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This document is the cover page for a legal filing, specifically 'Appellant Ghislaine Maxwell's Motion for Pretrial Release', submitted to the U.S. Court of Appeals for the Second Circuit on April 1, 2021. The motion is part of an appeal from a case in the U.S. District Court for the Southern District of New York, in the matter of United States of America v. Ghislaine Maxwell. The filing was made by attorney David Oscar Markus of the Miami-based law firm MARKUS/MOSS PLLC.
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This document is a Notice of Appeal filed on March 24, 2021, in the U.S. District Court for the Southern District of New York on behalf of defendant Ghislaine Maxwell. The appeal challenges a court order from March 22, 2021, which denied her 'Third Motion for Release on Bail'. The document identifies Maxwell's attorney, David Oscar Markus, and the prosecuting Assistant U.S. Attorneys.
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This document is the signature page of a legal filing submitted on July 9, 2010, by the office of the United States Attorney. It lists Wifredo A. Ferrer as the U.S. Attorney and Dexter A. Lee, Eduardo I. Sánchez, and A. Marie Villafaña as Assistant U.S. Attorneys representing the respondent, providing their contact information and Florida Bar numbers.
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This legal document, dated March 31, 2008, is a motion for a protective order filed by the law firm Herman & Mermelstein, P.A. on behalf of 'Witness Y. Doe'. The motion requests that the court order the witness's deposition for an unspecified criminal case and the civil case 'Jane Doe No. 3 v. Jeffrey Epstein' to be conducted simultaneously. The stated purpose is to prevent potential harassment of the witness by the defendant, Jeffrey Epstein.
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This document is a letter dated March 31, 2008, from attorney Stuart S. Mermelstein to Judge Sandra McSorley regarding the case of 'State of Florida v. Jeffrey Epstein'. Mermelstein, representing an unnamed witness, requests a brief (15-minute) hearing to address a Motion for Protective Order. The letter indicates active legal proceedings and efforts to protect a witness involved in the case against Epstein.
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In a letter dated April 21, 2008, attorney Stuart S. Mermelstein informs attorney Jack A. Goldberger that his firm is representing a client identified as 'Jane Doe No. 5' in matters concerning the case *State of Florida v. Jeffrey E. Epstein*. Mermelstein requests that all future communication regarding his client be directed to his office and proposes scheduling a single deposition to be used for both the criminal and civil matters, subject to agreement and approval from the State Attorney's Office.
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This document is a fax transmittal sheet dated April 21, 2008, from attorney Stuart S. Mermelstein of Herman & Mermelstein, PA. The fax, consisting of two pages, was sent to Lanna Leigh Belohlavek at the State Attorney's Office and Jack A. Goldberger of the law firm Atterbury, Goldberger & Weiss, P.A. The subject of the fax is the legal case "State of Florida v. Jeffrey Epstein" and it states that correspondence is attached.
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This document is a flight log page (page 77) for aircraft N908JE (a Gulfstream II) covering the period from October 17, 2000, to November 19, 2000. It details 19 specific flights piloted by David Rodgers between various locations including Bangor, New York, Palm Beach, Miami, St. Thomas (USVI), London (Luton), Santa Fe, and California. The 'Remarks' column, which typically contains passenger names, is heavily redacted for all entries.
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This letter, dated January 18, 2008, is from attorney Jeffrey Herman of the law firm Herman & Mermelstein PA to Lanna Leigh Belohlavek at the State Attorney's Office. Herman formally notifies the State Attorney's Office that his firm has been retained to represent a client and his minor daughter in their legal claim against Jeffrey Epstein.
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This document details the tense negotiations between the USAO (Acosta) and Epstein's defense team (Starr, Lefkowitz, Dershowitz) in December 2007. Following defense submissions, the USAO initiated a de novo review of evidence by Criminal Chief Robert Senior and held a meeting in Miami on December 14, 2007, where the defense argued state charges did not apply. The defense subsequently threatened to seek review from DOJ Washington (AAG Fisher), prompting Acosta to request an expedited review to preserve a scheduled January 4th plea date.
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This document appears to be a page from a DOJ report (likely the OPR report) detailing the structure of Florida law enforcement and the background of U.S. Attorney R. Alexander Acosta. It outlines the roles of the Palm Beach State Attorney and Sheriff's Office, Acosta's professional history, and his direct involvement in negotiating Jeffrey Epstein's controversial Non-Prosecution Agreement (NPA) and subsequent state plea deal.
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Attorney Stuart S. Mermelstein of Herman & Mermelstein PA sends a letter via facsimile to Lanna Leigh Belohlavek at the State Attorney's Office regarding the case State of Florida v. Jeffrey Epstein. Mermelstein requests coordination for client depositions, arguing for a single deposition per client to be used in both the civil and criminal cases to protect the victims' emotional well-being. He notes that a deposition is scheduled for April 2, 2008, and urges a prompt response.
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This legal document, dated March 31, 2008, is a request for a protective order filed by the law firm Herman & Mermelstein on behalf of 'Witness Y. Doe'. The motion asks the court to require that depositions for a criminal case and a civil case, 'Jane Doe No. 3 v. Jeffrey Epstein', be conducted at the same time to prevent harassment of the witness by Defendant Epstein. The filing states that counsel for the State and for Epstein were contacted about this request but have not responded.
