# UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

# Thurgood Marshall U.S. Courthouse 40 Foley Square, New York, NY 10007 Telephone: 212-857-8500

## MOTION INFORMATION STATEMENT

Docket Number(s): 21-770/21-58

Motion for: Renewed Motion for Pretrial Release

Set forth below precise, complete statement of relief sought:
Ghislaine Maxwell renews her motion for pretrial release or in the alternative, remand for an evidentiary hearing.

United States of America v. Ghislaine Maxwell

MOVING PARTY: Ghislaine Maxwell
OPPOSING PARTY: United States of America

☐ Plaintiff ☐ Defendant
☑ Appellant/Petitioner ☐ Appellee/Respondent

MOVING ATTORNEY: David Oscar Markus
OPPOSING ATTORNEY: AUSA

[name of attorney, with firm, address, phone number and e-mail]

Markus/Moss PLLC
United States Attorney's Office, So. Dist. of NY

Please check appropriate boxes:

Has movant notified opposing counsel (required by Local Rule 27.1):

☑ Yes □ No (explain):___

Opposing counsel's position on motion:

Does opposing counsel intend to file a response:

Has this request for relief been made below?

Has this relief been previously sought in this court?

Requested return date and explanation of emergency:

Is oral argument on motion requested?

Has argument date of appeal been set?



Yes. No (requests for oral argument will not necessarily be granted)





Yes No If yes, enter date:



Signature of Moving Attorney:



/s/ David Oscar Markus





Date: 5/17/2021



Service by: ✔ CM/ECF



□ Other [Attach proof of service]



Form T-1080 (rev.12-13)

EFTA00089451

No. 21-770 & 21-58

In the

## UNITED STATES OF AMERICA,

Appellee,

## GHISLAINE MAXWELL,

Appellant.

On Appeal from the United States District Court for the Southern District of New York, 20-CR-330 (AJN)

Appellant Ghislaine Maxwell’s Renewed Motion for Pretrial Release

Leah S. Saffian

LAW OFFICES OF LEAH SAFFIAN





David Oscar Markus
*Counsel of Record*






markuslaw.com