RE: Ghislaine Maxwell Redacted Documents

[smartscheme]

https://www.archive.org/download/gov.uscourts.nysd.447706/gov.uscourts.nysd.447706.21.0.pdf

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United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF
PLAINTIFF’S OPPOSITION TO DEFENDANT’S MOTION TO STAY
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
   Opposition to Defendant Maxwell’s Motion to Stay.
3. Attached hereto as Exhibit 1, is a true and correct copy of the Government’s
   September 3, 2008 Victim Notification Letter.
4. Attached hereto as Composite Exhibit 2, is a true and correct copy of flight logs
   for Jeffrey Epstein’s private jet, and a summary chart reflecting flights where Ms. Giuffre and
   Defendant were listed as passengers, and a chart listing the airport codes.
5. Attached hereto as Exhibit 3, is a true and correct copy of a picture of Prince
   Andrew, Ghislaine Maxwell and Virginia Roberts Giuffre.
   Case 1:15-cv-07433-RWS Document 21 Filed 12/10/15 Page 1 of 4

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1. Attached hereto as Exhibit 4, is a true and correct copy of Excerpts from the July
   29, 2009 and August 7, 2009 Deposition Transcripts of Alfredo Rodriguez.
2. Attached hereto as Composite Exhibit 5, is a true and correct copy of the Palm
   Beach Police Reports dated March 14, 2005 and July 28, 2006.
3. Attached hereto as Exhibit 6, is a true and correct copy of Excerpts from the
   September 8, 2009 Deposition Transcript of Juan Alessi.
4. Attached hereto as Exhibit 7, is a true and correct copy of Juan Alessi’s
   November 21, 2005 Sworn Statement.
5. Attached hereto as Composite Exhibit 8, is a true and correct copy of the Notice
   of Deposition of Ghislaine Maxwell, Subpoena and Cancellation Payment Notice, and January
   13, 2015 Daily Mail, “Bill Clinton pictured with Jeffrey Epstein’s social fixer at Chelsea’s
   wedding AFTER severing links with disgraced pedophile.”
6. Attached hereto as Exhibit 9, is a true and correct copy of Plaintiff’s First Request
   for Production of Documents to Defendant, dated October 27, 2015.
   I declare under penalty of perjury that the foregoing is true and correct.
   /s/ Sigrid S. McCawley______
   Sigrid S. McCawley, Esq.
   Case 1:15-cv-07433-RWS Document 21 Filed 12/10/15 Page 2 of 4

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Dated: December 10, 2015
Respectfully Submitted,
BOIES, SCHILLER & FLEXNER LLP
By: /s/ Sigrid McCawley
Sigrid McCawley (Pro Hac Vice)
Boies, Schiller & Flexner LLP
401 E. Las Olas Blvd., Suite 1200
Ft. Lauderdale, FL 33301
[phone]
David Boies
Boies, Schiller & Flexner LLP
333 Main Street
Armonk, NY 10504
Ellen Brockman
Boies, Schiller & Flexner LLP
575 Lexington Ave
New York, New York 10022
[phone]
Case 1:15-cv-07433-RWS Document 21 Filed 12/10/15 Page 3 of 4

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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on December 10, 2015, I electronically filed the foregoing
document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing
document is being served this day on the individuals identified below via transmission of Notices of
Electronic Filing generated by CM/ECF.
Laura A. Menninger, Esq.
HADDON, MORGAN & FOREMAN, P.C.
150 East 10th Avenue
Denver, Colorado 80203
Tel: [phone]
Fax: [phone]
Email: [email protected]
/s/ Sigrid S. McCawley
Sigrid S. McCawley

Case 1:15-cv-07433-RWS Document 21 Filed 12/10/15 Page 4 of 4