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nited States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. 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
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: I. I am a partner with the law firm of Boies, Schiller & Flexn
ne Maxwell, Defendant. DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF PLAINTIFF'S RESPONSE TO DEFENDANT'
ompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. II. Challenging Designations Of Protected Material (a) A Party shall not be obligated to challenge the propriety of any designation of discovery material under this Order at the time the designation
hire r California a New Jersey 4 FACSIMILE COVER SHEET TO: Laura Menninger, Esq. Haddon, Morgan and Foreman, P.C. Fax No. Telephone No. FROM: Sigrid S. McCawley, Esq. DATE: February 26, 2016 RE: .r . Maxwell, Case no. 15-cv-07433-RWS Total Number of Pages: 26 (including this cover sheet) MESSAGE: At
n, P.C. Fax No. Telephone No. FROM: Sigrid S. McCawley, Esq. DATE: February 26, 2016 RE: .r . Maxwel
ompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. 11. Challenging Designations Of Protected Material (a) A Party shall not be obligated to challenge the propriety of any designation of Discovery Material under this Order at the time the designation
Florida i California &New Jerse FACSIMILE COVER SHEET TO: Laura Menninger, Esq. Haddon, Morgan and Foreman, P.C. Fax No. Telephone No. FROM: Sigrid S. McCawley, Esq. DATE: February 26, 2016 RE: r. Maxwell, Case no. 15-cv-07433-RWS Total Number of Pages: 26 (including this cover sheet) MESSAGE: Atta
n, P.C. Fax No. Telephone No. FROM: Sigrid S. McCawley, Esq. DATE: February 26, 2016 RE: r. Maxwell,
ompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. 11. Challenging Designations Of Protected Material (a) A Party shall not be obligated to challenge the propriety of any designation of Discovery Material under this Order at the time the designation
ell's guilt. For example, Mr. Edwards opined that Ms. Maxwell was "a main facilitator" of Mr. Epstein's crimes who "started the whole thing." M Ms. McCawley praised the prosecutors: "[They] have done an incredible job and they're being very meticulous, they want to make sure that the Indictments stick. .
6-0022 FACSIMILE COVER SHEET TO: Laura Menninger, Esq. Haddon, Morgan and Foreman, P.C. Fax No. Telephone No. 303.832.2628 301831.7364 FROM: Sigrid S. McCawley, Esq. DATE: February 26, 2016 RE: v. Maxwell, Case no. 15-cv-07433-RWS Total Number of Pages: 26 (including this cover sheet) MESSAGE: Atta
ompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. 11. Challenging Designations Of Protected Material (a) A Party shall not be obligated to challenge the propriety of any designation of Discovery Material under this Order at the time the designation
Entities connected to both Sigrid McCawley and Challenging Designations Of Protected Material

David Boies
PERSON
Ghislaine Maxwell
PERSONLaura Menninger
PERSONthe Southern District
LOCATION
Foreman
PERSONHaddon
PERSONBates
PERSONSCHILLER & FLEXNER LLP
ORGANIZATIONthe Protected Material
ORGANIZATIONthe Receiving Party
ORGANIZATIONCONFIDENTIALshall
ORGANIZATIONthe Producing Party
ORGANIZATIONthe non-party
ORGANIZATION