Epstein Secrets

amplified by the defendant's extensive international ties, her citizenship in two foreign countries, her wealth, and her lack of meaningful ties to the United States. In short, Maxwell has three passports, large sums of money, extensive international connections, and absolutely no reason to stay in the United Sta

f production—not a burden of persuasion—to rebut that presumption by coming forward with evidence that [she] does not pose . . . a risk of flight." See United States v. English, 629 F.3d 311, 319 (2d Cir. 2011) (quotation omitted). This rebuttable presumption can be readily satisfied, United States v. Conway, No

ca v. Ghislaine Maxwell OPPOSING PARTY: United States of America DPlaintiff ODefenchnt FlAprellantPetiimer DArpelke/Respandent MOVING ATTORNEY: David Oscar Markus OPPOSING ATTORNEY: Won. S. Shin, AUSA [name of attorney. win lynx address, phone number and e-mail] Markus/Moss PLLC United States Attorney's Of

ly likely to have a materially prejudicial effect ... applying equally to all attorneys participating in a pending case") (emphasis added); see also United States v. Brown, 218 F.3d 415 (5th Cir. 2000) (discussing the factors to consider in entering a gag order for "trial participants'). The Government, howev

enied because (1) undersigned counsel does not currently represent Ms. Maxwell, and (2) the Op-Ed did not violate the local rules. Sincerely, /s/ David Oscar Markus David Oscar Markus EFTA00082647

ly likely to have a materially prejudicial effect ... applying equally to all attorneys participating in a pending case") (emphasis added); see also United States v. Brown, 218 F.3d 415 (5th Cir. 2000) (discussing the factors to consider in entering a gag order for "trial participants'). The Government, howev

enied because (1) undersigned counsel does not currently represent Ms. Maxwell, and (2) the Op-Ed did not violate the local rules. Sincerely, /s/ David Oscar Markus David Oscar Markus EFTA00087805

s in the United States, her strong desire to return to her family in the United States, and her intention to establish her innocence at her trial in the United States. 2 EFTA00089483 Case 1:20-cr-00330-AJN Document 272 Filed 05/07/21 Page 3 of 3 LAW OFFICES OF 13O13131 C. STERNHEIM In the face of the Epstein'

Motion for Pretrial Release Leah S. Saffian LAW OFFICES OF LEAH SAFFIAN 15546 Meadowgate Road Encino, California 91436-3429 Tel: (858)488-2765 David Oscar Markus *Counsel of Record MARKUS/MOSS PLLC 40 N.W. Third Street, PH 1 Miami. Florida 33128 Tel: mar aw.com EFTA00089465 Appendix* App. 86 Doc. 2

humiliating memories of my life. I will hold onto these memories forever, but these memories are my motivation to stay out of trouble, your Honor." United States v. Tiffany Days, April 29, 2021, which can be accessed at: https://tinyurl.com/ytf8cyw5. The judge in that case was upset, finding: "it is the find

MOVING PARTY: Ghislaine Maxwell OPPOSING PARTY: United States of America 'attendant [Appellant/Petitioner IllAppenee/Respondent MOVING ATTORNEY: David Oscar Markus Markus/Moss PLLC OPPOSING ATTORNEY: , AUSA [name of attorney, with firm address, phone number and e-mail] United States Attorney's Office, So. Dis

s in the United States, her strong desire to return to her family in the United States, and her intention to establish her innocence at her trial in the United States. 2 EFTA00096551 CageSegite$410)3Oacaltdit fitietIV/0021F lot 6111:16707/21gefaitief 301 3 LAW OFFICES OF BOBBI C. STERNHEIM In the face of the

TY: Ghislaine Maxwell OPPOSING PARTY: United States of America 9Plaintiff ElDelendant ZAppellant/Petkioner nAppeUee/Respondent MOVING ATTORNEY: David Oscar Markus Markus/Moss PLLC OPPOSING ATTORNEY: , AUSA [name of attorney, with firm address, phone number and e-mail) United States Attorney's Office, So. Dis