DOJ-OGR-00000255.tif

11 others to prevent any federal prosecution of Epstein’s circle. Whether or not this was wise, it was the deal, and Petitioner is entitled to enforce it. III. This case is an ideal vehicle for resolving the split over this important and recurring question. It is hard to imagine a more compelling scenario for this Court’s review: for decades now, the same federal promise has yielded opposite results in different jurisdictions, undermining the uniformity of federal law and the integrity of plea bargains nationwide. This Court’s review is warranted. CONCLUSION For the foregoing reasons, this Court should grant the petition for certiorari. Respectfully submitted, DAVID OSCAR MARKUS Counsel of Record MONA MARKUS MARKUS/Moss PLLC 40 N.W. Third Street Penthouse One Miami, FL 33128 (305) 379-6667 dmarkus@markuslaw.com Counsel for Petitioner July 28, 2025 DOJ-OGR-00000255