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---
category: "Law Enforcement & Legal"
tags:
- Event
- FederalCase
- CrimeVictimsRightsAct
- JeffreyEpstein
- NonProsecutionAgreement
- SouthernDistrictOfFlorida
- EleventhCircuit
alias:
- In re Wild
- In re Courtney Wild
- In re Wild (en banc)
- Jane Doe 1 and Jane Doe 2 v. United States
- Does v. United States
- Doe v. United States (CVRA)
summary: "Crime Victims' Rights Act case filed in 2008 by Epstein victims over his secret non-prosecution agreement, which won a 2019 violation finding but no remedy, and failed 7-4 before the en banc Eleventh Circuit."
start: 2008-07-07
end: 2022-02-22
location: "West Palm Beach, Florida"
relations:
- type: participant_in
with: "[[Paul Cassell]]"
reverse: true
role: "petitioners' counsel"
start: 2008-07-28
fn: 2
- type: participant_in
with: "[[Jay Howell]]"
reverse: true
role: "petitioners' counsel"
start: 2008-08-08
fn: 2
- type: participant_in
with: "[[U.S. Attorney's Office for the Southern District of Florida]]"
reverse: true
role: "respondent's counsel"
start: 2008-07-09
fn: 2
- type: participant_in
with: "[[Jay Lefkowitz]]"
reverse: true
role: "proposed intervenor"
start: 2011-04-07
fn: 4
- type: participant_in
with: "[[Roy Black]]"
reverse: true
role: "proposed intervenor"
start: 2011-04-07
fn: 4
- type: participant_in
with: "[[Bruce Reinhart]]"
reverse: true
role: "proposed intervenor and movant for sanctions"
start: 2011-05-03
fn: 4
- type: participant_in
with: "[[Jeffrey Epstein]]"
reverse: true
role: "proposed limited intervenor"
start: 2011-09-02
fn: 4
- type: participant_in
with: "[[Kevin Newsom]]"
reverse: true
role: "author of the en banc majority opinion"
start: 2021-04-15
fn: 11
created: 2026-09-25
updated: 2026-09-25
---
Doe v. United States (No. 9:08-cv-80736-KAM) is the case opened in the [[United States District Court for the Southern District of Florida]] on July 7, 2008 by an emergency petition under the [[Crime Victims' Rights Act]], 18 U.S.C. 3771, filed for the victim of [[Jeffrey Epstein]] then known as Jane Doe 1, later identified as [[Courtney Wild]], and joined by Jane Doe 2. It ran before Judge [[Kenneth Marra]] for eleven years. In February 2019 Marra held that federal prosecutors had violated the Act by concealing the [[Epstein non-prosecution agreement]]; after Epstein's death he denied every remedy. Wild's mandamus petition, In re Wild (No. 19-13843), was denied by the en banc [[United States Court of Appeals for the Eleventh Circuit|Eleventh Circuit]] on April 15, 2021 by seven votes to four, and the [[Supreme Court of the United States|Supreme Court]] denied certiorari on February 22, 2022.[^1][^2][^3]
### The Petition
[[Bradley Edwards]] filed the petition a week after Epstein's June 30, 2008 state guilty plea. Marra ordered the [[U.S. Attorney's Office for the Southern District of Florida]] to respond by July 9. The government moved to file its response under seal, and its response, supported by a declaration of the line prosecutor, [[Ann Marie Villafana|A. Marie Villafaña]], was the first reference the petitioners saw to the agreement. Marra denied the sealing motion after a hearing on July 11. On July 28 [[Paul Cassell]], who had resigned as a federal judge in Utah the previous November, moved for a limited appearance for the petitioners, and on August 8 [[Jay Howell]] did the same. On August 21, 2008 Marra issued an order compelling production of the agreement under a protective order; on February 12, 2009 he denied the petitioners' motion to unseal it. Edwards litigated the case without fee for more than ten years.[^1][^2]
With the petitioners pursuing civil claims against Epstein, the case was administratively closed on September 8, 2010, and reopened on October 28, 2010 after an order to show cause for lack of prosecution. In March 2011 the petitioners moved for a finding of violations, for an order that the office not withhold evidence, and to use the plea correspondence between prosecutors and defense counsel as proof. On April 7, 2011 Epstein's lawyers [[Roy Black]], [[Martin Weinberg]] and [[Jay Lefkowitz]] moved to intervene in their own names; on May 3, 2011 the former prosecutor [[Bruce Reinhart]] moved to intervene and for sanctions; and on September 2, 2011 Epstein moved for limited intervention. On August 19, 2011 the government filed an opinion of the [[Department of Justice|Justice Department]]'s [[Office of Legal Counsel]].[^2][^4]
