Case 1:15-cv-07433-LAP Document 103 Filed 04/19/16 Page 1 of 4 United 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 OPPOSITION TO DEFENDANT'S MOTION TO DISCLOSE CRIMINAL INVESTIGATION BY LAW ENFORCEMENT, OR IN THE ALTERNATIVE TO STAY PROCEEDINGS 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 & 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 Motion for Protective Order regarding 3. Deposition. Attached hereto as Exhibit 1, is a true and correct copy of the 2009 Notice of Taking Deposition of Ghislaine Maxwell, Subpoena, Cancellation Notice, and Daily Mail Article. 4. Attached hereto as Exhibit 2, is a true and correct copy of the April 13, 2016 Correspondence from Assistant U.S. Attorney Villafaila to Laura Menninger. EFTA02781591