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Extracted Text (OCR)
Case 1:20-cr-00330-PAE Document 805-1 Filed 08/06/25 Page 2 of 2
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.
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.
6. 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.
7. 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.
8. 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).
9. HMF has served a copy of this declaration and its notice of motion to withdraw
on Ms. Maxwell via Mr. Markus.
We declare under penalty of perjury that the foregoing is true and correct.
Dated: August 6, 2025.
Respectfully submitted,
s/ Jeffrey S. Pagliuca
s/ Laura A. Menninger
Jeffrey S. Pagliuca
Laura A. Menninger
945 N. Pennsylvania St.
Denver, CO 80203
Phone: 303-831-7364
Attorneys for Ghislaine Maxwell
DOJ-OGR-00015125
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Document Details
| Filename | DOJ-OGR-00015125.jpg |
| File Size | 522.0 KB |
| OCR Confidence | 93.6% |
| Has Readable Text | Yes |
| Text Length | 1,356 characters |
| Indexed | 2026-02-03 18:53:03.013645 |