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duously refrained from any involvement with the media, despite repeated, persistent and borderline-harassing requests for comment. The statements in the New York Daily News Op-Ed piece were from Mr. Markus, who is not counsel of record in this case. These statements did not violate Rule 23.1. Nevertheless, it is approp
spectfully submitted: /s/ Bobbi C. Stemheim /s/ Christian R. Everdell Is/ Laura A. Menninger Is/ Jeffrey S. Pagliuca cc: Government counsel David Oscar Markus, Esq. 3 EFTA00087798
dge Nathan: The Government respectfully submits this letter to bring to the Court's attention an opinion piece (the "Op-Ed") published yesterday in the New York Daily News, which was authored by David Markus, Esq., who represents the defendant in connection with this case. Mr. Markus's statements in the Op-Ed were in
n Prison, N.Y. Post (May 5, 2021), https://nypost.com/2021/05/05/ghislaine-maxwell-on-enhanced-security-schedule-lockup-feds/ (quoting Mr. Markus); David Oscar Markus, Ghislaine Maxwell Should Be Released: She Should Await Her Trial Outside Confinement, N.Y. Daily News (Feb. 24, 2021), https:thvww.nydailynews.corn
dge Nathan: The Government respectfully submits this letter to bring to the Court's attention an opinion piece (the "Op-Ed") published yesterday in the New York Daily News, which was authored by David Markus, Esq., who represents the defendant in connection with this case. Mr. Markus's statements in the Op-Ed were in
Page: EFTA00023532 →he attended the arraignment and spoke to members of the media thereafter.' I See Stephen Rex Brown, Ghislaine Marvell Makes First Court Appearance, N.Y. Daily News (Apr. 23, 2021), http :Thinvw.nyda ilynews.corn/new-york/ny-ghisla ine-maxwell-arra ignment-20210423- b3aza5eh7bddna7r247px2yb7e-story.html (quoting
Page: EFTA00023532 →Prison, N.Y. Post (May 5, 2021), https://nypost.comi2021/05/05/ghislaine-mtucwell-on-enhanced-security-schedule-lockup-feds/ (quoting Mr. Markus); David Oscar Markus, Ghislaine Maxwell Should Be Released: She Should Await Her Trial Outside Confinement, N.Y. Daily News (Feb. 24, 2021), https:thvww.nydailynews.corn
Page: EFTA00023533 →Entities connected to both New York Daily News and David Oscar Markus

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
United States
LOCATION
George W. Bush
PERSON
Bloomberg L.P.
ORGANIZATION
Julie K. Brown
PERSON
Stephen Hawking
PERSONThe New York Post
ORGANIZATION
Michael Cohen
PERSON
William Barr
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
John F. Kennedy
PERSON
David Boies
PERSONFederal Bureau of Prisons
ORGANIZATIONSecond Circuit
ORGANIZATION
the United States District Court
ORGANIZATION
Alison J. Nathan
PERSON