From: David Oscar Markus <[REDACTED]>
To: [REDACTED] (USANYS)" <[REDACTED]>
Cc: "[REDACTED] (USANYS)" <[REDACTED]>
Subject: Re: U.S. v. Ghislaine Maxwell
Date: Wed, 31 Mar 2021 15:01:54 +0000
[REDACTED]
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
[REDACTED]
From [REDACTED] (USANYS) <[REDACTED]>
Sent: Thursday, March 25, 2021 7:10 PM
To: David Oscar Markus
Cc: [REDACTED]; Christian Everdell; Bobbi Sternheim ([REDACTED]);
Mark S. Cohen
Subject: RE: U.S. v. Ghislaine Maxwell
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]
Assistant United States Attorney
Southern District of New York
One Saint Andrew’s Plaza
New York, NY 10007
[REDACTED]
EFTA00020437
From: David Oscar Markus <[REDACTED]>
Sent: Thursday, March 25, 2021 5:33 PM
To: [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 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]
EFTA00020438
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