Case 1:09-cr-00466-BMC-RLM Document 480 Filed 11/30/18 Page 1 of 2 PageID #: 6256

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF NEW YORK
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UNITED STATES OF AMERICA

AFFIRMATION
-against-
S4 09 CR 466 (BMC)
JOAQUIN GUZMAN-LOERA

Defendant.

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MICHAEL LAMBERT, an attorney duly admitted to practice before this Court certifies

the following under the penalties of perjury, pursuant to 28 U.S.C. § 1746:

1. I am the principal of the Law Office of Michael Lambert, located at 369

Lexington Avenue, 2nd Floor, New York, New York. I am one of the attorneys for Joaquin

Guzman-Loera, the defendant in the above-captioned case and am fully familiar with the facts

and circumstances herein.

2. I respectfully submit this affirmation in response to the government’s November

27, 2018 motion for sanctions against

(Dkt. No. 467).

3. I did share my phone with Ms. Coronel briefly in the courtroom and the

courthouse, I used the Google Translate application to help facilitate communication with Ms.

Coronel regarding the court proceeding due to the language barrier between us. We were always

in close proximity and the phone only changed hands for the purposes of our own personal

communication. It is my understanding that this situation was already discussed and resolved

during a sidebar conference.

4. I have no personal knowledge of any other member of the defense team acting
Case 1:09-cr-00466-BMC-RLM Document 480 Filed 11/30/18 Page 2 of 2 PageID #: 6257

inappropriately in any way.

WHEREFORE, based on the factual proffer contained in this affirmation, the

government’s motion for sanctions should be denied.

Dated: New York, New York

November 30, 2018

___________________________________
MICHAEL LAMBERT