Browse by Document Type
Other (98,409 documents)
Case 1:19-cr-00490-RMB Document2 _ Filed 07/02/19 Page 7 of 14
to touch him while he masturbated, and touch victims’ genitals
with his hands or with sex toys.
16. In connection with each sexual enco
Led
Case 1:19-cr-00490-RMB Document2 _ Filed 07/02/19 Page5of14
employees and associates, including a New York-based employee
(“Employee-1”), to communicate with victims via phone to arrange
for the
Case 1:19-cr-00490-RMB Document2 _ Filed 07/02/19 Page 4 of 14
9. When a victim arrived at the New York Residence,
she typically would be escorted to a room with a massage table,
where she would perf
Case 1:19-cr-00490-RMB Document2 _ Filed 07/02/19 Page 3 of 14
recruited, dozens of minor girls to engage in sex acts with him,
after which EPSTEIN paid the victims hundreds of dollars in
cash, at th
E-Mail Address: 1115 H Street, N.E.
Est yal [email protected] Washington, D.C. 20002
WSO Web Site: Tel (202) 789-0096
COEF www.wilsonepes.com Fax (202) 842-4896
No. 24-1073
GHISLAINE MAXWELL, A
No. 24-1073
IN THE
Supreme Court of the Anited States
GHISLAINE MAXWELL, AKA SEALED DEFENDANT 1,
Petitioner,
Vv.
UNITED STATES OF AMERICA,
Respondent.
On Petition for Writ of Certiorari to the
U
9
attempting to import unwritten limits that the deal-
makers did not include.
The government’s argument, across the board, is
essentially an appeal to what it wishes the agreement
had said, rather
i
TABLE OF AUTHORITIES
CASES Page(s)
Prisco v. United States,
562 U.S. 1290 (2011), No. 10-7895........... 2
Santobello v. New York,
404 U.S. 257 (1971)... cccceesssseeeeeeeeees 4,6
Thomas v. INS
TABLE OF CONTENTS
Page
TABLE OF AUTHORITIES ................cccccsecceeeeees li
REASONS FOR GRANTING THE PETITION .... 1
I. The government concedes that the
circuits are split as to whether a promise
No. 24-1073
IN THE
Supreme Court of the Anited States
GHISLAINE MAXWELL, AKA SEALED DEFENDANT 1,
Petitioner,
Vv.
UNITED STATES OF AMERICA,
Respondent.
On Petition for Writ of Certiorari to the
24-1073
MAXWELL, GHISLAINE
USA
SARA KROPF
KROPF MOSELEY SCHMITT PLLC
1100 H STREET, NW
SUITE 1220
WASHINGTON, DC 20005
202-627-6900
SARA@KMLA WFIRM.COM
DAVID OSCAR MARKUS VIA EMAIL
MARKUS/MOSS P
15
reference to ‘the government’ [at a plea hearing] clearly
referred to only the United States Attorney for the Dis-
trict of New Jersey”).
3. Indeed, this case would be an unsuitable candi-
date f
No. 24-1073
IN THE SUPREME COURT OF THE UNITED STATES
GHISLAINE MAXWELL, PETITIONER
V.
UNITED STATES OF AMERICA
CERTIFICATE OF SERVICE
It is hereby certified that all parties required to be serve
16
petitioner cannot make up for the absence of actual au-
thority by invoking principles of estoppel or apparent
authority against the government. See Federal Crop Ins.
Corp. v. Merrill, 332 U.S. 38
11
reasonably susceptible to petitioner’s broad interpreta-
tion.
Petitioner also invokes (Pet. 16-17) the interpretive
principle expressio unius est exclusio alterius, in argu-
ing that the NPA’s “
9
While petitioner emphasizes (Pet. 18) the paragraph
stating that Epstein sought “to resolve globally his
state and federal criminal liability,” Pet. App. 25a, even
as to “his” federal liability spe
Id. at 26a.
The NPA further specified that, if Epstein timely
fulfilled all the terms and conditions of the agreement,
no prosecution against him would “be instituted in this
District.” Pet. App. 26a
2
STATEMENT
Following a jury trial in the United States District
Court for the Southern District of New York, petitioner
was convicted on one count of conspiring to transport
minors with intent to e
IV
Cases—Continued: Page
United States v. Andreas, 216 F.3d 645 (7th Cir.),
cert. denied, 531 U.S. 1014 (2000) ..... eee eeceeseerseneeeee 15
United States v. Annabi,
771 F.2d 670 (2d Cir. 1985) oo
TABLE OF CONTENTS
Page
Opinions below ..........ceesscssesseeceseesceeeeccscesscssesseessasecsneesceesesseesesees 1
JULISCICTION ........csescssesecsceseescssvessssesessessecsenseososssssssevsssssses
Jn the Supreme Court of the Gnited States
No. 24-1078
GHISLAINE MAXWELL, PETITIONER
Vv.
UNITED STATES OF AMERICA
ON PETITION FOR A WRIT OF CERTIORARI
TO THE UNITED STATES COURT OF APPEALS
FOR THE S
Miscellaneous: Page
U.S. Dep’t of Justice, Justice Manual (Feb. 2018)........ 5, 10
Antonin Scalia & Bryan A. Garner, Reading Law:
The Interpretation of Legal Tests (2012).........cseseceeeeee 10
DO
U.S. Department of Justice
Office of the Solicitor General
Washington, D.C. 20530
June 6, 2025
Honorable Scott S. Harris
Clerk
Supreme Court of the United States
Washington, D.C. 20543
Re: Ghislaine
No. 24-1073
In the Supreme Court of the Anited States
GHISLAINE MAXWELL, PETITIONER
Vv.
