20250728111721067_24-1073ReplyInSupportOfPetitionForWritOfCertiorari.pdf
179 KB
Extraction Summary
6
People
8
Organizations
4
Locations
3
Events
2
Relationships
6
Quotes
Document Information
Type:
Legal filing (supreme court reply brief)
File Size:
179 KB
Summary
This document is a legal reply brief filed in the Supreme Court on behalf of Ghislaine Maxwell (Petitioner) against the United States, dated July 28, 2025. The brief argues that the Non-Prosecution Agreement (NPA) signed by Jeffrey Epstein in the Southern District of Florida, which promised not to prosecute 'potential co-conspirators' in 'the United States,' should legally bind other districts like the Southern District of New York. The filing highlights a circuit split on whether US Attorneys can bind other districts and contends that the Second Circuit's decision allowing Maxwell's prosecution violates contract law and the plain text of the agreement.
People (6)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Petitioner / Sealed Defendant 1 |
Seeking Writ of Certiorari to enforce Epstein's NPA as a third-party beneficiary; arguing that the NPA binds the enti...
|
| Jeffrey Epstein | Deceased Defendant / Original Signer of NPA |
Signed the Non-Prosecution Agreement (NPA) in SDFL which granted immunity to himself and potential co-conspirators.
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| David Oscar Markus | Counsel of Record |
Attorney for Ghislaine Maxwell, author of the brief.
|
| Mona Markus | Attorney |
Attorney for Ghislaine Maxwell, listed on the brief.
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| Antonin Scalia | Former Supreme Court Justice |
Cited for his work 'Reading Law: The Interpretation of Legal Texts' regarding contract interpretation.
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| Bryan A. Garner | Author |
Cited co-author with Scalia on legal text interpretation.
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Organizations (8)
| Name | Type | Context |
|---|---|---|
| Supreme Court of the United States |
Court where the petition is filed.
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| United States Court of Appeals for the Second Circuit |
Lower court whose decision is being challenged.
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| United States Attorney's Office (Southern District of Florida) |
Office that negotiated and signed the original Epstein NPA.
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| United States Attorney's Office (Southern District of New York) |
Office that prosecuted Maxwell, allegedly in violation of the NPA.
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| Department of Justice (DOJ) |
Federal agency overseeing US Attorneys; heavily involved in the NPA drafting.
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| Office of Professional Responsibility (OPR) |
Conducted an investigation into the execution of the Epstein NPA.
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| Markus/Moss PLLC |
Law firm representing the Petitioner.
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| National Association of Criminal Defense Lawyers |
Filed an amicus brief supporting the Petitioner.
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Timeline (3 events)
2025-07-28
Filing of Reply in Support of Petition for Writ of Certiorari
Supreme Court of the United States
Unknown (Past)
Signing of Jeffrey Epstein's Non-Prosecution Agreement (NPA)
Southern District of Florida
Jeffrey Epstein
USAO SDFL
Unknown (Past)
OPR Investigation into the Epstein NPA
Washington, D.C.
Office of Professional Responsibility
DOJ Attorneys
Locations (4)
| Location | Context |
|---|---|
|
Location of the Supreme Court.
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Location of Markus/Moss PLLC.
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Jurisdiction where the Epstein NPA was signed.
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Jurisdiction where Maxwell was prosecuted.
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Relationships (2)
Maxwell is petitioning as a third-party beneficiary to Epstein's NPA under the clause protecting 'any potential co-conspirators of Epstein'.
Listed as 'Counsel of Record' for Petitioner.
Key Quotes (6)
"The petition asks whether a U.S. Attorney’s promise made on behalf of “the United States” binds the entire United States."Source
20250728111721067_24-1073ReplyInSuppo...
Quote #1
"Promising “not to prosecute” somehow meant preserving the right to prosecute. That is not contract interpretation; it is alchemy."Source
20250728111721067_24-1073ReplyInSuppo...
Quote #2
"“the United States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to [four names].”"Source
20250728111721067_24-1073ReplyInSuppo...
Quote #3
"If the “United States” means just the Southern District of Florida, why specify the district for Epstein?"Source
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Quote #4
"Under any normal reading of this contract, then, no federal charges can be brought against any co-conspirator in any district in the United States."Source
20250728111721067_24-1073ReplyInSuppo...
Quote #5
"The primary reason this Court should grant certiorari is to create one single default rule across the country as to what parties mean when they use the term “the United States” without further qualification."Source
20250728111721067_24-1073ReplyInSuppo...
Quote #6
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