### Rulings
In 2011 Marra held that rights under the Act attach before the government files formal charges (Does v. United States, 817 F. Supp. 2d 1337), and in 2013 that the Act authorizes the rescission of a prosecutorial agreement, including a non-prosecution agreement, reached in violation of the conferral right (Doe v. United States, 950 F. Supp. 2d 1262). In December 2014 Edwards and Cassell moved to add a victim identified as Jane Doe 3, later publicly identified as [[Virginia Giuffre]], alleging that Epstein had trafficked her to [[Alan Dershowitz]] and others; Dershowitz denied it, and in April 2015 Marra struck the allegations as "immaterial and impertinent" without ruling on their truth. On February 10, 2016 the petitioners filed their consolidated statement of undisputed facts, with exhibits including the July 6, 2007 letter in which [[Gerald Lefcourt]] and Dershowitz cited the psychologist [[Steven Pinker]].[^1][^5][^6]
On February 21, 2019 Marra granted partial summary judgment (ECF No. 435, 359 F. Supp. 3d 1201). He wrote that "[p]articularly problematic was the Government's decision to conceal the existence of the NPA and mislead the victims to believe that federal prosecution was still a possibility," that "[w]hile the Government spent untold hours negotiating the terms and implications of the NPA with Epstein's attorneys, scant information was shared with victims," and that "[t]he Court is not ruling that the decision not to prosecute was improper." The Justice Department then recused the Southern District of Florida and assigned the [[U.S. Attorney's Office for the Northern District of Georgia]] to defend the case, and on February 6, 2019, after a December 2018 letter from Senator [[Ben Sasse]], the [[Office of Professional Responsibility]] had opened its review of the agreement, which it then expanded to cover the conduct on which Marra's findings rested.[^1][^7][^8]
Epstein was arrested in New York on July 6, 2019 and died in the [[Metropolitan Correctional Center, New York|Metropolitan Correctional Center]] on August 10. On September 16, 2019 Marra closed the case (ECF No. 478). He held the question whether the violation invalidated the agreement moot, denied rescission, sanctions, damages, a compelled meeting with former U.S. Attorney [[Alexander Acosta]] ("The Court has no jurisdiction over Alexander Acosta, the former U.S. Attorney, who is now a private citizen") and grand jury and internal documents, and refused attorney's fees because, "[a]lthough unsuccessful on the merits of the issue of whether there was a violation of the CVRA, the Government asserted legitimate and legally supportable positions throughout this litigation." He wrote that "despite Petitioners having demonstrated the Government violated their rights under the CVRA, in the end they are not receiving much, if any, of the relief they sought," and that the rulings "likely played some role, however small it may have been, in the initiation of criminal charges against Mr. Epstein in the [[U.S. Attorney's Office for the Southern District of New York|Southern District of New York]] and that office's continuing investigation of others who may have been complicit with him."[^9][^10]
### In re Wild
Wild petitioned the Eleventh Circuit for mandamus in her own name. The government argued in its brief that "as a matter of law, the legal obligations under the CVRA do not attach prior to the government charging a case," while conceding at oral argument that the office had "made a mistake in causing her to believe that the case was ongoing when in fact the NPA had been signed." A divided panel denied the petition on April 14, 2020, holding that the rights do not attach before charges, and the full court vacated that decision and granted rehearing en banc on August 7, 2020.[^8]
