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EFTA00029876EFTA00029879
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efta-efta00029877DOJ Data Set 8Correspondence

EFTA00029877

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DOJ Data Set 8
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efta-efta00029877
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EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
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. Dated: July 27, 2020 /s/ Christian R. Everdell New York, New York Christian R. Everdell COHEN & DRESSER LLP 800 Third Avenue New York, New York 10022 Phone: 212-957-7600 2 EFTA00029878

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Case #1:20-CR-00330-AJN
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Related Documents (6)

House OversightLegal FilingUnknown

Defense attorney Christian R. Everdell requests that the court order the MDC to accept two hard driv...

Defense attorney Christian R. Everdell requests that the court order the MDC to accept two hard drives containing non-Highly Confidential discovery materials for Ghislaine Maxwell's use. The hard drives are organized in a user-friendly format, and the government does not object to the request. The MDC Legal Department has expressed concerns and is given the opportunity to note objections.

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Court UnsealedLegal FilingUnknown

Declaration in Support of Motion to Withdraw as Co-Counsel: 798-1

Christian R. Everdell of Cohen & Gresser LLP declares that the firm is withdrawing as co-counsel for Ghislaine Maxwell with her consent, as Markus Moss PLLC has taken over her representation for the government's motion to unseal grand jury transcripts. Cohen & Gresser LLP represented Maxwell during her trial and sentencing but not in her appellate proceedings. The firm will share its files with Markus Moss PLLC upon request.

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DOJ Data Set 8CorrespondenceUnknown

EFTA00019897

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Court UnsealedLegal FilingUnknown

Court Filing: 133

Ghislaine Maxwell's defense team files a motion to suppress evidence obtained from a government subpoena and to dismiss Counts Five and Six of the indictment, citing the Due Process Clause. The motion is supported by a memorandum of law and exhibits. The defense attorneys representing Maxwell are listed, along with their contact information.

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Court UnsealedLegal FilingUnknown

Court filings: 8

The documents include court filings related to the cases of Ghislaine Maxwell and Jeffrey Epstein. The first filing concerns the scheduling of Maxwell's arraignment and bail hearing, while the second is related to Epstein's bail motion and financial disclosure.

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Court UnsealedCorrespondenceUnknown

Court Filing - Letter to Judge: Case1:20-cr-03320-AJN Document 292 Filed 08/27/20 Page 20 of 1164

The defense attorneys for Ghislaine Maxwell request a protective order from Judge Alison J. Nathan to govern the handling of discovery materials. The parties have reached agreement on most provisions but remain at odds over restrictions on government witnesses and the disclosure of alleged victim identities.

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