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Case 1:20-cr-00330-AJN Document 39 Filed 08/10/20 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 defense’s request for the disclosure of the
identities of Victims 1-3 referenced in the indictment, subject to the restrictions of
the protective order entered by the Court. The government did not agree to the
request, and instead indicated that it would disclose the identities of Victims 1-3
through its production of Rule 16 discovery, or as part of its production of Jencks
Act material closer to trial.
DOJ-OGR-00001711