805-01.pdf

Type: pdf
Source set: house-oversight-doj
Pages: 2
Text status: Searchable text available
OCR confidence: 0.9240595394943222

Extracted text

Case 1:20-cr-00330-PAE Document 805-1 _ Filed 08/06/25 Page1of2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ae x UNITED STATES OF AMERICA - : 20 Cr. 330 (PAE) GHISLAINE MAXWELL, : Defendant. oeeeeecneneeeeneneeeennnneneeneneneenneeee x DECLARATION OF JEFFREY S. PAGLIUCA AND LAURA A. MENNINGER IN SUPPORT OF MOTION TO WITHDRAW AS CO- COUNSEL We, JEFFREY S. PAGLIUCA AND LAURA A. MENNINGER, declare as follows: 1. We are partners at the law firm Haddon, Morgan & Foreman, P.C. (“HMF”), co- counsel for defendant Ghislaine Maxwell. We are 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 HMF’s motion to withdraw as co-counsel for defendant Ghislaine Maxwell in the above-captioned matter. 2 Ms. Maxwell retained HMF to represent her in the above-captioned case. We filed notice of appearances on July 8, 2020. HMF represented Ms. Maxwell at trial and through her sentencing on June 28, 2022. 3: Ms. Maxwell’s sentencing concluded her district court proceedings. Ms. Maxwell filed a notice of appeal on July 7, 2022. HMF did not represent Ms. Maxwell in her appellate proceedings. DOJ-OGR-00015124

Case 1:20-cr-00330-PAE Document 805-1 Filed 08/06/25 Page 2 of2 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 co…

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