{
  "document_metadata": {
    "page_number": "1",
    "document_number": "309",
    "date": "07/01/21",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 309 Filed 07/01/21 Page 1 of 3\nU.S. Department of Justice\nUnited States Attorney\nSouthern District of New York\nThe Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007\nJuly 1, 2021\nVIA ECF\nThe Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, New York 10007\nRe: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)\nDear Judge Nathan:\nThe 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.\nA. Mr. Markus's Statements to the Media\nDavid 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.1\n1 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-20210423-b3aza5eh7bddna7r247px2yb7e-story.html (quoting Mr. Markus, speaking outside the courthouse following the defendant's arraignment and identifying him as \"her attorney\").\nDOJ-OGR-00004807",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 309 Filed 07/01/21 Page 1 of 3",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "U.S. Department of Justice\nUnited States Attorney\nSouthern District of New York",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "The Silvio J. Mollo Building\nOne Saint Andrew's Plaza\nNew York, New York 10007",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "July 1, 2021",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "VIA ECF",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Honorable Alison J. Nathan\nUnited States District Court\nSouthern District of New York\nUnited States Courthouse\n40 Foley Square\nNew York, New York 10007",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Judge Nathan:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "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.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "A. Mr. Markus's Statements to the Media",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "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.1",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1 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-20210423-b3aza5eh7bddna7r247px2yb7e-story.html (quoting Mr. Markus, speaking outside the courthouse following the defendant's arraignment and identifying him as \"her attorney\").",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004807",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Alison J. Nathan",
      "Ghislaine Maxwell",
      "David Markus",
      "Stephen Rex Brown"
    ],
    "organizations": [
      "U.S. Department of Justice",
      "United States Attorney",
      "Southern District of New York",
      "New York Daily News",
      "Second Circuit"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "July 1, 2021",
      "April 14, 2021",
      "April 23, 2021"
    ],
    "reference_numbers": [
      "20 Cr. 330 (AJN)",
      "DOJ-OGR-00004807"
    ]
  },
  "additional_notes": "The document appears to be a formal letter from the U.S. Department of Justice to Judge Alison J. Nathan regarding a case involving Ghislaine Maxwell. The letter discusses a violation of Local Rule 23.1 by David Markus, an attorney representing Maxwell. The document is well-formatted and printed, with no visible handwriting or stamps."
}