034.pdf

Type

pdf

Source set

house-oversight-doj

Pages

2

Text status

Searchable text available

OCR confidence

0.9183565000445513

Original source

Extracted text

Case 1:20-cr-00330-AJN Document 34 Filed 07/28/20 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ee ee ee ee ee Pe ee ee ee ee ee ee ee ee x UNITED STATES OF AMERICA, : AFFIDAVIT OF CERTIFICATION : PURSUANT TO LOCAL -V.- : CRIMINAL RULE 16.1 GHISLAINE MAXWELL, j 20 Cr. 330 (AJN) Defendant. panna ks ee ae he Se Se x STATE OF NEW YORK ) COUNTY OF NEW YORK : SS.: SOUTHERN DISTRICT OF NEW YORK_) ALEX ROSSMILLER, pursuant to Title 28, United States Code, Section 1746, hereby affirms under penalty of perjury: L. I am an Assistant United States Attorney in the Office of Audrey Strauss, Acting United States Attorney for the Southern District of New York. I am one of the Assistants who represents the Government in these proceedings. 2. I certify pursuant to Local Criminal Rule 16.1 that the Government has conferred in good faith with counsel to the defendant, Ghislaine Maxwell, regarding the Government’s proposed protective order, pursuant to Federal Rule of Criminal Procedure 16. 3. The parties have been able to agree on most of the provisions of a protective order. However, the parties have been unable to resolve two areas of dispute. a. First, the defendant and her counsel have objected to the Government’s proposal that the defense be permitted to reference identities of witnesses and victims to prospective defense witnesses (so long as those witnesses and their counsel abstain from further disclosing or disseminating any such identities), and be permitted to reference publicly any victim DOJ-OGR-00001683 

Case 1:20-cr-00330-AJN Document 34 Filed 07/28/20 Page 2 of 2 who has spoken—or who at some future time speaks—by name on the public record in this case, and otherwise be permitted to identify victim names in sealed filings, or identify victims by pseudonyms in public filings, or redact victim names in public filings, but that the defendant and her counsel be restricted from otherwise publicly referencing witness or victim identities. That disag…

Open in the interactive archive →