Case 1:15-cv-07433-LAP Document 1320-34 Filed 01/03/24 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, v. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. X Declaration Of Laura A. Menninger In Support Of Defendant's Motion For Rule 37(B) &(C) Sanctions For Failure To Comply With Court Order And Failure To Comply With Rule 26(A) 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, & P.C., counsel of record for Defendant Ghislaine Maxwell ("Maxwell") in this action. I respectfully submit this declaration in support of Defendant's Motion for Rule 37(b) &(c) Sanctions for Failure to Comply with Court Order and Failure to Comply with Rule 26(a). 2. Attached as Exhibit A is a true and correct copy of excerpts from Plaintiff's Response and Objections to Defendant's First Set of Discovery Requests to Plaintiff, served March 16, 2016. EFTA02792638