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This document is a legal certification and request signed by attorney Jack A. Goldberger on February 7, 2008. It requests the court deny a Motion for Protective Order as moot because the parties (Goldberger and Theodore Leopold) agreed to reschedule Jane Doe No. 1's deposition to February 20, 2008. The document certifies service to attorneys Lanna Belohlavek, Theodore Leopold, and Jeffrey Herman.
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Attorney Jeffrey Herman writes to Lanna Leigh Belohlavek of the State Attorney's Office on February 5, 2008, regarding the case against Jeffrey Epstein. Herman states that a subpoena for a deposition scheduled for the next day was improperly served, the intended deponent is unaware of it and will not appear. He also notes that as counsel for a party in a related civil claim, he was not notified by Epstein's counsel, Jack Goldberger, and requests to be included in future scheduling.
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This is a fax transmittal sheet dated February 5, 2008, from attorney Jeffrey Herman of the law firm Herman & Mermelstein PA. The 3-page fax was sent to Lanna Leigh Belolavek at the State Attorney's Office for the 15th Judicial Circuit and to attorney Jack Goldberger. The message indicates that the fax is a cover sheet for accompanying correspondence.
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This document is a signature page and Certificate of Service for a legal filing submitted by David Oscar Markus of Markus/Moss PLLC on April 1, 2021. It includes a citation for a separate case, 'United States v. Dashawn Robertson' (District of New Mexico), likely referenced as case law or an exhibit within the larger filing. The document bears a Department of Justice Bates stamp (DOJ-OGR-00019862).
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This document is the cover page for a legal filing titled 'Appellant Ghislaine Maxwell's Appendix to the Motion for Pretrial Release', dated April 1, 2021. The filing is part of an appeal (No. 21-770 & 21-58) in the United States Court of Appeals for the Second Circuit, originating from a case in the U.S. District Court for the Southern District of New York. The parties are the United States of America (Appellee) and Ghislaine Maxwell (Appellant), who is represented by attorney David Oscar Markus of MARKUS/MOSS PLLC.
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This document is the conclusion of a legal filing dated April 1, 2021, submitted by attorney David Oscar Markus on behalf of Ms. Maxwell. The filing argues that Maxwell is being unfairly detained under unacceptable conditions due to the "Epstein effect" and formally requests her release on bail or an evidentiary hearing.
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This document is a Notice of Appeal filed on March 24, 2021, on behalf of Ghislaine Maxwell in the case of United States v. Ghislaine Maxwell (20-CR-00330-AJN). The appeal is directed to the U.S. Court of Appeals for the Second Circuit and challenges the District Court's order from March 22, 2021, which denied her third motion for release on bail. The document lists Maxwell's counsel as David Oscar Markus and the Assistant U.S. Attorneys as Maurene Comey, Alison Moe, and Lara Pomerantz.
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This document is a page from a court transcript (Case 1:20-cr-00330-PAE) featuring the direct examination of a witness named Espinosa. The testimony focuses on Espinosa booking hotels for Ghislaine Maxwell in Miami during the 2000s, establishing that Maxwell did not always stay at Jeffrey Epstein's residence when in Florida. The testimony also identifies Ted Waitt as a man Maxwell dated and eventually became a couple with during that time period.
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This page from a DOJ OPR report details the controversy surrounding Jeffrey Epstein's placement on work release following his guilty plea. It highlights the disconnect between the USAO's expectation of 'continuous confinement' and the Palm Beach Sheriff's Office's decision to allow work release, as well as the legal maneuvering by Epstein's defense team (Lefkowitz) to secure this privilege. The document establishes that while the USAO threatened to investigate if Epstein received special treatment, State Attorney Krischer confirmed Epstein's technical eligibility for the program.
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This document page details the legal maneuvering in May 2008 regarding the federal investigation into Jeffrey Epstein. It describes how Epstein's lawyers (Starr and Whitley) petitioned the Deputy Attorney General to review the case, arguing that federal involvement was unwarranted and politically motivated due to Epstein's 'close ties' to former President Bill Clinton. The page also notes that the USAO, under instruction from the Deputy AG's office, postponed a June 2 deadline for Epstein's plea agreement to allow for this high-level review.
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This document details the professional background of AUSA Ann Marie C. Villafaña, focusing on her role as the lead prosecutor in the Jeffrey Epstein investigation starting in 2006. It clarifies that while Alexander Acosta made the decision to use a Non-Prosecution Agreement (NPA), Villafaña was the primary negotiator with Epstein's counsel and drafted the agreement. The text also outlines the timeline of the investigation, the subsequent CVRA litigation, and the eventual finding of government misconduct in 2019.
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This document, page 31 of a DOJ report (likely the OGR report), details the professional biographies and specific roles of USAO officials Jeffrey Sloman, Matthew Menchel, and Andrew Lourie in the Epstein investigation and the negotiation of the Non-Prosecution Agreement (NPA). It highlights Sloman's negotiation of an NPA addendum, Menchel's communication of the two-year plea deal, and Lourie's role in the NPA negotiations before his departure. The text also notes Alexander Acosta's resignation as Labor Secretary in 2019 due to criticism regarding the Epstein case.
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