DOJ-OGR-00019829.pdf

Case 21-58, Document 39-1, 04/01/2021, 3068530, Page1 of 31 UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT Thurgood Marshall U.S. Courthouse 40 Foley Square, New York, NY 10007 Telephone: 212-857-8500 MOTION INFORMATION STATEMENT Docket Number(s): 21-770/21-58 Caption [use short title] Motion for: Pretrial Release Set forth below precise, complete statement of relief sought: Ghislaine Maxwell requests that this Court set reasonable bail or in the alternative, remand for an evidentiary hearing. United States of America v. Ghislaine Maxwell MOVING PARTY: Ghislaine Maxwell OPPOSING PARTY: United States of America Plaintiff Defendant Appellant/Petitioner Appellee/Respondent MOVING ATTORNEY: David Oscar Markus OPPOSING ATTORNEY: Won. S. Shin, AUSA Markus/Moss PLLC United States Attorney's Office, So. Dist. of NY 40 NW Third Street, PH 1, Miami, FL 33128 1 St. Andrew's Plaza, New York, New York 10007 (305)379-6667; dmarkus@markuslaw.com (212)637-2226 Court- Judge/ Agency appealed from: Alison J. Nathan, Southern District of New York Please check appropriate boxes: Has movant notified opposing counsel (required by Local Rule 27.1): Yes No (explain): Opposing counsel's position on motion: Unopposed Opposed Don't Know Does opposing counsel intend to file a response: Yes No Don't Know Is oral argument on motion requested? Yes No (requests for oral argument will not necessarily be granted) Has argument date of appeal been set? Yes No If yes, enter date: FOR EMERGENCY MOTIONS, MOTIONS FOR STAYS AND INJUNCTIONS PENDING APPEAL: Has this request for relief been made below? Yes No Has this relief been previously sought in this court? Yes No Requested return date and explanation of emergency: Signature of Moving Attorney: /s/ David Oscar Markus Date: 04/01/2021 Service by: CM/ECF Other [Attach proof of service] Form T-1080 (rev.12-13) DOJ-OGR-00019829