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Case 1:20-cr-00330-PAE Document 314 Filed 07/12/21 Pagelof7
MARKUS / MOSS
July 9, 2021
VIA EMAIL TO CHAMBERS
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
40 Foley Square
New York, New York 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
Even though I do not currently represent Ms. Maxwell in any proceedings and
have never entered an appearance in connection with her trial before Your Honor, the
Government submitted a letter “to bring to the Court’s attention” an article that I wrote
on June 30, 2021, and asked that the Court “issue an order pursuant to Local Rule
23.1(h)” directed at me. (Dkt. No. 309). This Court ordered that I respond (Dkt. No.
312), and I do so here. I respectfully request that the Court deny the Government’s
request for the following reasons:
I. The local rules do not apply as I do not currently represent Ghislaine
Maxwell in any proceeding and have not entered an appearance in
this Court.
Because undersigned counsel does not currently represent Ms. Maxwell in any
court and has never entered an appearance as her lawyer in this Court, the local rules
do not apply. See, e.g., Local Rule 23.1(h) (explaining that the Court “may issue a
special order governing such matters as extrajudicial statements by parties and
witnesses likely to interfere with the rights of the accused to a fair trial by an impartial
jury’) (emphasis added). Because undersigned counsel does not represent a party or a
witness, the Government’s request should be denied.
Undersigned counsel was previously retained to represent Ms. Maxwell’s family.
Then, when this Court denied her third bail application, undersigned counsel was
retained to represent Ms. Maxwell in the Second Circuit on her bail appeal (and not
regarding the merits of the case). That proceeding is concluded, and undersigned
counsel no longer represents Ms. Maxwell in any capacity.
DOJ-OGR-00004955