On April 15, 2021 the en banc court (994 F.3d 1244) denied the petition. Judge [[Kevin Newsom]], writing for Chief Judge [[William Pryor]] and Judges Wilson, Lagoa, Brasher and [[Gerald Tjoflat|Tjoflat]], and in part Luck, wrote: "We have the profoundest sympathy for Ms. Wild and others like her, who suffered unspeakable horror at Epstein's hands, only to be left in the dark," and, "so it seems, affirmatively misled," by government attorneys: "Even so, we find ourselves constrained to deny Ms. Wild's petition." The Act permits a victim to move for relief within a preexisting proceeding, but "it does not authorize a victim to seek judicial enforcement of her CVRA rights in a freestanding civil action"; the majority stated that "we needn't decide whether, in the abstract, the rights to confer and to be treated with fairness might attach prior to the formal commencement of criminal proceedings." In a separate concurrence Newsom wrote that the prosecutors had, "by their own admission," affirmatively misled Wild and dozens of others: "Shameful all the way around. The whole thing makes me sick." Judge Elizabeth Branch, joined by Judges Martin, Jill Pryor and Hull, dissented, and Judge [[Frank Hull]] wrote separately: "Good gracious, there's nothing abstract about this case," and "[o]nce the ink was dry on the Agreement, the U.S. Attorney had exercised his discretion and made his charging decision."[^3][^11]
The Supreme Court denied certiorari on February 22, 2022 (No. 21-351), the Solicitor General opposing review. Wild wrote after the denial: "The government intentionally misled the victims but found a way to get away with it by working with a child molester to get around the law. And the Judges ruled in their favor. How?" Representatives [[Jackie Speier]], [[Scott Perry]], [[Lois Frankel]] and [[Mo Brooks]] had introduced the Courtney Wild Crime Victims' Rights Reform Act of 2019 (H.R. 4729) to extend the conferral and notice rights to the pre-charge period; it was not enacted, nor were its successors in 2022 and later.[^3][^12]
### The Epstein Side
On February 25, 2018, while the case was pending, Epstein wrote to [[Kathryn Ruemmler]], the former [[White House]] Counsel, about a newly discovered "email trail" involving [[Scott Rothstein]]'s prosecutors and lawyer: "now the issue is how to use, it, CVRA? marie? Bar. USA[?]. scoff rothsteins prosecutors that w[i]thdrew his r[ule] 35 [ ] filing. nurik, rothsteins lawyer on some of t[h]e emails. Judge marra, cvra.? press? move f[o]r sanctions? strategy time." Ruemmler replied at 2:12 a.m. on February 26: "How did you discover it? Let's discuss in the a.m."[^13]
### Footnotes
[^1]: Opinion and Order, *Jane Doe 1 and Jane Doe 2 v. United States*, No. 9:08-cv-80736-KAM (S.D. Fla. Feb. 21, 2019), ECF No. 435 (Marra, J.), reported at 359 F. Supp. 3d 1201, at 2-3, 12-21, 26-33, citing *Does v. United States*, 817 F. Supp. 2d 1337 (S.D. Fla. 2011), and *Doe v. United States*, 950 F. Supp. 2d 1262 (S.D. Fla. 2013). https://storage.courtlistener.com/recap/gov.uscourts.flsd.317867/gov.uscourts.flsd.317867.435.0.pdf
[^2]: Docket, *Doe v. United States*, No. 9:08-cv-80736-KAM (S.D. Fla.), ECF Nos. 1, 3, 11-14, 16, 18, 20, 21, 26, 28, 36, 38, 40, 44, CourtListener docket 4502088. https://www.courtlistener.com/docket/4502088/doe-v-united-states/
[^3]: *In re Wild*, No. 19-13843, 994 F.3d 1244 (11th Cir. Apr. 15, 2021) (en banc), opinion of Newsom, J., at 2-3, 13; Branch, J., dissenting; Hull, J., dissenting, at 156, 158. https://media.ca11.uscourts.gov/opinions/pub/files/201913843.enb.pdf ; Supreme Court of the United States, docket No. 21-351, order of February 22, 2022 denying certiorari. https://www.supremecourt.gov/search.aspx?filename=/docket/docketfiles/html/public/21-351.html
