Case 2:18-cv-02217-SJO-FFM Document 50 Filed 04/25/18 Page 1 of 2 Page ID #:935

1 BLAKELY LAW GROUP

BRENT H. BLAKELY (CA Bar No. 157292)
1334 Parkview Avenue, Suite 280
3 Manhattan Beach, California 90266
Telephone: (310) 546-7400
4
Facsimile: (310) 546-7401
5 Email:
BBlakely@BlakelyLawGroup.com
2

6

Attorneys for Defendants
7 ESSENTIAL CONSULTANTS, LLC and
8 MICHAEL COHEN
9

UNITED STATES DISTRICT COURT

10

CENTRAL DISTRICT OF CALIFORNIA

11
12 STEPHANIE CLIFFORD a.k.a.

STORMY DANIELS a.k.a. PEGGY

13 PETERSON, an individual,
14

Plaintiff,

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16

Case No. 2:18-CV-02217-SJO-FFM
DECLARATION OF MICHAEL D.
COHEN IN SUPPORT OF JOINT EX
PARTE APPLICATION FOR STAY
Assigned for All Purposes to the
Hon. S. James Otero

v.

17 DONALD J. TRUMP a.k.a. DAVID
18 DENNISON, an individual,

Action Filed: March 6, 2018

ESSENTIAL CONSULTANTS, LLC, a
Delaware Limited Liability Company,
20 MICHAEL COHEN, an individual, and
DOES 1 through 10, inclusive,
19

21
22

Defendants.

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24
25
26
27
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DECLARATION OF MICHAEL D. COHEN

 Case Document 50 Filed 04/25/18 Page 2 of 2 Page ID #:936



(DECLARATION OF MICHAEL D. COHEN

1, Michael D. Cohen, declare as follows:

1. I have personal knowledge of the facts set forth herein, and if called and
sworn as a witness, I could and would competently testify to the matters stated herein.

2. On April 9, 2018, the Federal Bureau of Investigation executed
three search warrants on my residence, of?ce and hotel room, respectively, without
any prior notice. During the corresponding raids, the FBI seized various electronic
devices and documents in my possession, which contain information relating to the
$130,000 payment to Plaintiff Stephanie Clifford at the center of this case, and my
communications with counsel, Brent Blakely, relating to this action.

3. Based upon the advice of counsel, 1 will assert my 5th amendment rights
in connection with all proceedings in this case due to the ongoing criminal
investigation by the FBI and US. Attorney for the Southern District of New York.

4. On April 10, 2018 I ?rst realized that my Fi?h Amendment rights would
be implicated in this case, after I considered the events of April 9, 2018, described in
the above paragraph 2.

I declare under penalty of perjury under the laws of the United States of
America that the foregoing is true and correct.

Executed on April 25, 2018, at New York, New York. 

a,

1

 

1
MICHAEL D. COHEN . 

.2-
DECLARATION OF MICHAEL D. COHEN