mirror-epstein-docs/results/IMAGES006/DOJ-OGR-00015076.json

{
  "document_metadata": {
    "page_number": "2",
    "document_number": "798-1",
    "date": "08/01/25",
    "document_type": "Court Document",
    "has_handwriting": true,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 798-1 Filed 08/01/25 Page 2 of 2\n\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.\n\n6. I 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.\n\n7. Mr. Markus has also informed me that he has discussed this motion with Ms. Maxwell and she consents to C&G's withdrawal from this matter.\n\n8. C&G 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).\n\n9. C&G has served a copy of this declaration and its notice of motion to withdraw on Ms. Maxwell via Mr. Markus.\n\nI declare under a penalty of perjury pursuant to 28 U.S.C. 1746 that the foregoing is true and correct.\n\nDated: August 1, 2025\nNew York, New York\n\nRespectfully submitted,\nCOHEN & GRESSER LLP\n\nChristian R. Everdell\n800 Third Avenue, 21st Floor\nNew York, NY 10022\nPhone: (212) 957-7600\nFax: (212) 957-4514\neverdell@cohengresser.com\n\nAttorneys for Ghislaine Maxwell\n\n2\nDOJ-OGR-00015076",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 798-1 Filed 08/01/25 Page 2 of 2",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "5. 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.\n\n6. I 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.\n\n7. Mr. Markus has also informed me that he has discussed this motion with Ms. Maxwell and she consents to C&G's withdrawal from this matter.\n\n8. C&G 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).\n\n9. C&G has served a copy of this declaration and its notice of motion to withdraw on Ms. Maxwell via Mr. Markus.",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "I declare under a penalty of perjury pursuant to 28 U.S.C. 1746 that the foregoing is true and correct.",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "Dated: August 1, 2025\nNew York, New York",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "Respectfully submitted,\nCOHEN & GRESSER LLP",
      "position": "main"
    },
    {
      "type": "handwritten",
      "content": "Christian R. Everdell",
      "position": "signature"
    },
    {
      "type": "printed",
      "content": "Christian R. Everdell\n800 Third Avenue, 21st Floor\nNew York, NY 10022\nPhone: (212) 957-7600\nFax: (212) 957-4514\neverdell@cohengresser.com",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "Attorneys for Ghislaine Maxwell",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "2",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00015076",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "David Markus",
      "Melissa Madrigal",
      "Ms. Maxwell",
      "Mr. Markus",
      "Christian R. Everdell",
      "Ghislaine Maxwell"
    ],
    "organizations": [
      "Markus Moss PLLC",
      "COHEN & GRESSER LLP"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "July 22, 2025",
      "August 1, 2025"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "798-1",
      "Dkt. No. 36",
      "DOJ-OGR-00015076"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ghislaine Maxwell. It is a declaration from Christian R. Everdell of COHEN & GRESSER LLP, stating that Ms. Maxwell has retained new counsel and consenting to C&G's withdrawal from the case. The document is signed and dated August 1, 2025."
}