Page 1 of 23 EXHIBIT G DOJ-OGR-00002443

Caged :2Osrc0QPARSERWHopunaHcaY Filed 02/04/26 Page 2 of 23 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS Vv. Ghislaine Maxwell, Defendant. DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF PLAINTIFF’S RESPONSE TO DEFENDANT’S MOTION FOR PROTECTIVE ORDER I, Sigrid S. 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 September 29, 2015 Order granting my Application to Appear Pro Hac Vice. 2. I respectfully submit this Declaration in support of Plaintiff Virginia Giuffre’s Response to Defendant’s Motion for Protective Order. 3. Attached hereto as Exhibit 1, is a true and correct copy of Plaintiff's February 5, 2016 Notice of Taking Videotaped Deposition of Defendant Ghislaine Maxwell. 4. Attached hereto as Exhibit 2, is a true and correct copy of the Re-Notice of Taking Videotaped Deposition of Defendant Ghislaine Maxwell. 5. Attached hereto as Exhibit 3, is a true and correct copy of Defendant’s counsel, Laura Menninger’s February 25, 2016 Email Correspondence to Sigrid McCawley. DOJ-OGR-00002444

Caged :2Osrc0QPRRERWHopunEHcaY Filed 02/04/26 Page 2 of £3 6. Attached hereto as Exhibit 4, is a true and correct copy of the Plaintiff's proposed Protective Order in redline format and clean format sent to Laura Menninger on February 25, 2016. Ts Attached hereto as Exhibit 5, is a true and correct copy of Plaintiffs proposed Protective Order in redline format and clean version. I declare under penalty of perjury that the foregoing is true and correct. /s/ Sigrid S. McCawley Sigrid S. McCawley, Esq. DOJ-OGR-00002445

Caged :2Osrc0QPARoRWHopunanch ay Filed 02/04/26 Pages of 23 Dated: March 4, 2016 Respectfully Su…

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