EFTA00029877.pdf
84 KB
Extraction Summary
3
People
3
Organizations
2
Locations
1
Events
1
Relationships
3
Quotes
Document Information
Type:
Affidavit of certification (legal court filing)
File Size:
84 KB
Summary
This document is an affidavit filed on July 27, 2020, by Christian R. Everdell, attorney for Ghislaine Maxwell. It certifies that the defense conferred with the prosecution regarding a protective order but remains in dispute over two issues: restrictions on government witnesses regarding discovery materials and the defense's ability to name victims who have already gone public. The document includes redactions of the names of the Assistant U.S. Attorneys involved.
People (3)
| Name | Role | Context |
|---|---|---|
| Christian R. Everdell | Defense Attorney |
Partner at Cohen & Gresser LLP, submitting the affidavit on behalf of Ghislaine Maxwell.
|
| Ghislaine Maxwell | Defendant |
Defendant in the criminal case 20 Cr. 330 (AJN).
|
| AJN | Judge (Initial) |
Presiding judge initials in case caption (Alison J. Nathan).
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| United States District Court Southern District of New York |
Court where the document was filed.
|
|
| Cohen & Gresser LLP |
Law firm representing the defendant.
|
|
| United States of America |
Plaintiff/Prosecution.
|
Timeline (1 events)
2020-07-27
Filing of Affidavit of Certification Pursuant to Local Criminal Rule 16.1
Southern District of New York
Locations (2)
| Location | Context |
|---|---|
|
Location of filing and attorney's office.
|
|
|
Address of Cohen & Gresser LLP.
|
Relationships (1)
I am a partner at Cohen & Gresser LLP, counsel for defendant Ghislaine Maxwell
Key Quotes (3)
"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"Source
EFTA00029877.pdf
Quote #1
"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."Source
EFTA00029877.pdf
Quote #2
"I certify pursuant to Local Criminal Rule 16.1 that defense counsel has conferred in good faith with Assistant U.S. Attorneys... regarding the government’s proposed protective order"Source
EFTA00029877.pdf
Quote #3
Full Extracted Text
Complete text extracted from the document (2,285 characters)
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,
SOUTHERN DISTRICT OF NEW YORK
---------------------------------------------------------x
UNITED STATES OF AMERICA,
v.
GHISLAINE MAXWELL,
Defendant.
---------------------------------------------------------x
---------------------------------------------------------x
AFFIDAVIT OF CERTIFICATION
PURSUANT TO LOCAL
CRIMINAL RULE 16.1
PURSUANT TO LOCAL
CRIMINAL RULE 16.1
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:
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.
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 [REDACTED], [REDACTED], and
[REDACTED] regarding the government’s proposed protective order pursuant
to Federal Rule of Criminal Procedure 16.
in good faith with Assistant U.S. Attorneys [REDACTED], [REDACTED], and
[REDACTED] 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.
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
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.
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.
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.
foregoing statements are willfully false, I am subject to punishment.
Dated: July 27, 2020
New York, New York
New York, New York
/s/ Christian R. Everdell
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, New York 10022
Phone: 212-957-7600
Christian R. Everdell
COHEN & GRESSER LLP
800 Third Avenue
New York, New York 10022
Phone: 212-957-7600
2
EFTA00029878
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