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This legal document is a Notice of Appearance filed on April 1, 2021, by attorney David Oscar Markus of the firm Markus/Moss PLLC. He is formally notifying the court that he will be serving as additional counsel for Ghislaine Maxwell in the case of United States of America v. Maxwell (Docket No. 21-770/21-58), acting as co-counsel alongside Christian R. Everdell of Cohen & Gresser LLP.
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This legal document, filed on July 18, 2019, outlines the U.S. Government's argument against granting pretrial release to the defendant, Mr. Epstein. The Government asserts he is an extraordinary flight risk due to his wealth, access to private planes, and the long potential prison sentence he faces. The document also provides background on Epstein's past legal issues, including a 2005 investigation, a 2007 non-prosecution agreement, and a 2008 guilty plea in Florida, contrasting the prosecution's view with the defense's claim that Epstein is not a flight risk.
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This document is a page from a court transcript dated July 24, 2019, in a case involving Mr. Epstein. An unidentified speaker, likely the prosecutor, argues against the credibility of the defense's claims, particularly the idea that Epstein has disciplined himself. The speaker contends that this claim is an admission of his "appetite for children" and that the court should not risk community safety based on it, also referencing articles by the Miami Herald about Epstein's past misconduct.
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This document is a transcript from a legal proceeding where an attorney argues against an allegation that Mr. Epstein authorized an investigator to drive someone off the road. The speaker contends there is no proof of this authorization and that other attorneys involved, Mr. Goldberger and Roy Black, were never questioned about the incident and do not know the investigator. The argument is made to a judge ("Your Honor") and references a prior investigation in Florida.
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This legal document, filed on July 18, 2019, outlines the arguments concerning the pretrial release of the defendant, Mr. Epstein. The Government contends he is an extraordinary flight risk due to his wealth, access to private planes, and the lengthy potential prison sentence, citing a history of investigations for sex offenses starting around 2005. The Defense counters by arguing that Mr. Epstein's compliance with his sex-offender registration mitigates any danger and that he has never attempted to flee the U.S.
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This document is a contact sheet related to case number 24-1073 for Ghislaine Maxwell. It lists the contact information for two attorneys: Sara Kropf of Kropf Moseley Schmitt PLLC in Washington, D.C., and David Oscar Markus of Markus/Moss PLLC in Miami, FL. The document indicates it was transmitted via email.
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This is a page from a court transcript (cross-examination) filed on August 10, 2022. Attorney Mr. Pagliuca questions witness Ms. Hesse about her knowledge of women visiting Jeffrey Epstein for massages when Ghislaine Maxwell was not present, which Hesse confirms based on messages she took. The testimony also establishes that Hesse knew Maxwell had a home in New York but was unaware of a residence in Miami.
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This document is a handwritten pilot logbook page (page 97) signed by pilot David Rodgers, covering flights from late September to mid-November 2002. The logs detail flights on aircraft N908JE (Boeing 727) and N909JE (Gulfstream), recording routes between locations including Paris, London, New York, West Palm Beach, and St. Thomas (Little St. James). The logs explicitly list passengers for each leg, placing Jeffrey Epstein (JE) and Ghislaine Maxwell (GM) on flights with high-profile individuals such as Naomi Campbell, as well as frequent associates like Sarah Kellen (SK) and Andrea Metrovich.
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This document is a flight log page from March and April 2001 documenting flights on Jeffrey Epstein's Gulfstream (N909JE) and a Cessna (N908GM). Significant entries show Virginia Roberts ('VR') traveling with Epstein, Ghislaine Maxwell, and scientist Marvin Minsky to Santa Fe on March 29, 2001. The log also lists numerous other passengers including Banu Kucukkoylu, Alexis Wallace, and Henry Jarecki, and includes a redacted name on the March 31st flight.
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This document is a flight log page from 2003 signed by pilot David Rodgers. It records flights between July 31 and September 26 involving aircraft N908JE (Boeing 727), N909JE (Gulfstream), and N491GM (Bell Helicopter). Locations include New York (JFK), West Palm Beach (PBI), St. Thomas (TIST), Little St. James (LSJ), Santa Fe (SAF), Aspen (ASE), and Teterboro (TEB). The passenger names in the remarks column are fully redacted.
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This document is page 3 of a U.S. Customs and Border Protection (CBP) TECS Person Encounter List, generated on December 14, 2021, by Michael Aznaran. It lists various airport and preclearance locations where an individual had encounters with U.S. authorities. The locations include facilities in Teterboro, New York (JFK), Miami, Los Angeles (LAX), and Nassau, Bahamas.
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This document is an excerpt from an investigator's report dated November 21, 2005, detailing a visit to a residence in Orange Park, Florida. Investigators Bill Riley and Steve Kiraly, working for Jeffrey Epstein, attempted to interview a young woman but were met with extreme hostility from both the woman and her boyfriend's mother, Mary Parker, who ordered them off the property and threatened to call the police.
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This document is an investigator's report from November 21, 2005, detailing a failed attempt to interview a young woman in Orange Park, Florida. The investigators, Bill Riley and Steve Kiraly, working on behalf of Jeffrey Epstein, were met with extreme hostility by Mary Parker, the mother of the woman's boyfriend, who ordered them off her property and refused to cooperate.