[^4]: Docket, *Doe v. United States*, No. 9:08-cv-80736-KAM (S.D. Fla.), ECF Nos. 46-51, 55, 56, 68, 70, 79, 80, 83, 89, 90, 93, 94 (March to September 2011), CourtListener. https://www.courtlistener.com/docket/4502088/doe-v-united-states/
[^5]: "Lawyers Call Sexual Misconduct Case Against Dershowitz 'A Mistake,'" *The Harvard Crimson,* April 11, 2016. https://www.thecrimson.com/article/2016/4/11/lawyers-drop-dershowitz-case/
[^6]: Letter from Gerald B. Lefcourt and Alan M. Dershowitz to Jeffrey Sloman, Matthew Menchel, Andrew Lourie and A. Marie Villafaña, July 6, 2007, filed as Exhibit 46 to Jane Doe 1 and Jane Doe 2's Consolidated Statement of Undisputed Material Facts and Motion for Partial Summary Judgment, ECF No. 361-46 (entered February 10, 2016). https://storage.courtlistener.com/recap/gov.uscourts.flsd.317867/gov.uscourts.flsd.317867.361.46.pdf
[^7]: Opinion and Order, *Jane Doe 1 and Jane Doe 2 v. United States*, ECF No. 435 (note 1), quoting ECF No. 407 at paragraphs 33, 37, 52, 61, 63, 83, 90; U.S. Department of Justice, Office of Professional Responsibility, "Investigation into the U.S. Attorney's Office for the Southern District of Florida's Resolution of Its 2006-2008 Federal Criminal Investigation of Jeffrey Epstein," November 2020. https://www.justice.gov/opr/page/file/1336471/dl
[^8]: U.S. Department of Justice, Office of Professional Responsibility, Executive Summary of the November 2020 report, pp. v-vii. https://www.justice.gov/opr/page/file/1336471/dl ; the same report as filed in CA Florida Holdings, LLC v. Aronberg: U.S. Department of Justice, Epstein Library, EFTA02733081, Court Records (CA Florida Holdings, LLC, Publisher of the Palm Beach Post v. Aronberg, No. 50-2019-CA-014681-XXXX-MB (Fla. 15th Cir. Ct. 2019)), appendix Exhibit 3. https://www.justice.gov/epstein/files/Court%20Records/CA%20Florida%20Holdings%2C%20LLC%2C%20Publisher%20of%20the%20Palm%20Beach%20Post%20v.%20Aronberg%2C%20No.%2050-2019-CA-014681-XXXX-MB%20(Fla.%2015th%20Cir.%20Ct.%202019)/EFTA02733081.pdf
[^9]: Opinion and Order, *Doe v. United States*, No. 9:08-cv-80736-KAM (S.D. Fla. Sept. 16, 2019), ECF No. 478 (Marra, J.). https://www.govinfo.gov/content/pkg/USCOURTS-flsd-9_08-cv-80736/pdf/USCOURTS-flsd-9_08-cv-80736-2.pdf
[^10]: U.S. Department of Justice, Office of the Inspector General, *Investigation and Review of the Federal Bureau of Prisons' Custody, Care, and Supervision of Jeffrey Epstein at the Metropolitan Correctional Center in New York, New York,* Report 23-085, June 2023, pp. iii to iv. https://oig.justice.gov/sites/default/files/reports/23-085.pdf
[^11]: *In re Wild*, No. 19-13843 (11th Cir. Apr. 15, 2021) (en banc), Newsom, J., concurring. https://media.ca11.uscourts.gov/opinions/pub/files/201913843.enb.pdf
[^12]: "Supreme Court Turns Away Jeffrey Epstein Victim's Petition on Dead Predator's Infamous Non-Prosecution Agreement," *Law & Crime,* February 22, 2022. https://lawandcrime.com/jeffrey-epstein-2/supreme-court-turns-away-jeffrey-epstein-victims-petition-on-dead-predators-infamous-non-prosecution-agreement/ ; H.R. 4729, 116th Congress. https://www.congress.gov/bill/116th-congress/house-bill/4729/text ; H.R. 9444, 117th Congress. https://www.congress.gov/bill/117th-congress/house-bill/9444
[^13]: U.S. Department of Justice, Epstein Library, EFTA02522534, DataSet 11, email chain, Jeffrey Epstein and Kathy Ruemmler, "Re: this email trail was discovered today," February 25 to 26, 2018 (duplicate at EFTA02522094). https://www.justice.gov/epstein/files/DataSet%2011/EFTA02522534.pdf

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### The Terms
The agreement required Epstein to plead guilty in state court to the pending solicitation indictment and to a new information charging procurement of minors for prostitution under Florida Statute 796.03, an offense requiring sex offender registration, and to make a binding joint recommendation of 18 months in county jail followed by 12 months of community control. In exchange the office agreed not to prosecute him in the Southern District of Florida.[^2]
