mirror-epstein-docs/results/IMAGES006/DOJ-OGR-00015125.json

{
  "document_metadata": {
    "page_number": "2 of 2",
    "document_number": "805-1",
    "date": "08/06/25",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 805-1 Filed 08/06/25 Page 2 of 2\n4. On July 18, 2025, Deputy Attorney General Todd Blanche appeared in this case on behalf of the government and filed a motion to unseal grand jury transcripts.\n5. On July 22, 2025, David Markus and Melissa Madrigal of Markus Moss PLLC (\"Markus Moss\") appeared as counsel of record in this case for Ms. Maxwell.\n6. We have spoken with Mr. Markus who has confirmed that Ms. Maxwell has retained Markus Moss to handle the government's unsealing motion and that he is prepared to meet any deadlines imposed by the Court.\n7. Mr. Markus has also informed us that he has discussed this motion with Ms. Maxwell and she consents to HMF's withdrawal from this matter.\n8. HMF is not asserting any liens in this matter and will share its files with Markus Moss upon request, subject to the conditions imposed by the protective order in this case (Dkt. No. 36).\n9. HMF has served a copy of this declaration and its notice of motion to withdraw on Ms. Maxwell via Mr. Markus.\nWe declare under penalty of perjury that the foregoing is true and correct.\nDated: August 6, 2025.\nRespectfully submitted,\ns/ Jeffrey S. Pagliuca\ns/ Laura A. Menninger\nJeffrey S. Pagliuca\nLaura A. Menninger\n945 N. Pennsylvania St.\nDenver, CO 80203\nPhone: 303-831-7364\nAttorneys for Ghislaine Maxwell\nDOJ-OGR-00015125",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 805-1 Filed 08/06/25 Page 2 of 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "4. On July 18, 2025, Deputy Attorney General Todd Blanche appeared in this case on behalf of the government and filed a motion to unseal grand jury transcripts.\n5. On July 22, 2025, David Markus and Melissa Madrigal of Markus Moss PLLC (\"Markus Moss\") appeared as counsel of record in this case for Ms. Maxwell.\n6. We have spoken with Mr. Markus who has confirmed that Ms. Maxwell has retained Markus Moss to handle the government's unsealing motion and that he is prepared to meet any deadlines imposed by the Court.\n7. Mr. Markus has also informed us that he has discussed this motion with Ms. Maxwell and she consents to HMF's withdrawal from this matter.\n8. HMF is not asserting any liens in this matter and will share its files with Markus Moss upon request, subject to the conditions imposed by the protective order in this case (Dkt. No. 36).\n9. HMF has served a copy of this declaration and its notice of motion to withdraw on Ms. Maxwell via Mr. Markus.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "We declare under penalty of perjury that the foregoing is true and correct.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "Dated: August 6, 2025.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "Respectfully submitted,",
      "position": "main body"
    },
    {
      "type": "signature",
      "content": "s/ Jeffrey S. Pagliuca\ns/ Laura A. Menninger",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "Jeffrey S. Pagliuca\nLaura A. Menninger\n945 N. Pennsylvania St.\nDenver, CO 80203\nPhone: 303-831-7364",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "Attorneys for Ghislaine Maxwell",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00015125",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Todd Blanche",
      "David Markus",
      "Melissa Madrigal",
      "Ms. Maxwell",
      "Jeffrey S. Pagliuca",
      "Laura A. Menninger",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "Markus Moss PLLC",
      "HMF"
    ],
    "locations": [
      "Denver, CO"
    ],
    "dates": [
      "July 18, 2025",
      "July 22, 2025",
      "August 6, 2025"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "805-1",
      "Dkt. No. 36",
      "DOJ-OGR-00015125"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ghislaine Maxwell. It is a declaration from attorneys Jeffrey S. Pagliuca and Laura A. Menninger, stating that they are withdrawing from the case and have served the necessary documents to the new counsel, Markus Moss PLLC. The document is dated August 6, 2025, and includes the attorneys' contact information."
}