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Case 1:20-cr-00330-PAE Document 314 Filed 07/12/21 Page/7of7 Page 7 because it is doing so in pleadings, it is not crossing the line in the local rules. For example, the Government filed in a public pleading that Ms. Maxwell was vaccinated while at MDC. (Dkt. No. 196). There was no valid reason for saying this at all, let alone in a public pleading. (Imagine if the defense publicly filed medical information about one of the accusers). But it believed that it could legally speak to the media in such a fashion. The Government also falsely claimed that Ms. Maxwell had an “eye mask” and that she was responsible for the stench in her cell. Jd. Both claims were proven to be untrue. She has never been provided an eye mask and the stench in her cell is caused by a sewage problem in the jail, which has been well-documented by other inmates and judges. But the damage was done. The media went into a feeding frenzy, reporting the false Government statements and ignoring the truth when it came out. As Mark Twain said, “a lie can travel halfway around the world while the truth is still putting on its shoes.” The Government’s responsibility for the fair administration of justice commands it to foster a realignment of the scales. The Government’s request should be denied because (1) undersigned counsel does not currently represent Ms. Maxwell, and (2) the Op-Ed did not violate the local rules. Sincerely, /s/ David Oscar Markus David Oscar Markus DOJ-OGR-00004961