EFTA00014661.pdf

Type: pdf
Source set: data-set-8
Extracted text

From: ' 
To: Laura lvlennin er <ImenningerOiNnflav,%com 
(USANYS)" 
• 
Cc: Jeff Pagliuca <jpagliucaghmflaw.com>, mceverdellgcohengresser.coni" 
<ceverdellgcohengresser.com>, "'Bobbi Sternheim (bestemheimgmac.com)"' 
<[email protected]> 
Subject: RE: Conferral Regarding Possible Violation of Local Criminal Rule 23.1 
Date: Wed, 12 May 2021 03:03:03 +0000 
Inline-Images: image001.jpg 
Counsel, 
To our knowledge, Spencer Kuvin does not represent any of the witnesses the Government expects to call at trial in this 
case. Because this individual does not represent any witnesses in this case, we do not see a need to raise this issue with 
the Court. 
We agree that compliance with Local Rule 23.1 is important. To that end, we note that David Markus, an attorney who 
has filed a notice of appearance in the Second Circuit on behalf of Ms. Maxwell, and who was present for the arraignment 
before Judge Nathan last month, has also made public statements to the press regarding this case, which run the risk of 
violating the rule. See, e.g., https://nypost.com/2021/05/05/ghislaine-maxwell-on-enhanced-security-schedule-lockup-
fecIst 
Our hope is that by alerting you to this concern now, there will not be a need in the future to raise the issue with the 
Court. 
Best, 
From: Laura Menninger <[email protected]> 
Sent: Friday, May 7, 2021 5:18 PM 
To: 
>; 
(USANYS) 
Cc: Jeff Pagliuca <[email protected]>; [email protected]' <[email protected]>; 'Bobbi 
Sternheim ([email protected])' <[email protected]> 
Subject: Conferral Regarding Possible Violation of Local Criminal Rule 23.1 
Counsel — 
The linked article by the Sun dated yesterday contains a number of statements which, if made by a lawyer associated with 
a witness in this case, appear to violate Local Criminal Rule 23.1. See also Dkt. No. 28 (expectation of strict compliance 
with Rule 23.1 by "counsel for all involved parties"). The rule applies by its terms to any "lawyer participating in or 
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