This document is a legal reply brief filed in the Supreme Court on behalf of Ghislaine Maxwell (Petitioner) against the United States, dated July 28, 2025. The brief argues that the Non-Prosecution Agreement (NPA) signed by Jeffrey Epstein in the Southern District of Florida, which promised not to prosecute 'potential co-conspirators' in 'the United States,' should legally bind other districts like the Southern District of New York. The filing highlights a circuit split on whether US Attorneys can bind other districts and contends that the Second Circuit's decision allowing Maxwell's prosecution violates contract law and the plain text of the agreement.
This document is a confidential letter dated September 2, 2020, from the DOJ Office of Professional Responsibility (OPR) to the FBI. OPR informs the FBI that it has completed an investigation into the U.S. Attorney's Office for the Southern District of Florida regarding the 2007 Non-Prosecution Agreement (NPA) with Jeffrey Epstein. OPR is providing the draft report to the FBI for a sensitivity review before releasing it to Congress and the public, noting that FBI personnel names will not appear in the final text.
This document is a chain of internal emails between the FBI and DOJ from September and October 2020. The correspondence concerns the review of a draft report by the Office of Professional Responsibility (OPR) regarding the Southern District of Florida's handling of the Jeffrey Epstein investigation between 2006 and 2008. FBI officials, including a Unit Chief and Special Agent, are coordinating to review the report specifically to ensure its release does not compromise their '7A stance,' which refers to FOIA Exemption 7(A) protecting ongoing law enforcement proceedings.
This document is an email from March 10, 2020, sent by an official at the DOJ's Office of Professional Responsibility regarding the 'OPR Epstein investigation.' The sender requests a brief consultation with the recipient that afternoon. The names and contact details of the individuals involved are redacted.
This document is a redacted email from November 9, 2020, between various high-level Department of Justice offices including the Office of Privacy and Civil Liberties (OPCL), the Office of the Deputy Attorney General (ODAG), the Office of Professional Responsibility (OPR), and the US Attorney for the Southern District of New York (USANYS). The subject matter concerns 'Victim Meeting Talking Points,' suggesting coordination on how to address victims, likely related to the Epstein/Maxwell case given the involvement of SDNY and the timing (post-Epstein death, post-Maxwell arrest).
This document is an Opinion & Order by District Judge Alison J. Nathan in the case against Ghislaine Maxwell. The Court denies Maxwell's motions to dismiss the indictment based on Jeffrey Epstein's 2007 Non-Prosecution Agreement, statute of limitations arguments, and pre-indictment delay. However, the Court grants Maxwell's motion to sever the perjury charges from the sex trafficking-related charges, ruling they must be tried separately to ensure a fair trial. The Court also orders the parties to negotiate a schedule for outstanding pretrial disclosures.
This document is an email forwarding a Law360 article from February 2019. The article discusses a DOJ Office of Professional Responsibility (OPR) investigation into Labor Secretary Alexander Acosta's handling of the 2008 Jeffrey Epstein sex trafficking case. It highlights legislative efforts (the Inspector General Access Act) to transfer oversight of attorney misconduct from the OPR to the independent Office of Inspector General (OIG), citing the Epstein case as a catalyst for this reform due to concerns over OPR's lack of transparency and independence.
This document is a Reply Memorandum filed by Ghislaine Maxwell's defense team on March 15, 2021, supporting her motion to dismiss the indictment based on the Non-Prosecution Agreement (NPA) Jeffrey Epstein signed in Florida. Maxwell argues that the NPA's clause immunizing 'potential co-conspirators of Epstein' explicitly covers her and bars the current prosecution in the Southern District of New York. The defense contends that the government's attempt to limit the NPA geographically (to Florida) or to specific crimes is contradicted by the plain text of the agreement and legal precedent regarding plea agreements.
An email from attorney Stuart Kaplan to the US Attorney's Office (SDNY) and FBI regarding his client, a retired FBI Special Agent. The client has been subpoenaed to testify in the Ghislaine Maxwell trial and is requesting access to '1A notes' related to an FD-302 report to prepare. The email also reveals that the agent was interviewed under oath by the Office of Professional Responsibility (OPR) regarding the Jeffrey Epstein investigation just prior to her retirement.
