UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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UNITED STATES OF AMERICA, AFFIDAVIT OF CERTIFICATION
PURSUANT TO LOCAL
• CRIMINAL RULE 16.1
GHISLAINE MAXWELL, • 20 Cr. 330 (MN)
Defendant.
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STATE OF NEW YORK
COUNTY OF NEW YORK SS.:
SOUTHERN DISTRICT OF NEW YORK )
pursuant to Title 28, United States Code, Section 1746, hereby
affirms under penalty of perjury:
1. 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 defense counsel's request
that the warden of the Metropolitan Detention Center ("MDC") report directly to the Court and
counsel on the defendant's conditions of confinement, and that the parties have been unable to
reach agreement.
3. In particular, on November 30, 2020, the Government asked defense counsel
whether they would consent to MDC legal counsel addressing the Court and counsel directly in
writing on the defendant's conditions of confinement. On December 1, 2020, defense counsel
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indicated that they would not consent and reiterated their request that the Court summon Warden
Tellez to report directly to the Court and counsel on the defendant's conditions of confinement.
4. I hereby certify that the foregoing statements made by me are true.
Dated: New York, New York
December 1, 2020
Assistant United States Attorney
Telephone:
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