Pennsylvania

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Also known as:
Commonwealth (Pennsylvania) University of Pennsylvania Lancaster, Pennsylvania Ashland, Pennsylvania Media, Pennsylvania 935 Pennsylvania Ave., NW, Washington, D.C. 950 Pennsylvania Avenue, N.W. – Room 3266 (DOJ Address) Reading, Pennsylvania

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EFTA00010767.pdf

This document is a chain of emails from whistleblower Christopher Dilorio to redacted recipients (likely regulators or law enforcement) sent between April and May 2019. Dilorio makes extensive allegations connecting Apollo Global Management (Leon Black), Jeffrey Epstein, Jared Kushner, and Russian interests to money laundering, stock fraud, and SEC corruption. The emails include links to various news articles and regulatory filings to support claims of financial misconduct involving 'shell' companies like Environmental Solutions Worldwide and DryShips.

Email chain / whistleblower complaint
2025-12-25

EFTA00010710.pdf

This document is a series of whistleblower emails from Christopher Dilorio sent between April and May 2019, alleging massive corruption involving the SEC, Apollo Global Management, and the Trump administration. Dilorio claims that companies like DryShips and Environmental Solutions Worldwide (ESWW) are money laundering shells linked to Jeffrey Epstein, Leon Black, and George Economou. He further alleges that the SEC dropped investigations into Apollo after meetings between Jared Kushner and Apollo co-founder Joshua Harris.

Email chain / whistleblower complaint
2025-12-25

EFTA00010414.pdf

This document is a legal letter from Ghislaine Maxwell's defense counsel to Judge Alison Nathan, dated July 2, 2021. The defense cites a recent Pennsylvania Supreme Court decision overturning Bill Cosby's conviction due to a violation of a non-prosecution promise, arguing that this precedent supports dismissing charges against Maxwell based on the Epstein Non-Prosecution Agreement (NPA). The letter contends that the government is violating due process by reneging on the specific immunity granted to Maxwell in the NPA.

Legal correspondence / court filing
2025-12-25

DOJ-OGR-00020813.jpg

This document is page 4 of a legal opinion (Case 22-1426) dated February 28, 2023. The court rejects Ghislaine Maxwell's arguments that the *Commonwealth v. Cosby* decision or the *Annabi* precedent should prevent her prosecution. The court rules that the Non-Prosecution Agreement (NPA) from one district does not bind another district in this context, distinguishing her situation from Bill Cosby's case where a specific promise not to prosecute was made by a district attorney.

Legal opinion / court filing
2025-11-20

DOJ-OGR-00020812.jpg

This document is a page from a court order rejecting Ghislaine Maxwell's argument that Jeffrey Epstein's Non-Prosecution Agreement (NPA) protects her from prosecution in the Southern District of New York. Citing the Second Circuit precedent *United States v. Annabi*, the court maintains that plea agreements generally only bind the specific district where they are entered. The court dismisses Maxwell's renewed motion and supplemental authority, affirming that the SDNY is not bound by the agreement made in another district.

Court order / legal opinion (page from appellate record)
2025-11-20

DOJ-OGR-00015241.jpg

This document is page 30 of a bibliography, identified as LOFTUS-046, listing academic publications primarily from 2013 and 2014. The works are heavily focused on the research of E.F. Loftus and numerous colleagues in the fields of psychology and law. Key topics include misinformation, false memories, eyewitness testimony, repressed memories, and legal system reforms.

Bibliography
2025-11-20

DOJ-OGR-00002281.jpg

This document is page 'ii' (3 of 19) of a legal filing from January 25, 2021, related to Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). It is a 'Table of Authorities' section listing various legal precedents (cases) cited in the main document, including United States v. Halper and United States v. Burke. The document bears a Department of Justice Bates stamp 'DOJ-OGR-00002281'.

Legal filing (table of authorities)
2025-11-20

DOJ-OGR-00002281(1).jpg

This document is a Table of Authorities page (Page 3 of 19) from a court filing dated January 25, 2021, in Case 1:20-cr-00330-AJN (United States v. Ghislaine Maxwell). It lists twenty-one legal precedents (cases) cited in the brief, primarily from the Second Circuit and D.C. Circuit, covering dates from 1964 to 2011. The document bears a Department of Justice Bates stamp DOJ-OGR-00002281.

Court filing (table of authorities)
2025-11-20

DOJ-OGR-00010144.jpg

This document is a page from a professional resume or curriculum vitae for Stephen Gillers, filed as part of a court case. It details his public lectures, participation in PBS series on ethics and the Constitution, and extensive legal and public service activities. Key activities include holding leadership and member roles in various American Bar Association commissions and being retained by the New Jersey Supreme Court to analyze lawyer disciplinary systems.