The agreement required Epstein to plead guilty in state court to the pending solicitation indictment and to a new information charging procurement of minors for prostitution under Florida Statute 796.03, an offense requiring sex offender registration, and to make a binding joint recommendation of 18 months in county jail followed by 12 months of community control. In exchange the office agreed not to prosecute him in the [[U.S. Attorney's Office for the Southern District of Florida|Southern District of Florida]].[^2]
The immunity clause read: "the United States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to [[Sarah Kellen]], [[Adriana Ross]], [[Lesley Groff]], or [[Nadia Marcinkova]]." A confidentiality clause provided that "[t]he parties anticipate that this agreement will not be made part of any public record," and that if the government received a [[Freedom of Information Act]] request or compulsory process for the agreement, "it will provide notice to Epstein before making that disclosure."[^1]

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---
category: "Law Enforcement & Legal"
tags:
- Event
- FederalCase
- JeffreyEpstein
- JPMorganChase
- VirginIslands
- JesStaley
- ProjectJeep
- SouthernDistrictOfNewYork
alias:
- Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A.
- USVI v. JPMorgan
- USVI v. JPMorgan Chase
- Virgin Islands v. JPMorgan
- Government of the U.S. Virgin Islands v. JPMorgan Chase Bank
summary: "The Virgin Islands' 2022 federal suit accusing JPMorgan of facilitating Jeffrey Epstein's trafficking, heard by Judge Jed Rakoff with two victims' bank suits and settled in 2023 for 75 million dollars."
start: 2022-12-27
end: 2023-10-18
location: "New York, New York"
relations:
- type: participant_in
with: "[[Government of the United States Virgin Islands]]"
reverse: true
role: "plaintiff"
start: 2022-12-27
end: 2023-10-18
fn: 1
- type: participant_in
with: "[[JPMorgan Chase]]"
reverse: true
role: "defendant and third-party plaintiff"
start: 2022-12-27
end: 2023-10-18
fn: 1
- type: participant_in
with: "[[Jed Rakoff]]"
reverse: true
role: "presiding judge"
start: 2022-12-27
fn: 1
- type: participant_in
with: "[[Jes Staley]]"
reverse: true
role: "third-party defendant"
start: 2023-03-08
end: 2023-10-18
fn: 1
- type: participant_in
with: "[[Motley Rice]]"
reverse: true
role: "counsel for the Virgin Islands"
start: 2022-12-27
end: 2023-10-18
fn: 4
- type: participant_in
with: "[[WilmerHale]]"
reverse: true
role: "counsel for JPMorgan"
fn: 7
- type: participant_in
with: "[[Denise George]]"
reverse: true
role: "Attorney General who filed the suit"
start: 2022-12-27
end: 2022-12-31
fn: 2
- type: participant_in
with: "[[Carol Thomas-Jacobs]]"
reverse: true
role: "counsel for the Virgin Islands; Acting Attorney General"
start: 2022-12-30
fn: 1
created: 2026-09-25
updated: 2026-09-25
---
Government of the [[U.S. Virgin Islands|United States Virgin Islands]] v. JPMorgan Chase Bank, N.A. (No. 1:22-cv-10904-JSR) was a suit filed on December 27, 2022 in the [[U.S. District Court for the Southern District of New York]] by the [[Government of the United States Virgin Islands]], which alleged that [[JPMorgan Chase]] had knowingly facilitated and profited from [[Jeffrey Epstein]]'s sex trafficking while keeping him as a private bank client from 1998 to 2013. Attorney General [[Denise George]] filed it; Governor [[Albert Bryan]] removed her four days later. Judge [[Jed Rakoff]] consolidated it for pretrial purposes with two suits by a victim against JPMorgan and [[Deutsche Bank]], and JPMorgan brought a third-party claim against its former executive [[Jes Staley]]. The bank settled with the territory in September 2023 for 75 million dollars, 20 million of which went to the territory's outside counsel, [[Motley Rice]].[^1][^2][^3][^4]
