EFTA00020437.pdf

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

From: David Oscar Markus ‹
> 
To: 
(USANYS)" 
Cc: ' 
(USANYS)" 
Subject: Re: U.S. v. Ghislaine Maxwell 
Date: Wed, 31 Mar 2021 15:01:54 +0000 
We are preparing our motion for bail in the Second Circuit and need to inform the Court of the government's 
position. We intend to let the Court know that the Government's opposes Ms. Maxwell's motion and intends to 
file a response. Please confirm. 
Thanks, 
David 
--David Oscar Markus 
markuslaw.com 
Fro 
(USANYS) •
> 
Sent: Thursday, March 25, 2021 7:10 PM 
To: David Oscar Markus 
Cc: 
Mark S. Cohen 
Subject: RE: U.S. v. Ghislaine Maxwell 
David, 
; Christian Everdell; Bobbi Sternheim 
►; 
Thanks for letting us know that you'll be counsel on this appeal. As an initial matter, the majority of the docket entries 
you've referenced do not appear to be redacted. In any event, you may obtain these materials from defense counsel -- I've 
copied them here. This case is already governed by a protective order (ECF No. 36), which is binding on all counsel. 
Thanks, 
Assistant United States Attorney 
Southern District of New York 
One Saint Andrew's Plaza 
New York. NY 10007 
EFTA00020437


From: David Oscar Markus c
r• 
Sent: Thursday, March 25, 2021 5:33 PM 
To: 
(USANYS) < 
Subject: U.S. v. Ghislaine Maxwell 
Good afternoon counsel: 
I have been engaged to represent Ghislaine Maxwell in her appeal from the denial of her third application for 
bail. In preparing this appeal, I will need access to certain unredacted documents, including docket entries 4, 
18, 22, 97, 100, 103, 106, 159, 160, 165, 171, 169. Do you have any objection to me having access to these 
unredacted documents? (There may be additional documents that I need, but I have not identified them as of 
yet.) I'm happy to enter into a protective order with the government if you believe that is necessary. I plan on 
filing the appeal next week, so I would appreciate it if you could get back to me as soon as possible. 
Thank you, 
David 
--David Oscar Markus 
markuslaw.…
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