mirror-epstein-docs/results/IMAGES006/DOJ-OGR-00015054.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "793",
    "date": "July 22, 2025",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 793 Filed 07/22/25 Page 1 of 1\n\nMARKUS / MOSS\n\nJuly 22, 2025\n\nBy ECF\n\nThe Honorable Paul A. Engelmayer\nUnited States District Judge\nUnited Sates District Court for the\nSouthern District of New York\n40 Foley Square\nNew York, New York 10007\n\nRe: United States v. Ghislaine Maxwell, 20-CR-330 (PAE)\n\nDear Judge Engelmayer:\n\nWe respectfully submit this letter in connection with our representation of Ghislaine Maxwell in the above-referenced case.\n\nEarlier 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.\n\nAs 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.\n\nThank you for your consideration in this matter.\n\nRespectfully submitted,\n\n/s/ David Oscar Markus\nDavid Oscar Markus\nMelissa Madrigal\n\nMARKUS/MOSS PLLC\n40 NW 3rd Street, PH 1\nMiami, FL 33128\nT 305 379-6667\nF 305 379-6668\nmarkuslaw.com\n\nDOJ-OGR-00015054",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 793 Filed 07/22/25 Page 1 of 1",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "MARKUS / MOSS",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "July 22, 2025",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "By ECF\n\nThe Honorable Paul A. Engelmayer\nUnited States District Judge\nUnited Sates District Court for the\nSouthern District of New York\n40 Foley Square\nNew York, New York 10007",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Re: United States v. Ghislaine Maxwell, 20-CR-330 (PAE)",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Dear Judge Engelmayer:\n\nWe respectfully submit this letter in connection with our representation of Ghislaine Maxwell in the above-referenced case.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "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.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "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.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Thank you for your consideration in this matter.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Respectfully submitted,\n\n/s/ David Oscar Markus\nDavid Oscar Markus\nMelissa Madrigal",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "MARKUS/MOSS PLLC\n40 NW 3rd Street, PH 1\nMiami, FL 33128\nT 305 379-6667\nF 305 379-6668\nmarkuslaw.com",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00015054",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Paul A. Engelmayer",
      "Ghislaine Maxwell",
      "David Oscar Markus",
      "Melissa Madrigal",
      "Todd Blanche"
    ],
    "organizations": [
      "United States District Court for the Southern District of New York",
      "MARKUS/MOSS PLLC"
    ],
    "locations": [
      "New York",
      "Miami, FL"
    ],
    "dates": [
      "July 22, 2025",
      "July 29, 2025"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "793",
      "20-CR-330 (PAE)",
      "789",
      "DOJ-OGR-00015054"
    ]
  },
  "additional_notes": "The document is a letter from David Oscar Markus and Melissa Madrigal of MARKUS/MOSS PLLC to Judge Paul A. Engelmayer regarding the case United States v. Ghislaine Maxwell. The letter is dated July 22, 2025, and is related to the unsealing of grand jury transcripts."
}