Document 34

Case 1:19-cr-00490-RMB Document 34 Filed 07/22/19 Page 1 of 1 Criminal Notice of Appeal - Form A NOTICE OF APPEAL United States District Court Southern District of New York Caption: United States v. Jeffrey Epstein Docket No.: 19-cr-00490 (RMB) Hon. Richard M. Berman (District Court Judge) Notice is hereby given that Defendant Jeffrey Epstein appeals to the United States Court of Appeals for the Second Circuit from the judgment other Decision & Order Remanding Defendant entered in this action on July 18, 2019 (date) (specify) This appeal concerns: Conviction only | Sentence only | Conviction & Sentence | Other | Defendant found guilty by plea | trial | N/A | Offense occurred after November 1, 1987? Yes | No | N/A | Date of sentence: N/A | Bail/Jail Disposition: Committed | Not committed | N/A | Appellant is represented by counsel? Yes | No | If yes, provide the following information: Defendant's Counsel: Reid Weingarten Counsel's Address: 1114 Avenue of the Americas New York, NY 10036 Counsel's Phone: (212) 506-3900 Assistant U.S. Attorney: Alex Rossmiller AUSA's Address: 1 Saint Andrew's Plaza New York, NY 10007 AUSA's Phone: (212) 637-2415 Signature: Reid Weingarten DOJ-OGR-00000509 FILED U.S. DISTRICT COURT 2019 JUL 22 PM 4:47 S.D. OF N.Y. --- PAGE BREAK --- Case 21-770, Document 34, 04/05/2021, 3070625, Page1 of 1 ACKNOWLEDGMENT AND NOTICE OF APPEARANCE Short Title: United States of America v. Maxwell Docket No.: 21-770/21-58 Lead Counsel of Record (name/firm) or Pro se Party (name): David Oscar Markus, Markus/Moss PLLC Appearance for (party/designation): Ghislaine Maxwell DOCKET SHEET ACKNOWLEDGMENT/AMENDMENTS Caption as indicated is: (√) Correct ( ) Incorrect. See attached caption page with corrections. Appellate Designation is: (√) Correct ( ) Incorrect. The following parties do not wish to participate in this appeal: Parties: ____________________________________________________ ( ) Incorrect. Please change the following parties' designations: Party Correct Designation Contact Information for Lead Counsel/Pro Se Party is: (√) Correct ( ) Incorrect or Incomplete. As an e-filer, I have updated my contact information in the PACER "Manage My Account" screen. Name: David Oscar Markus Firm: Markus/Moss PLLC Address: 40 NW Third Street, PH 1, Miami, Florida 33128 Telephone: (305)379-6667 Fax: (305)379-6668 Email: dmarkus@markuslaw.com RELATED CASES ( ) This case has not been before this Court previously. ( ) This case has been before this Court previously. The short title, docket number, and citation are: ____________________________________________________ (√) Matters related to this appeal or involving the same issue have been or presently are before this Court. The short titles, docket numbers, and citations are: United States of America v. Maxwell, Case Number 21-58. CERTIFICATION I certify that (√) I am admitted to practice in this Court and, if required by LR 46.10(a)(2), have renewed my admission on ____________________________________________________ OR that ( ) I applied for admission on ____________________________________________________ or renewal on ____________________________________________________. If the Court has not yet admitted me or approved my renewal, I have completed Addendum A. Signature of Lead Counsel of Record: /s/ David Oscar Markus Type or Print Name: David Oscar Markus OR Signature of pro se litigant: ____________________________________________________ Type or Print Name: ____________________________________________________ ( ) I am a pro se litigant who is not an attorney. ( ) I am an incarcerated pro se litigant. DOJ-OGR-00001314 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 34 Filed 07/28/20 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------------------X UNITED STATES OF AMERICA, - v. - GHISLAINE MAXWELL, Defendant. --------------------------------------------------------------X STATE OF NEW YORK COUNTY OF NEW YORK SOUTHERN DISTRICT OF NEW YORK ALEX ROSSMILLER, pursuant to Title 28, United States Code, Section 1746, hereby affirms under penalty of perjury: 1. I am an Assistant United States Attorney in the Office of Audrey Strauss, Acting United States Attorney for the Southern District of New York. I am one of the Assistants who represents the Government in these proceedings. 2. I certify pursuant to Local Criminal Rule 16.1 that the Government has conferred in good faith with counsel to the defendant, Ghislaine Maxwell, regarding the Government's proposed protective order, pursuant to Federal Rule of Criminal Procedure 16. 3. The parties have been able to agree on most of the provisions of a protective order. However, the parties have been unable to resolve two areas of dispute. a. First, the defendant and her counsel have objected to the Government's proposal that the defense be permitted to reference identities of witnesses and victims to prospective defense witnesses (so long as those witnesses and their counsel abstain from further disclosing or disseminating any such identities), and be permitted to reference publicly any victim --- PAGE BREAK --- Case 1:20-cr-0030-AJN Document 34 Filed 07/28/20 Page 2 of 2 who has spoken—or who at some future time speaks—by name on the public record in this case, and otherwise be permitted to identify victim names in sealed filings, or identify victims by pseudonyms in public filings, or redact victim names in public filings, but that the defendant and her counsel be restricted from otherwise publicly referencing witness or victim identities. That disagreement is reflected in the differences between the Government's proposed order paragraphs 5, 6, 8, and 16 and the corresponding defense proposed paragraphs 6, 7, 9, and 17. b. Second, the defendant and her counsel have proposed certain restrictions on the Government and potential Government witnesses and their counsel. For the reasons set forth in the Government's accompanying letter, the Government does not believe that such restrictions are warranted or appropriate. That disagreement is reflected in the defendant's proposed paragraph 3, which does not have a corresponding paragraph in the Government's proposed order, and in the differences between the Government's proposed order paragraph 4 and the corresponding defense proposed paragraph 5. 4. I hereby certify that the foregoing statements made by me are true. Dated: New York, New York July 28, 2020 Alex Rossmiller Assistant United States Attorney Telephone: (212) 637-2415 2 DOJ-OGR-00001684