Page 1 of 3
Case 1:20-cr-00330-PAE Document 309 _ Filed 07/01/21 Page1of3
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew's Plaza
New York, New York 10007
July 1, 2021
VIA ECF
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge 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 violation of Local Rule 23.1, which contains provisions relating
to extrajudicial public statements by attorneys. Accordingly, for the reasons stated below, the
Government respectfully requests that the Court order Mr. Markus to comply with Local Rule
23.1.
A. Mr. Markus’s Statements to the Media
David Markus represents the defendant in connection with appellate matters in this case.
In particular, Mr. Markus has handled the defendant’s bail appeals in this case, including an
argument on her behalf in the Second Circuit. As the Court may recall, on April 14, 2021, Mr.
Markus emailed Chambers requesting permission to bring electronics to the courthouse to attend
the defendant’s arraignment on the superseding indictment. The Court informed Mr. Markus that
he would need to file a notice of appearance before making such an application to the Court. Mr.
Markus did not file a notice of appearance, but he attended the arraignment and spoke to members
of the media thereafter.!
! See Stephen Rex Brown, Ghislaine Maxwell Makes First Court Appearance, N.Y. Daily News (Apr. 23, 2021),
http://www .nydailynews.com/new-york/ny-ghislaine-maxwell-arraignment-202 10423-
b3aza5eh7bddna7r247px2yb7e-story.html (quoting Mr. Markus, speaking outside the courthouse following the
defendant’s arraignment and identifying him as “her attorney”).
DOJ-OGR-00004807