Legal document
2025-11-20

DOJ-OGR-00004892.jpg

This document is the final page (80 of 80) of a legal filing in the case United States v. Ghislaine Maxwell (1:20-cr-00330-PAE), filed on July 2, 2021. The content is an excerpt from the Pennsylvania Supreme Court's opinion vacating Bill Cosby's conviction, focusing on the concept of 'fundamental fairness' regarding prosecutorial discretion and non-prosecution agreements. This precedent was likely submitted by the defense to argue regarding the validity of the Non-Prosecution Agreement (NPA) previously granted to Jeffrey Epstein.

Court filing / legal opinion (exhibit)
2025-11-20

DOJ-OGR-00004878.jpg

This document is a page from a legal filing in Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on July 2, 2021. The text appears to be an excerpt from a Pennsylvania Supreme Court opinion (*Commonwealth v. Taylor*) discussing the Fifth Amendment privilege against self-incrimination, citing various U.S. Supreme Court precedents to argue that the privilege applies broadly in both criminal and civil/administrative proceedings. The document emphasizes that the right accompanies a person regardless of the legal proceeding type.

Legal filing / court opinion exhibit
2025-11-20

DOJ-OGR-00004871.jpg

This page is an excerpt from a legal document filed on July 2, 2021, in the case of United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE). The text appears to be from the Pennsylvania Supreme Court opinion in *Commonwealth v. Cosby* (indicated by docket [J-100-2020]), which was used by Maxwell's defense to argue about the enforceability of non-prosecution agreements. The text discusses the scope of prosecutorial discretion versus a defendant's due process rights and fundamental fairness, specifically when a defendant relies on a prosecutor's actions to their detriment.

Legal filing / court opinion attachment
2025-11-20

DOJ-OGR-00004869.jpg

This is page 57 of a legal filing (Document 310-1) from the Ghislaine Maxwell case (1:20-cr-00330-PAE), filed on July 2, 2021. The text presents legal arguments citing various precedents (including Martinez, Carrillo, and Baird) to establish that non-prosecution agreements should be treated as binding contracts similar to plea agreements. This argument is likely being used to support the defense's claim regarding the applicability of the 2007 Epstein non-prosecution agreement.

Legal filing / court opinion page
2025-11-20

DOJ-OGR-00004867.jpg

This document is page 55 of 80 from a legal filing (Document 310-1) in the case United States v. Ghislaine Maxwell (1:20-cr-00330-PAE), filed on July 2, 2021. The text is an excerpt from a legal opinion citing the precedent of *Commonwealth v. Zuber*, discussing the legal obligation of prosecutors to honor promises made during plea bargaining. This is likely included in a defense motion arguing for the enforcement of a non-prosecution agreement (likely the Epstein NPA) based on the principle of 'benefit of the bargain.'

Legal filing / court opinion exhibit
2025-11-20

DOJ-OGR-00004866.jpg

This document is page 54 of a legal filing (Exhibit 310-1) from Case 1:20-cr-00330-PAE (United States v. Ghislaine Maxwell), filed on July 2, 2021. The text contains legal arguments citing precedents such as *Santobello v. New York* and *Commonwealth v. Zuber* regarding the binding nature of prosecutorial promises and plea agreements under due process principles. It serves as a supporting legal authority, likely arguing that the government must honor previous non-prosecution agreements.

Legal filing / court document exhibit
2025-11-20

DOJ-OGR-00004863.jpg

This document is a page from a legal filing in the case United States v. Ghislaine Maxwell (Case 1:20-cr-00330-PAE), filed on July 2, 2021. It contains an excerpt from a judicial opinion regarding *Commonwealth v. Cosby*, specifically discussing former D.A. Bruce Castor's testimony and emails asserting his intent to permanently bind the Commonwealth from prosecuting Bill Cosby for a 2004 incident to remove his Fifth Amendment protections in civil court. This case law was likely cited in the Maxwell trial regarding the validity of non-prosecution agreements.

Court filing / legal opinion exhibit
2025-11-20

DOJ-OGR-00004861.jpg

This document is Page 49 of a larger filing (Document 310-1) in the case USA v. Ghislaine Maxwell (1:20-cr-00330-PAE). The text is an excerpt from a legal opinion (likely the Pennsylvania Supreme Court opinion in Commonwealth v. Cosby) discussing the legal effect of D.A. Bruce Castor's 2005 decision not to prosecute Bill Cosby. It serves as legal precedent regarding non-prosecution agreements (NPAs) and whether a prosecutor's promise not to charge a defendant is binding and prevents future prosecution. This case law was cited in the Maxwell trial because Maxwell's defense argued that Jeffrey Epstein's 2007 Non-Prosecution Agreement in Florida should shield her from federal prosecution.

