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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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VIRGINIA L. GIUFFRE,
Plaintiff,
v.
GHISLAINE MAXWELL,
Defendant.
15-cv-07433-RWS
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Declaration Of Laura A. Menninger In Support Of Defendant’s Motion
For Rule 37(B) &(C) Sanctions For Failure To Comply With Court Order
And Failure To Comply With Rule 26(A)
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, Morgan & Foreman, P.C., counsel of record for Defendant
Ghislaine Maxwell (“Maxwell”) in this action. I respectfully submit this declaration in support of
Defendant’s Motion for Rule 37(b) &(c) Sanctions for Failure to Comply with Court Order and
Failure to Comply with Rule 26(a).
2.
Attached as Exhibit A is a true and correct copy of excerpts from Plaintiff’s
Response and Objections to Defendant’s First Set of Discovery Requests to Plaintiff, served
March 16, 2016.
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Case 1:15-cv-07433-LAP Document 1320-34 Filed 01/03/24 Page 1 of 4