### Filing and the Removal of the Attorney General
The complaint (ECF No. 1) invoked federal question jurisdiction and demanded a jury; its first amended version attached, as Exhibit 1, the Second Amended Complaint in the territory's separate Superior Court suit against Epstein's estate and co-executors, [[Darren Indyke]] and [[Richard Kahn]], which had settled on November 30, 2022 for 105 million dollars in cash and other terms. George had brought that estate case in January 2020. Bryan removed George on December 31, 2022. His office gave no reason and said reports tying the removal to the JPMorgan suit were "not entirely accurate." [[Carol Thomas-Jacobs]], who had moved for admission pro hac vice in the case on December 30, became Acting Attorney General effective January 1, 2023, and on January 20, 2023 signed the territory's 62.5 million dollar settlement with the financier [[Leon Black]]. The territory's lawyers of record included [[Linda Singer]] and Elizabeth Paige Boggs of Motley Rice.[^1][^2][^5]
George told the [[Federal Bureau of Investigation]] in an October 2023 interview, according to agents' notes released in January 2026, that Bryan had asked her in 2019 to waive the territory's 21-day travel-notice rule for Epstein, had told her after Epstein's death, "He's dead go for it," and had later pressed her to settle with the estate for 80 million dollars through a mediator of his choosing. Bryan has said Epstein received no special privilege from his administration.[^6]
### Consolidation and Rulings
On December 29, 2022 Rakoff consolidated the case "for all pretrial purposes" with Doe v. Deutsche Bank Aktiengesellschaft (22-cv-10018) and Doe v. JP Morgan Chase & Co. (22-cv-10019), suits brought by pseudonymous victims, under a single case management plan. On March 8, 2023 JPMorgan filed a third-party complaint against its former executive James Edward Staley, seeking to shift liability for his relationship with Epstein. On March 20, 2023 Rakoff issued a single "bottom-line" order granting in part and denying in part the motions to dismiss in all three cases (ECF No. 90), explained in an opinion of May 1 (ECF No. 130). On April 10 he refused to sever Staley's claims, and on May 2 he admitted [[Paul Cassell]] pro hac vice in the Jane Doe case against JPMorgan. On August 18, 2023 he denied Staley's motion to dismiss "in its entirety" (ECF No. 293).[^1]
### Discovery and Project Jeep
In February 2023 Motley Rice sought to subpoena [[Leslie Wexner]]; his Columbus lawyers would not accept service, and the territory moved on February 17 for leave to serve him by certified mail. JPMorgan's chief executive, [[Jamie Dimon]], was deposed on May 26, 2023; examining him for the territory, Singer objected on the record to "counsel coaching the witness on answers," and Dimon testified that the bank "did not need introductions to anybody."[^7][^8]
On May 28, 2023, near the close of discovery, JPMorgan produced a 22-page summary from an internal review, code-named "Project Jeep," begun after Epstein's 2019 arrest. It stated that "Jes Staley appears to have a close relationship with Jeffrey Epstein, regularly communicating with him and seeking advice from him including while Epstein is incarcerated," and that Epstein "appears to maintain a particularly close relationship with [[Prince Andrew]] the [Duke] of York and Lord Peter Mandelson, a senior member of the British Government," and "a close relationship with [[Sultan Ahmed bin Sulayem|Sultan Ahmed Bin Sulayem]]." On June 7, 2023 Motley Rice asked Rakoff to reopen depositions, citing the summary's "more than four pages of Epstein referrals to JPMorgan," including [[Andrew Farkas]], [[Boris Nikolic]], [[Bill Gates]] and [[Peter Mandelson]]; emails showing that the former [[Bear Stearns]] chairman [[Alan Greenberg]] had gone to general counsel [[Stephen Cutler]] "for an exception to the felony policy" for Epstein; and a 2008 email stating that "JPM requires top of the house ok for clients who are convicted felons. (ie PCS Legal to Asset Mgt Legal to Cutler to Jaime Daimnon [sic])." [[WilmerHale]], for JPMorgan, answered on June 9 that "top of the house" meant Cutler, that Dimon did not recognize the name "Project Jeep," and that there was "no evidence that Mr. Greenberg had anything to do with Epstein's accounts at the Private Bank." In August 2023 Rakoff ordered production of records concerning newly identified women Epstein had paid, but denied the request "to compel production of all documents and information concerning 'Project Jeep' or other investigations by JPMorgan that occurred after Epstein's 2019 arrest."[^7][^9]
