19 III. This case is an ideal vehicle for resolving the split over this important and recurring question. This case is especially worthy of review because it cleanly presents the issue at hand, which is ripe for this Court’s attention. In this case, the government made a written promise that Epstein’s co-conspirators would not be prosecuted by the United States, and Maxwell was in fact prosecuted as a co-conspirator of Epstein by the United States. The only question is whether the government’s promise that the “United States” would not prosecute her was enforceable against the U.S. Attorney’s office in New York, or only against the Southern District of Florida. The circuit split on this issue is well developed and ripe for the Court’s review. CONCLUSION For the foregoing reasons, this Court should grant the petition for certiorari. Respectfully submitted, DAVID OSCAR MARKUS Counsel of Record MARKuUs/Moss PLLC 40 N.W. Third Street Penthouse One Miami, FL 33128 (305) 379-6667 dmarkus@markuslaw.com Counsel for Petitioner April 10, 2025 DOJ-OGR-O0000061