Legal opinion / court exhibit
2025-11-20

DOJ-OGR-00004860.jpg

This document is page 48 of a court filing (Exhibit 310-1) from the Ghislaine Maxwell case (Case 1:20-cr-00330-PAE), filed on July 2, 2021. However, the content of the page is an excerpt from the Pennsylvania Supreme Court opinion *Commonwealth v. Cosby* (2020), detailing the legal issues surrounding Bill Cosby's appeal, specifically concerning a non-prosecution agreement made by District Attorney Castor in 2005. This legal precedent regarding non-prosecution agreements was likely cited by Maxwell's defense team to argue similar issues regarding Epstein's plea deal.

Court filing / legal opinion (exhibit)
2025-11-20

DOJ-OGR-00004855.jpg

This document is page 43 of 80 from a legal filing in the Ghislaine Maxwell case (1:20-cr-00330-PAE), filed on July 2, 2021. The text analyzes legal precedents from the Bill Cosby case (Commonwealth v. Cosby), focusing on the admissibility of 'prior bad acts' evidence, Rule 404(b), and the use of drugs (Quaaludes vs. Benadryl) to establish mens rea. It appears this case law is being cited to support arguments regarding evidence admissibility in the Maxwell trial.

Legal filing / court opinion excerpt
2025-11-20

DOJ-OGR-00004852.jpg

This document is Page 40 of 80 from a legal filing (Exhibit) in the Ghislaine Maxwell case (1:20-cr-00330), filed on July 2, 2021. The text is an excerpt from a legal opinion regarding *Commonwealth v. Cosby*, discussing the procedural history of Bill Cosby's appeal and the legal standards for admitting 'prior bad acts' evidence under Rule 404(b) and the 'common plan, scheme, or design' exception. It cites precedents *Commonwealth v. Miller* and *Commonwealth v. Tyson* to analyze how such evidence is used to establish identity or counter defenses of consent.

Legal filing / court opinion exhibit
2025-11-20

DOJ-OGR-00004851.jpg

This document is a page from a legal filing (Case 1:20-cr-00330-PAE, United States v. Ghislaine Maxwell) citing the legal precedent of *Commonwealth v. Cosby*. The text details the court's reasoning for admitting 'prior bad acts' evidence (Rule 404(b)) and deposition testimony regarding Quaaludes in the Bill Cosby trial to prove intent and motive. It concludes with a summary of Cosby's conviction for aggravated indecent assault and his designation as a 'sexually violent predator' under SORNA.

Legal filing / court opinion exhibit
2025-11-20

DOJ-OGR-00004850.jpg

This document is page 38 of a legal filing from the Ghislaine Maxwell case (1:20-cr-00330-PAE), filed on July 2, 2021. It discusses legal arguments regarding the admissibility of 'prior bad acts' evidence and the 'doctrine of chances,' heavily citing Pennsylvania case law involving Bill Cosby (Commonwealth v. Cosby) and Andrea Constand. The text argues that the similarity of crimes can outweigh the remoteness in time between incidents.

Court filing / legal brief (case law citation)
2025-11-20

DOJ-OGR-00004849.jpg

This document is a page from a legal filing (Case 1:20-cr-00330-PAE, likely USA v. Ghislaine Maxwell) filed on July 2, 2021. It appears to be quoting a legal opinion regarding the Bill Cosby case (specifically referencing case J-100-2020 and Commonwealth v. Hicks), discussing the admissibility of 'prior bad acts' evidence and the 'doctrine of chances' to prove lack of mistake or accident in sexual assault cases. The text analyzes Cosby's modus operandi involving intoxicants and mentions Andrea Constand and 19 other witnesses.

Legal filing / court opinion exhibit
2025-11-20

DOJ-OGR-00004841.jpg

This document is a page from a legal opinion (likely the Pennsylvania Supreme Court decision in Commonwealth v. Cosby) filed as an exhibit in the Ghislaine Maxwell case (1:20-cr-00330-PAE). It discusses the legal insufficiency of a 'press release' issued by D.A. Castor to grant immunity to Bill Cosby without court permission. The text cites Pennsylvania statutes regarding witness immunity and highlights the inconsistency of Castor's testimony regarding his intent.

Legal filing (court opinion/exhibit)
2025-11-20

DOJ-OGR-00004840.jpg

This document is a page from a legal filing (Exhibit attached to Document 310-1 in Case 1:20-cr-00330-PAE, likely United States v. Ghislaine Maxwell) filed on July 2, 2021. It presents an excerpt from a Pennsylvania Supreme Court opinion ([J-100-2020]) regarding Commonwealth v. Cosby. The text analyzes whether former D.A. Castor had a valid non-prosecution agreement with Bill Cosby, concluding that the interaction was an 'unauthorized contemplation of transactional immunity' that did not comply with Pennsylvania statutes. This legal precedent regarding immunity deals is likely being cited in the Maxwell/Epstein proceedings to argue the validity or invalidity of similar non-prosecution agreements.

Legal filing / court exhibit (excerpt from pennsylvania supreme court opinion cited in federal case)
2025-11-20
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