EFTA00015825.pdf
132 KB
Extraction Summary
3
People
3
Organizations
2
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Email chain / legal correspondence
File Size:
132 KB
Summary
This document is an email chain between David Oscar Markus, representing Ghislaine Maxwell, and the US Attorney's Office (SDNY) regarding her appeal of a bail denial. The correspondence, dating from March 25 to April 10, 2021, covers Markus's request for unredacted docket entries, discussions on expediting the appeal process, and the filing of an unredacted Exhibit F under seal. The US Attorney confirms the existence of a protective order and agrees not to oppose expediting consideration of the appeal, provided the 10-day response window remains intact.
People (3)
| Name | Role | Context |
|---|---|---|
| David Oscar Markus | Defense Attorney |
Counsel for Ghislaine Maxwell, Markus/Moss law firm
|
| Ghislaine Maxwell | Defendant/Appellant |
Subject of the legal case and appeal regarding bail denial
|
| [REDACTED] | Assistant United States Attorney |
Prosecutor, SDNY (USANYS)
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Markus/Moss |
Law firm representing Ghislaine Maxwell
|
|
| USANYS |
United States Attorney's Office for the Southern District of New York
|
|
| Southern District of New York |
Court jurisdiction
|
Timeline (2 events)
2021-03-25
David Oscar Markus engages as counsel for Ghislaine Maxwell for her appeal regarding bail denial.
New York
2021-04-09
Government indicates intent to file unredacted copy of Exhibit F under seal.
SDNY
Locations (2)
| Location | Context |
|---|---|
|
Address of the Assistant United States Attorney
|
|
|
Website of the defense counsel
|
Relationships (2)
Markus states: 'I have been engaged to represent Ghislaine Maxwell in her appeal'
Correspondence regarding legal motions and protective orders in U.S. v. Ghislaine Maxwell
Key Quotes (4)
"I have been engaged to represent Ghislaine Maxwell in her appeal from the denial of her third application for bail."Source
EFTA00015825.pdf
Quote #1
"I will need access to certain unredacted documents, including docket entries 4, 18, 22, 97, 100, 103, 106, 159, 160, 165, 171, 169."Source
EFTA00015825.pdf
Quote #2
"We do not oppose the Court expediting consideration but do oppose any request to shorten the ten days by which we have to respond."Source
EFTA00015825.pdf
Quote #3
"If you are filing that one unredacted pleading, would you be willing to file the others as well? I think the court should have them all."Source
EFTA00015825.pdf
Quote #4
Full Extracted Text
Complete text extracted from the document (3,937 characters)
From: David Oscar Markus <[REDACTED]>
To: "[REDACTED] (USANYS)" <[REDACTED]>
Cc: "[REDACTED])" <[REDACTED]>, "[REDACTED])" <[REDACTED]>
Subject: Re: U.S. v. Ghislaine Maxwell
Date: Sat, 10 Apr 2021 01:23:56 +0000
To: "[REDACTED] (USANYS)" <[REDACTED]>
Cc: "[REDACTED])" <[REDACTED]>, "[REDACTED])" <[REDACTED]>
Subject: Re: U.S. v. Ghislaine Maxwell
Date: Sat, 10 Apr 2021 01:23:56 +0000
[REDACTED],
If you are filing that one unredacted pleading, would you be willing to file the others as well? I think the court should have them all. Let me know if you will include the others.
Thanks,
David
--David Oscar Markus
Markus/Moss
markuslaw.com
[REDACTED]
Markus/Moss
markuslaw.com
[REDACTED]
On Apr 9, 2021, at 6:25 PM, David Oscar Markus <[REDACTED]> wrote:
Hi [REDACTED]
No objection.
Have a nice weekend.
David.
