DOJ-OGR-00015054.jpg

Case 1:20-cr-00330-PAE Document 793 Filed 07/22/25 Pagelof1 MARKUS / MOSS July 22, 2025 By ECF The Honorable Paul A. Engelmayer United States District Judge United Sates District Court for the Southern District of New York 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20-CR-330 (PAE) Dear Judge Engelmayer: We respectfully submit this letter in connection with our representation of Ghislaine Maxwell in the above-referenced case. Earlier today, the Court issued an Order directing the Government to file a supplemental memorandum, no later than Tuesday, July 29, 2025, addressing specific factors relevant to the Government’s application to unseal grand jury transcripts in this case. (Dkt. 789). Additionally, the Court ordered the Government to provide the Court with the grand jury transcripts that the Government seeks to unseal by July 29, 2025, for the Court’s review. Id. at 3. As counsel for Ms. Maxwell, we would similarly like to review the grand jury transcripts at issue (we have not seen them and our understanding is that they have never been provided to the defense in their entirety) in order to craft a response and set out our position to the Court. We have discussed our request to review the grand jury transcripts with Deputy Attorney General Todd Blanche, and he has no objection to our application. Thank you for your consideration in this matter. Respectfully submitted, /s/ David Oscar Markus David Oscar Markus Melissa Madrigal MARKUS/MOSS PLLC ce markuslaw.com DOJ-OGR-00015054