EFTA00020437.pdf

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 cr• 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.com EFTA00020438