UNITED STATES OF AMERICA
ON PETITION FOR A WRIT OF CERTIORARI
TO THE UNITED STATES COURT OF APPEALS
FOR THE
QUESTION PRESENTED
Whether petitioner’s prosecution for sex trafficking
of a minor, in violation of 18 U.S.C. 1591(a) and (b){2),
by the U.S. Attorney for the Southern District of New
York was prohib
24-1073
MAXWELL, GHISLAINE
USA
SARA KROPF
KROPF MOSELEY SCHMITT PLLC
1100 H STREET, NW
SUITE 1220
WASHINGTON, DC 20005
202-627-6900
[email protected]
DAVID OSCAR MARKUS
MARKUS/MOSS PLLC
40 N.W.
AFFIDAVIT OF SERVICE
SUPREME COURT OF THE UNITED STATES
No. 24-1073
we ee ee ee ene X
GHISLAINE MAXWELL,
Petitioner,
v.
UNITED STATES,
Respondent.
panne ee eee ee eee x
STATE OF NEW YORK )
COUNTY O
Service, by Priority Mail, postage prepaid. An electronic version was also served
by email to each individual.
That on the same date as above, I sent to this Court forty copies and 1 un-
bound copy o
SUPREME COURT OF THE UNITED STATES
No. 24-1073
wn ee ee ee eee X
GHISLAINE MAXWELL,
Petitioner,
v.
UNITED STATES,
Respondent.
wae ee ee ee ee eee X
CERTIFICATE OF COMPLIANCE
As required by Supreme C
9
Central District of California: “This agreement
is limited to the [Central District of California] USAO
and cannot bind any other federal, state, local, or foreign
prosecuting, enforcement, adminis
UV
Cited Authorities
Page
Other Authorities:
https://fm.cnbe.com/applications/enbe.com/
resources/editorialfiles/2022/12/21/
1671676065196-Caroline Ellison Plea_
Agreement.pdf i... ... cece eee eee
w
Cited Authorities
Page
Uyated States v. Maltk,
No. 4:24-er-00010-HEA, ECF No. 127
(Apr. 4, 2023)... cece e eens 10
United States v. Melntyre,
No. 1:24-er-00211, ECF No. 33 (Dee. 19, 2024) ..... 8
Cited Authorities
Page
United States v. Detloff Marketing
and Asset Management, Inc.,
No. 18-cr-00197-PAM-HB, ECF No. 96
(July 25, 2019)... ccc cece eee eee 10
United States v. Ellison,
No. 22-CR
uw
TABLE OF CITED AUTHORITIES
Page
Cases:
Brady v. United States,
397 U.S. 742 (1970)... eee ee 4,5
Giglio v. United States,
A405 U.S. 150 1972)... cc eee eee 12
McCarthy v. United States,
394 U
No. 24-1073
IN THE
Supreme Court of the United States
GHISLAINE MAXWELL,
Petitioner,
v.
UNITED STATES,
Respondent.
ON PETITION FOR A WRIT OF CERTIORARI TO THE
UNITED STATES Court oF APPEALS FOR TH
U.S. Department of Justice
Office of the Solicitor General
Washington, D.C. 20530
May 7, 2025
Honorable Scott S. Harris
Clerk
Supreme Court of the United States
Washington, D.C. 20543
Re: Ghislaine
24-1073
MAXWELL, GHISLAINE
USA
SARA KROPF
KROPF MOSELEY SCHMITT PLLC
1100 H STREET, NW
SUITE 1220
WASHINGTON, DC 20005
202-627-6900
[email protected]
DAVID OSCAR MARKUS
MARKUS/MOSS PLLC
40 N.W.
128a
not violate a clear and unambiguous standard and
therefore does not constitute professional misconduct.
2. The USAO’s Agreement Not to Prosecute
Unidentified “Potential Co-Conspirators”
Did Not
129a
and unambiguous standard or constituted professional
misconduct.
Notwithstanding this finding, in Section IV of this
Part, OPR includes in its criticism of Acosta’s decision
to approve the NPA
127a
authorities to let him out early.” Krischer responded
that under the proposal as it then stood, Epstein would
serve 15 months. He also told Villafafa that a plea to
a registrable offense would n
126a
evidence of “any other potential co-conspirators. So, . .
. we wouldn’t be prosecuting anybody else, so why not
include it? ... I just didn’t think that there was
anybody that it would cover.” S
121a
initiating, or encouraging immigration proceedings. It
also included a provision stating the government's
agreement to forgo a presentence investigation and a
promise by the government to suspend
115a
month federal charges with half of his jail
time being spent in home confinement
pursuant to the guidelines. I told him that I
had no objection to that approach but, in the
interest of full disc
1l12a
offering to meet the next day to work on the
agreement:
Can I suggest that tomorrow we either meet
live or via teleconference, either with your
client or having him within a quick phone
call,
109a
allegedly facilitated Epstein in his criminal scheme.
The defense sought a government promise not to
prosecute them, as well as certain other unnamed
Epstein employees, and a promise to forego i
107a
they reviewed at the time.* However, OPR’s evaluation
of the subjects’ conduct was aided significantly by
extensive, contemporaneous emails among the prose-
cutors and communications between the
105a
submissions from victims, concerning victim contacts
with the USAO and the FBI.
OPR identified former U.S. Attorney Acosta, three
former USAO supervisors, and the AUSA as subjects
of its invest
104a
the scope of its investigation an examination of the
government’s conduct that formed the basis for the
court’s findings that the USAO violated the CVRA in
failing to afford victims a reasonable
103a
argument, the government conceded that the USAO
had not been “fully transparent” with the petitioner
and had “made a mistake in causing her to believe that
the case was ongoing when in fact the
101la
created a vast network of underage victims in both
New York and Florida whom he sexually abused and
exploited. Epstein was arrested on the charges on July
6, 2019. In arguing for Epstein’s pret