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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
UNITED STATES OF AMERICA,
AFFIDAVIT OF CERTIFICATION
v. PURSUANT TO LOCAL
CRIMINAL RULE 16.1
GHISLAINE MAXWELL,
Defendant. 20 Cr. 330 (AJN)
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 Alison Moe, Alex Rossmiller, and
Maurene Comey 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
DOJ-OGR-00001660