DOJ-OGR-00000043.tif
Extracted Text
PETITION FOR WRIT OF CERTIORARI Ghislaine Maxwell respectfully petitions for a writ of certiorari to review the judgment of the United States Court of Appeals for the Second Circuit. OPINIONS BELOW The opinion of the Second Circuit (App.1) is reported at United States v. Maxwell, 118 F.4th 256 (2d Cir. 2024). The Second Circuit’s order denying Maxwell’s petition for rehearing en banc (App.92) is not pub- lished in the Federal Reporter. The district court’s order denying Maxwell’s motion to dismiss (App.52) is available at United States v. Maxwell, 534 F. Supp. 3d 299 (S.D.N.Y. 2021). JURISDICTION The Second Circuit issued its opinion on September 17, 2024. Maxwell’s motion for en banc review was denied on November 25, 2024. This Court has jurisdiction under 28 U.S.C. § 1254. CONSTITUTIONAL AND STATUTORY PROVISIONS INVOLVED There are no pertinent constitutional or statutory provisions involved in the matter at issue in this case. STATEMENT OF THE CASE Despite the existence of a non-prosecution agree- ment promising in plain language that the United States would not prosecute any co-conspirator of Jeffrey Epstein, the United States in fact prosecuted Ghislaine Maxwell as a co-conspirator of Jeffrey Epstein. Only because the United States did so in the Second Circuit and not elsewhere, her motion to dismiss the DOJ-OGR-00000043