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This document is the final page of a legal filing, dated January 24, 2008, from the law firm Herman & Mermelstein, P.A. On behalf of the plaintiff, Jane Doe's Father, the filing demands judgment for loss of consortium and other damages, and formally requests a jury trial. The document is signed by attorney Jeffrey M. Herman and lists other attorneys from the firm.
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This document is an excerpt from a DOJ OPR report analyzing the handling of the Epstein case by the US Attorney's Office. It details a significant communication breakdown between US Attorney Alexander Acosta and AUSA Marie Villafaña regarding the signing of Epstein's 2007 plea agreement (NPA), where Villafaña felt forced to sign a deal she opposed while Acosta claimed he intended to give her veto power. It also highlights how senior management (Menchel) blocked Villafaña from meeting directly with Acosta, resulting in final decisions being made without input from the prosecutor most familiar with the facts.
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This document, an OPR report, analyzes prosecutor Villafaña's conduct during the federal investigation and prosecution of Epstein, refuting a public narrative that she colluded with defense counsel. The report concludes that Villafaña consistently advocated for prosecuting Epstein, worked to protect victims' anonymity, and cared deeply about them, despite some criticisms of her interactions. It examines email exchanges and supervisor statements to provide context for her actions and explanations.
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This page from a DOJ OPR report analyzes the Non-Prosecution Agreement (NPA) negotiations between the USAO and Epstein's defense. It concludes that while prosecutor Villafaña's emails to defense attorney Lefkowitz appeared accommodating—suggesting 'off campus' meetings and venue changes to avoid press—OPR did not find evidence that these actions were motivated by improper favoritism or that Acosta's breakfast meeting with Lefkowitz materially altered the sentence. The document notes that state officials, not the USAO, were responsible for granting Epstein work release privileges.
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This legal document details the post-meeting communications and ongoing negotiations between the U.S. Attorney's Office (represented by Acosta and Sloman) and Jeffrey Epstein's defense counsel (Lefkowitz) regarding Epstein's Non-Prosecution Agreement (NPA). It highlights a significant dispute over alleged concessions Acosta made during a breakfast meeting, as claimed by Lefkowitz in an October 23, 2007 letter, and a contemporaneous draft response from the USAO refuting those claims.
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This legal document details communications from May 2008 regarding the Jeffrey Epstein case, where his defense team, including Starr and Whitley, petitioned the Deputy Attorney General for a review. They argued the federal prosecution was unwarranted, irregular, and politically motivated due to Epstein's "close personal association" with former President Bill Clinton. In response, a Senior Associate Deputy Attorney General instructed the U.S. Attorney's Office to postpone a June 2, 2008 plea deadline pending the completion of this high-level review.
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This legal document details a March 12, 2008 meeting where Jeffrey Epstein's defense team, including Ken Starr, presented their case to officials from the DOJ's Child Exploitation and Obscenity Section (CEOS). Following the meeting, the defense team submitted written complaints about the U.S. Attorney's Office's conduct, alleging improper coordination with state authorities and conflicts of interest. Footnotes reveal communications indicating the defense team actively tried to block communication between federal and state prosecutors.
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This document details the conflicts that arose immediately following the signing of a Non-Prosecution Agreement (NPA), focusing on the September-October 2007 period. The central issue was the selection of an attorney representative for the victims, where AUSA Villafaña's choice, Lefkowitz, was challenged by her colleague Sloman due to a potential conflict of interest, as Lefkowitz was recommended by an AUSA Villafaña was dating.
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This legal document details plea negotiations in the case against Mr. Epstein on and around September 21, 2007. It reveals intense back-and-forth communication between prosecutors (Acosta, Villafaña, Lourie) and defense attorneys (Lefkowitz, Sanchez) over critical terms, including whether Epstein would have to register as a sex offender and the scope of a non-prosecution agreement for his alleged co-conspirators. The document highlights internal prosecution strategies and their dismissive view of some members of Epstein's legal team.
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This document is a page from a DOJ OPR report detailing the 2007 plea negotiations between the US Attorney's Office (Villafaña, Sloman) and Epstein's defense (Lefkowitz). It highlights a specific email from Villafaña suggesting a Miami venue to minimize press coverage, which was later scrutinized during CVRA litigation. Crucially, it details the defense's counter-proposal to include immunity for four female assistants who facilitated Epstein's crimes, protection from immigration proceedings for two of them, and the withdrawal of legal processes seeking Epstein's computers.
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This document is a page from a DOJ OPR report detailing the internal conflict and confusion regarding the decision to offer Jeffrey Epstein a plea deal with only a two-year prison term. It highlights Prosecutor Villafaña's shock at the decision, noting she felt it violated sentencing guidelines and that she had not been consulted. The document confirms that U.S. Attorney Alexander Acosta ultimately made the decision for the two-year term, despite conflicting recollections from supervisors Menchel, Sloman, and Lourie regarding how and when this was communicated.
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This legal document details internal disagreements within a U.S. Attorney's Office regarding the prosecution of a case, likely against Epstein. Prosecutor Villafaña pushed for a rapid indictment, citing concerns about ongoing crimes, but her superiors, including Menchel, Sloman, and Acosta, believed she was moving too fast and that more review was necessary. The conflict led to multiple communications seeking direction and was later reviewed by the Office of Professional Responsibility (OPR).
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