20250117162420418_AMENDED%20Application%20to%20Extend%20Time%20to%20File%20Petition%20for%20Writ.pdf

App. No: 24A709

In the
Supreme Court of the United States

GHISLAINE MAXWELL,
Petitioner,
v.
UNITED STATES OF AMERICA,
Respondent.
__________________________
PETITIONER’S AMENDED APPLICATION TO EXTEND TIME
TO FILE PETITION FOR A WRIT OF CERTIORARI
___________________________
To the Honorable Sonia Sotomayor, as Circuit Justice for the United States Court of
Appeals for the Second Circuit:
1. Petitioner Ghislaine Maxwell respectfully requests that the time to file a
Petition for a Writ of Certiorari in this case be extended for forty five days to April 10, 2025.
The court of appeals issued the Order denying the Petition for Rehearing/Rehearing En Banc
on November 25, 2024. Absent an extension of time, the petition would be due on Monday,
February 24, 2025. Petitioner is filing this Application at least ten days before the due date.
See S.Ct. R. 13-5. The jurisdiction of this Court is invoked under 28 U.S.C. § 1254(1).
2. Petitioner seeks review of the opinion of the United States Court of Appeals
for the Second Circuit based on substantial questions relating to that court’s resolution of
petitioner’s appeal. Specifically, the Second Circuit’s opinion acknowledged that it
deepened a circuit split on whether a plea agreement is binding on federal prosecutors in
districts other than the one in which it is entered. See United States v. Maxwell, 118 F. 4th
256 n.11 (2nd Cir. 2024) (“recogniz[ing] that circuits have been split on this issue”).
3. Undersinged counsel was just retained yesterday, on January 14, 2024. Due
to case-related and other reasons, additional time is necessary and warranted for counsel to
research the decisional conflicts, and prepare a clear, concise, and comprehensive petition
for certiorari for the Court’s review. The press of other matters makes the submission of the
petition difficult absent an extension, especially because Petitioner engaged undersigned
counsel just this week to represent her in the Supreme Court. For example, Counsel is
scheduled to commence a multi-defendant trial on March 3, 2025, United States v. Diego
Sanudo Sanchez Chocron, Southern District of Florida, case number 24-cr-20155-RAR(s).
In addition, counsel is due to file a reply brief in this Court in Elizabeth Peters Young v.
United States, case number 24-571, shortly after the Goverment files its response on January
22, 2025.
Therefore, because of the importance of this issue, and the need to draft a meaningful
petition on such short notice, undersigned counsel is respectfully requesting an additional 45
days in the matter to file until April 10, 2025.
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Conclusion
For the foregoing reasons, the time to file a Petition for a Writ of Certiorari in this
matter should be extended forty five days to and including April 10, 2025.
Respectfully submitted,
MARKUS/MOSS PLLC
40 N.W. Third Street
Penthouse One
Miami, Florida 33128
Tel: (305) 379-6667
Fax: (305)379-6668
markuslaw.com
By: /s/ David Oscar Markus
David Oscar Markus
Florida Bar Number 119318
dmarkus@markuslaw.com
January 2025
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