This document is an email chain from September 27, 2021, initiated by attorney Stuart N. Kaplan to the US Attorney's Office for the Southern District of New York (USANYS). Kaplan advises that he represents a retired FBI Special Agent who has been subpoenaed to testify in the *United States v. Ghislaine Maxwell* trial. Kaplan requests '1A notes' related to an FD-302 report to help his client prepare for testimony and discloses that his client was previously interviewed under oath by the Office of Professional Responsibility (OPR) regarding the Jeffrey Epstein investigation.
This document is an email chain from April 2020 between the DOJ's Office of Professional Responsibility (OPR) and the US Attorney's Office for the Southern District of New York (SDNY). OPR is seeking to interview 32 individuals regarding their historical contacts (2005-2008) with the Southern District of Florida (USAO-SDFL) and FBI Miami concerning the Epstein case. SDNY agrees to the interviews but requests that OPR avoid discussing the substance of the underlying criminal scheme or interactions with Epstein to avoid interfering with SDNY's active investigation, noting that any relevant statements must be handled as '3500 material' (Jencks Act). The correspondence lists the legal representation for the 32 individuals, noting the majority are represented by Brad Edwards.
This document is the Executive Summary of a DOJ Office of Professional Responsibility (OPR) report from November 2020 investigating the conduct of U.S. Attorney Alexander Acosta and other prosecutors regarding the 2007 Non-Prosecution Agreement (NPA) with Jeffrey Epstein. OPR concluded that while Acosta exercised 'poor judgment' in resolving the case via NPA and failing to ensure victims were notified, he did not commit professional misconduct as defined by clear and unambiguous standards. The report details the history of the investigation, the CVRA litigation by victims, and the subsequent fallout leading to Acosta's resignation and Epstein's 2019 arrest and death.
This document is a 'Second Supplemental Privilege Log' from the case Jane Doe v. United States, listing internal DOJ, FBI, and USAO communications withheld from civil discovery. The log chronicles the timeline of the Jeffrey Epstein investigation from late 2006 to August 2008, detailing the internal deliberations regarding the Non-Prosecution Agreement (NPA), plea negotiations, and the drafting of the indictment. It reveals critical details such as internal disagreements over plea terms, Epstein's refusal to plead to anything other than 'assault on the plane,' Jay Lefkowitz's admission that he never intended Epstein to register as a sex offender, and the government's struggles with victim notification and harassment by Epstein's defense team.
This document is an Opinion & Order by Judge Alison J. Nathan in the case against Ghislaine Maxwell. The Court denied Maxwell's motions to dismiss the indictment based on Jeffrey Epstein's 2007 Non-Prosecution Agreement, statute of limitations, and pre-indictment delay. However, the Court granted Maxwell's motion to sever the perjury charges, ruling they will be tried separately from the sex trafficking-related counts to ensure a fair trial.
This document is an email from the Office of Professional Responsibility (OPR) to the U.S. Attorney's Office for the Southern District of New York (USANYS) on August 6, 2020, attaching a draft report concerning the handling of the Jeffrey Epstein matter by the U.S. Attorney's Office for the Southern District of Florida between 2006 and 2008 for review. The email includes names of redacted individuals from both organizations and mentions an AUSA in the CC.
This document is an email dated February 6, 2019, circulating a Miami Herald article by Julie K. Brown. The article reports that the DOJ, specifically the Office of Professional Responsibility (OPR), opened an investigation into Labor Secretary Alex Acosta's role in the 2008 plea deal granted to Jeffrey Epstein. This investigation was initiated in response to a request by Senator Ben Sasse following the Herald's 'Perversion of Justice' series.
This document is an email chain from June 27, 2019, involving high-level DOJ officials from the Office of Professional Responsibility (OPR), the Office of the Deputy Attorney General (ODAG), and the SDNY Public Corruption Unit. The correspondence concerns the search for a 'non-public appendix' to Jeffrey Epstein's Non-Prosecution Agreement (NPA), which reportedly contains a list of victims entitled to compensation. OPR confirms they can assist and involves their lead counsel on the investigation.
