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House Oversight — DOJ production

DOJ-OGR-00002378

Format
pdf
File
134-02.pdf
Set
House Oversight (DOJ)
Pages
23
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Case 1:20-cr-00330-AJN Document 134-2 Filed 02/04/21 Page 1 of 23 EXHIBIT B DOJ-OGR- 00002378 

Caged :2Osrc0QPARoRWHopunEHca? Filed 02/04/26 Page 2 of £3 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-00002379 

Caged 2G src 0QPARERWHopunEHca? Filed 02/04/26 Page 2 of 23 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- 00002380 

Caged 2Osrc0QPARERWHopunEHca? Filed 02/04/26 Pages of 23 Dated: March 4, 2016 Respectfully Sub

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