--David Oscar Markus
Markus/Moss
markuslaw.com
[REDACTED]
Markus/Moss
markuslaw.com
[REDACTED]
On Apr 9, 2021, at 6:21 PM, [REDACTED] (USANYS) <[REDACTED]> wrote:
David,
We intend to submit a motion to seek leave to file an unredacted copy of Exhibit F under seal and need to indicate your position. Do you consent to this request?
Thanks
[REDACTED]
[REDACTED]
EFTA00015825
From: David Oscar Markus <[REDACTED]>
Sent: Thursday, April 01, 2021 6:35 PM
To: [REDACTED] (USANYS) <[REDACTED]>
Cc: [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>
Subject: Re: U.S. v. Ghislaine Maxwell
Sent: Thursday, April 01, 2021 6:35 PM
To: [REDACTED] (USANYS) <[REDACTED]>
Cc: [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>
Subject: Re: U.S. v. Ghislaine Maxwell
Thanks. I won’t ask to shorten the 10 days if the government doesn’t plan on asking for an extension. —dm
--David Oscar Markus
Markus/Moss
markuslaw.com
[REDACTED]
Markus/Moss
markuslaw.com
[REDACTED]
On Apr 1, 2021, at 6:07 PM, [REDACTED] (USANYS) <[REDACTED]> wrote:
We do not oppose the Court expediting consideration but do oppose any request to shorten the ten days by which we have to respond.
From: David Oscar Markus <[REDACTED]>
Sent: Thursday, April 01, 2021 5:59 PM
To: [REDACTED] (USANYS) <[REDACTED]>
Cc: [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>
Subject: Re: U.S. v. Ghislaine Maxwell
Sent: Thursday, April 01, 2021 5:59 PM
To: [REDACTED] (USANYS) <[REDACTED]>
Cc: [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>
Subject: Re: U.S. v. Ghislaine Maxwell
Both.
--David Oscar Markus
Markus/Moss
markuslaw.com
[REDACTED]
Markus/Moss
markuslaw.com
[REDACTED]
On Apr 1, 2021, at 5:33 PM, [REDACTED] (USANYS) <[REDACTED]> wrote:
David,
Are you asking to expedite the Court’s consideration of the appeal or asking to shorten our timeline for responding?
Thanks,
[REDACTED]
[REDACTED]
From: David Oscar Markus <[REDACTED]>
Sent: Thursday, April 01, 2021 5:27 PM
To: [REDACTED] <[REDACTED]>
Cc: [REDACTED] <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]>
Subject: Re: U.S. v. Ghislaine Maxwell
Sent: Thursday, April 01, 2021 5:27 PM
To: [REDACTED] <[REDACTED]>
Cc: [REDACTED] <[REDACTED]>; [REDACTED] (USANYS) <[REDACTED]>
Subject: Re: U.S. v. Ghislaine Maxwell
Counsel:
EFTA00015826
What is the government’s position on expediting the appeal?
Thank you.
David
--David Oscar Markus
Markus/Moss
markuslaw.com
[REDACTED]
Markus/Moss
markuslaw.com
[REDACTED]
On Mar 25, 2021, at 7:11 PM, [REDACTED] <[REDACTED]> wrote:
David,
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,
[REDACTED]
[REDACTED]
Assistant United States Attorney
Southern District of New York
One Saint Andrew’s Plaza
New York, NY 10007
(212) 63[REDACTED]
Assistant United States Attorney
Southern District of New York
One Saint Andrew’s Plaza
New York, NY 10007
(212) 63[REDACTED]
From: David Oscar Markus <[REDACTED]>
Sent: Thursday, March 25, 2021 5:33 PM
To: [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>
[REDACTED] (USANYS) <[REDACTED]>
Subject: U.S. v. Ghislaine Maxwell
Sent: Thursday, March 25, 2021 5:33 PM
To: [REDACTED] <[REDACTED]>; [REDACTED] <[REDACTED]>
[REDACTED] (USANYS) <[REDACTED]>
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
EFTA00015827
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.com
[REDACTED]
markuslaw.com
[REDACTED]
EFTA00015828
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