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Case 1:15-cv-07433-RWS Document 751 Filed 03/17/17 Page 1 of 5
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
VIRGINIA L. GIUFFRE,
v.
Plaintiff,
15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
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Declaration of Laura A. Menninger in Support of
Response in Opposition to Plaintiff’s Omnibus Motion in Limine
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 in this action. I respectfully submit this Declaration in support of
Ms. Maxwell’s Response in Opposition to Plaintiff’s Omnibus Motion in Limine.
2. Attached as Exhibit A is a true and correct copy of a statement on behalf of Ms.
Maxwell dated January 2, 2015.
3. Attached as Exhibit B is a true and correct copy of an article by Sharon Churcher
titled “Teenage girl recruited by paedophile Jeffrey Epstein reveals how she twice met Bill
Clinton,” DAILY MAIL, dated March 5, 2011.
Case 1:15-cv-07433-RWS Document 751 Filed 03/17/17 Page 2 of 5
4. Attached as Exhibit C (filed under seal) are true and correct copies of
5. Attached as Exhibit D (filed under seal) are true and correct copies of
6. Attached as Exhibit E (filed under seal) are true and correct copies of
7. Attached as Exhibit F (filed under seal) is a true and correct copy of
8. Attached as Exhibit G is a true and correct copy of an article by Sharon Churcher
titled “The Prince, a paedophile and the sex slave teen” The Daily Telegraph, dated February 28,
2011.
9. Attached as Exhibit H (filed under seal) is a true and correct copy of
10. Attached as Exhibit I is a true and correct copy of an article titled “Buckingham
Palace issues second deni

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