Declaration (non-motion)

Case 1:15-cv-07433-LAP Document 1116 Filed 09/11/20 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, v. GHISLAINE MAXWELL, Defendant. VIRGINIA L. GIUFFRE, 15-cv-07433-LAP DECLARATION OF LAURA A. MENNINGER I, Laura A. Menninger, declare as follows: 1. I represent Ghislaine Maxwell in the above-captioned matter. 2. Pursuant to this Court’s August 26, 2020 Order (Doc. #1107), directing the Original Parties to serve Non-Party Notices on all remaining Non-Parties, as well as to Does 1 and 2 at newly obtained addresses, and after conferral with Plaintiff’s counsel, undersigned counsel agreed to serve Non-Party Notices to J. Doe 1 through J. Doe 92. 3. Pursuant to the Order and Protocol for Unsealing Decided Motions (Doc. # 1108), I used best efforts to obtain the most current addresses for J. Does 1 through J. Doe 92. 4. I mailed each of the following documents to the Non-Parties listed below in the manner described below: (1) Notice to Non-Parties of Possible Unsealing of Sealed Documents (Doc. # 1044); (2) Non-Party’s Request for Excerpts of Sealed Documents and Acknowledgement of Court Order and Protocol Governing the Excerpts (Id.); (3) Non-Party’s Case 1:15-cv-07433-LAP Document 1116 Filed 09/11/20 Page 2 of 3 Objection to Unsealing (Id.); and (4) Order and Protocol for Unsealing Decided Motions (Updated August 27, 2020) (Doc. # 1108) (collectively, “Non-Party Notices”). 5. On September 11, 2020, I sent Non-Party Notices via first-class certified mail (return receipt requested) and, for international addresses via UPS, to the following Non-Parties: • [repeated 16 times] J. Does 1 – 9 J. Does 11 – 23 J. Does 25 – 28 J. Doe 30 J. Doe 32 J. Doe 34 – 39 J. Doe 41 – 45 J. Doe 47 – 50 J. Doe 52 – 58 J. Doe 60 J. Doe 63 – 73 J. Doe 75 – 76 J. Doe 78 – 79 J. Doe 82 – 84 J. Doe 89 – 92 J. Doe 105 6. On September 11, I sent Non-Party Notices via e-mail to the following Non-Parties for whom only an email address was available despite best efforts to locate a physical address: • [repeated 3 times] J. Doe 10 J. Doe 77 J. Doe 81 7. For the following Non-Parties, I have not been able to locate an address and therefore have not provided them a Non-Party Notice: • [repeated 6 times] J. Doe 29 J. Doe 31 J. Doe 33 J. Doe 40 J. Doe 46 J. Doe 51 2 Case 1:15-cv-07433-LAP Document 1116 Filed 09/11/20 Page 3 of 3 • [repeated 6 times] J. Doe 61 – 62 J. Doe 74 J. Doe 80 J. Doe 85 J. Doe 86 J. Doe 88 8. I have not sent a Non-Party to the following Non-Parties who are deceased: • [repeated 3 times] J. Doe 24 J. Doe 59 J. Doe 87 I hereby declare under penalty of perjury that the foregoing statements are true and correct. Dated: September 11, 2020. Respectfully submitted, s/ Laura A. Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca (pro hac vice) Ty Gee (pro hac vice) HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 Fax: 303.832.2628 lmenninger@hmflaw.com Attorneys for Ghislaine Maxwell 3