mirror-epstein-docs/results/IMAGES006/DOJ-OGR-00015075.json

{
  "document_metadata": {
    "page_number": "1",
    "document_number": "798-1",
    "date": "08/01/25",
    "document_type": "Declaration",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 798-1 Filed 08/01/25 Page 1 of 2\n\nUNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK\n\nUNITED STATES OF AMERICA,\n- against -\nGHISLAINE MAXWELL,\nDefendant.\n\n20 Cr. 330 (PAE)\n\nDECLARATION OF CHRISTIAN R.\nEVERDELL IN SUPPORT OF MOTION\nTO WITHDRAW AS CO-COUNSEL\n\nI, CHRISTIAN R. EVERDELL, declare as follows:\n\n1. I am a partner at the law firm Cohen & Gresser LLP (\"C&G\"), co-counsel for defendant Ghislaine Maxwell. I am fully familiar with the facts set forth herein and respectfully submit this declaration pursuant to Local Civil Rule 1.4, Local Criminal Rule 1.1(b) (making Local Civil Rule 1.4 applicable to criminal proceedings), and Local Criminal Rule 1.2, in support of C&G's motion to withdraw as co-counsel for defendant Ghislaine Maxwell in the above-captioned matter.\n\n2. Ms. Maxwell retained C&G to represent her in the above-captioned matter. Mark Cohen and I filed notices of appearance on July 8, 2020. C&G represented Ms. Maxwell at trial and through her sentencing on June 28, 2022.\n\n3. Ms. Maxwell's sentencing concluded her district court proceedings. Ms. Maxwell filed a notice of appeal on July 7, 2022. C&G did not represent Ms. Maxwell in her appellate proceedings.\n\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.\n\nDOJ-OGR-00015075",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 798-1 Filed 08/01/25 Page 1 of 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "UNITED STATES DISTRICT COURT\nSOUTHERN DISTRICT OF NEW YORK",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "UNITED STATES OF AMERICA,\n- against -\nGHISLAINE MAXWELL,\nDefendant.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "20 Cr. 330 (PAE)\n\nDECLARATION OF CHRISTIAN R.\nEVERDELL IN SUPPORT OF MOTION\nTO WITHDRAW AS CO-COUNSEL",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "I, CHRISTIAN R. EVERDELL, declare as follows:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1. I am a partner at the law firm Cohen & Gresser LLP (\"C&G\"), co-counsel for defendant Ghislaine Maxwell. I am fully familiar with the facts set forth herein and respectfully submit this declaration pursuant to Local Civil Rule 1.4, Local Criminal Rule 1.1(b) (making Local Civil Rule 1.4 applicable to criminal proceedings), and Local Criminal Rule 1.2, in support of C&G's motion to withdraw as co-counsel for defendant Ghislaine Maxwell in the above-captioned matter.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "2. Ms. Maxwell retained C&G to represent her in the above-captioned matter. Mark Cohen and I filed notices of appearance on July 8, 2020. C&G represented Ms. Maxwell at trial and through her sentencing on June 28, 2022.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "3. Ms. Maxwell's sentencing concluded her district court proceedings. Ms. Maxwell filed a notice of appeal on July 7, 2022. C&G did not represent Ms. Maxwell in her appellate proceedings.",
      "position": "middle"
    },
    {
      "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.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00015075",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Christian R. Everdell",
      "Ghislaine Maxwell",
      "Mark Cohen",
      "Todd Blanche"
    ],
    "organizations": [
      "Cohen & Gresser LLP",
      "UNITED STATES DISTRICT COURT",
      "UNITED STATES OF AMERICA"
    ],
    "locations": [
      "SOUTHERN DISTRICT OF NEW YORK"
    ],
    "dates": [
      "July 8, 2020",
      "June 28, 2022",
      "July 7, 2022",
      "July 18, 2025",
      "08/01/25"
    ],
    "reference_numbers": [
      "20 Cr. 330 (PAE)",
      "1:20-cr-00330-PAE",
      "Document 798-1",
      "DOJ-OGR-00015075"
    ]
  },
  "additional_notes": "The document appears to be a formal legal declaration with no visible redactions or damage."
}