This document is the Executive Summary of a DOJ Office of Professional Responsibility (OPR) report from November 2020 investigating the conduct of U.S. Attorney Alexander Acosta and other prosecutors regarding the 2007 Non-Prosecution Agreement (NPA) with Jeffrey Epstein. OPR concluded that while Acosta exercised "poor judgment" in resolving the case via the NPA and failing to ensure victims were properly notified, he and his staff did not commit professional misconduct as defined by DOJ standards. The report details the history of the investigation, the secret negotiations, the subsequent violation of the Crime Victims' Rights Act (CVRA), and the eventual fallout leading to Acosta's resignation as Labor Secretary in 2019.
This document is an Executive Summary of a November 2020 DOJ Office of Professional Responsibility report investigating the 2006-2008 federal handling of the Jeffrey Epstein case by the US Attorney's Office for the Southern District of Florida. It details the negotiation of the controversial Non-Prosecution Agreement (NPA) approved by then-US Attorney Alexander Acosta, which allowed Epstein to plead to lesser state charges, and examines the failure of the government to consult with victims under the Crime Victims' Rights Act (CVRA). The report concludes that while Acosta and other attorneys did not commit professional misconduct by definition, Acosta exercised 'poor judgment' in resolving the case via the NPA and the government failed to treat victims with necessary forthrightness.
This document is a legal memorandum filed on October 13, 2021, by Ghislaine Maxwell's defense team in the Southern District of New York. The defense argues that due to 'tsunami' of negative pretrial publicity surrounding Maxwell and Jeffrey Epstein (including books, podcasts, and documentaries), standard jury selection is insufficient. They request the Court allow individual sequestered voir dire and limited attorney-conducted questioning to identify and remove biased jurors.
This document is a legal memorandum filed on October 13, 2021, by Ghislaine Maxwell's defense team in the Southern District of New York. The defense argues for individual sequestered voir dire (jury selection questioning) and permission for attorneys to conduct limited questioning of jurors, citing 'tsunami' levels of negative pretrial publicity and the inflammatory nature of the sexual abuse charges. The motion lists numerous documentaries, podcasts, and books as evidence of prejudicial media coverage that allegedly demonizes Maxwell and links her inextricably to Jeffrey Epstein's crimes.
An email chain from June 27, 2019, involving officials from the DOJ's Office of Professional Responsibility (OPR) and the U.S. Attorney's Office for the Southern District of New York (SDNY). The Chief of the SDNY Public Corruption Unit requests a copy of a 'non-public appendix' to the Epstein Non-Prosecution Agreement (NPA) containing a list of victims entitled to compensation. The Director of OPR responds, indicating that OPR can assist and referring the matter to the lead counsel on their investigation.
This document is a transcript of a deposition or interview with R. Alexander Acosta, conducted by the Office of Professional Responsibility (OPR) regarding the handling of the Jeffrey Epstein case by the U.S. Attorney's Office for the Southern District of Florida. The transcript covers discussions about the Non-Prosecution Agreement (NPA), victim notification issues, internal Department of Justice communications, and interactions with Epstein's defense team, including Ken Starr and Jay Lefkowitz. Acosta defends his office's decisions, emphasizing the goal of securing sex offender registration and restitution, while addressing criticisms regarding the perceived leniency and lack of transparency with victims.
This document details aspects of Jeffrey Epstein's non-prosecution agreement (NPA) in Florida, where he pleaded guilty to soliciting minors for prostitution and served 18 months in jail. The NPA included a controversial provision where the U.S. Attorney's Office agreed not to charge Epstein federally or his 'potential co-conspirators,' a point criticized by the OPR as 'poor judgment.' The document also discusses Ghislaine Maxwell's contention that the NPA bars her prosecution as Epstein's co-conspirator, a claim the Court rejects based on Second Circuit precedent and the scope of the NPA.
This document is a page from a DOJ OPR report detailing the timeline of events following the Miami Herald's 2018 reporting and Jeffrey Epstein's 2019 death. It covers the dismissal of the indictment against Epstein due to his suicide, the ongoing CVRA litigation by victims (specifically Jane Doe 1) in the 11th Circuit regarding the government's failure to confer with victims before the NPA, and the initiation of the OPR investigation requested by Senator Ben Sasse.
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