EFTA00029877.pdf

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pdf

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data-set-8

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Case 1:20-cr-00330-AJN Document 30 Filed 07/27/20 Page 1 of 2 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
 x 
• 
UNITED STATES OF AMERICA, 
• 
. 
AFFIDAVIT OF CERTIFICATION 
v. 
. 
PURSUANT TO LOCAL 
• 
CRIMINAL RULE 16.1 
GHISLAINE MAXWELL, 
. 
Defendant. 
20 Cr. 330 (AJN) 
• 
 x 
I, Christian R. Everdell, an attorney duly admitted to practice in New York State and 
before this Court, declare the following is true and correct under penalty of perjury pursuant to 
28 U.S.C. § 1746: 
1. 
I am a partner at Cohen & Gresser LLP, counsel for defendant Ghislaine Maxwell 
in the above-captioned case. 
2. 
I certify pursuant to Local Criminal Rule 16.1 that defense counsel has conferred 
in good faith with Assistant U.S. Attorneys 
and 
regarding the government's proposed protective order pursuant 
to Federal Rule of Criminal Procedure 16. 
3. 
While the parties have been able to agree on most of the provisions of the 
protective order, we have been unable to resolve two narrow areas of dispute. 
a. First, the defense believes that potential government witnesses and their 
counsel should be subject to the same restrictions as the defense concerning 
appropriate use of the discovery materials—namely, if these individuals are 
given access to discovery materials during trial preparation, they may not use 
EFTA00029877


Case 1:20-cr-00330-AJN Document 30 Filed 07/27/20 Page 2 of 2 
those materials for any purpose other than preparing for trial in the criminal 
case, and may not post those materials on the Internet. 
b. Second, the defense believes it should not be restricted from publicly 
disclosing or disseminating the identity of any alleged victims or potential 
witnesses referenced in the discovery materials who have already identified 
themselves by speaking on the public record. 
I hereby certify that the foregoing statements made by me are true. I am aware that if any of the 
foregoing statements are willfully false, I am subject to punishment. 
Date…

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