On July 24, 2023 the territory filed its statement of material facts (ECF No. 221), which recorded that in March 2011 the investment bank's general counsel had reported to Cutler a conversation with [[Jay Lefkowitz]], who "represented Epstein in state plea/fed NPA process" and believed "any pre-plea conduct is subsumed within plea/NPA." A June 2023 expert report for the territory, filed as ECF No. 238-31, found that Epstein held "at least 134 accounts" at the bank and cited among its sources Judge [[Richard M. Berman]]'s August 27, 2019 hearing in [[United States v. Epstein]].[^10][^11]
### Settlement
On September 26, 2023, with summary judgment motions pending, JPMorgan agreed to pay the territory 75 million dollars without admitting wrongdoing: 30 million dollars to organizations combating human trafficking, 25 million dollars to strengthen the territory's law enforcement, and 20 million dollars in attorneys' fees. JPMorgan had agreed in June to pay 290 million dollars to settle the Jane Doe class, which Rakoff approved in November. The territory dismissed its claims with prejudice on October 2, 2023 (ECF No. 344, after a deficient filing on September 29), JPMorgan dismissed its claims against Staley on October 6 (ECF No. 345), and Rakoff closed the case on October 18, 2023 (ECF No. 348). On November 22, 2023 he ordered JPMorgan and Deutsche Bank to pay the [[Epstein Victims' Compensation Program]] 563,365.51 dollars and 187,788.50 dollars respectively for its costs of complying with their subpoenas. The territory received about 180 million dollars from its Epstein settlements after Motley Rice's fees and, as of January 2026, had not filed the accounting of the money that a 2024 territorial law requires.[^3][^4][^6][^12]
### After Termination
On April 4, 2024 six women identified as Jane Doe 1 through Jane Doe 6 moved to intervene and for disclosure of sealed filings for use in a related case, Doe v. USVI (23-cv-10301); the territory opposed, and Rakoff denied the motion on June 28, 2024 (ECF No. 366). On a motion by [[The New York Times]], he unsealed part of the summary judgment record on July 30, 2024 (ECF No. 367), and on October 24, 2025, on motions by the Times and [[The Wall Street Journal]], he ordered further exhibits unsealed, subject to redactions to protect victims' identities, which the parties filed on the public docket on October 31, 2025 (ECF Nos. 381-384). The November 2020 report of the [[Department of Justice|Justice Department]]'s [[Office of Professional Responsibility]] on the Florida [[Epstein non-prosecution agreement|non-prosecution agreement]] was also filed as an exhibit in the case.[^1][^13]
### Footnotes
[^1]: Docket, Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 1:22-cv-10904-JSR (S.D.N.Y.), ECF Nos. 1, 5, 6, 7, 17, 70, 90, 117, 120, 130, 131, 293, 343-348, 351, 358-369, 381-384, CourtListener docket 66683865. https://www.courtlistener.com/docket/66683865/government-of-the-united-states-virgin-islands-v-jpmorgan-chase-bank-na/
[^2]: "U.S. Virgin Islands fires attorney general in Jeffrey Epstein cases," *PBS NewsHour / Associated Press,* January 2023. https://www.pbs.org/newshour/nation/u-s-virgin-islands-fires-attorney-general-in-jeffrey-epstein-cases ; "Attorney General Denise George Has Been Terminated," *The Virgin Islands Consortium,* December 31, 2022. https://viconsortium.com/vi-government/virgin-islands-attorneygeneral-denise-george-has-been-terminated-
[^3]: "JPMorgan Chase settles Jeffrey Epstein sex trafficking suit by U.S. Virgin Islands for $75 million," *CNBC,* September 26, 2023. https://www.cnbc.com/2023/09/26/jpmorgan-to-settle-jeffrey-epstein-suit-by-virgin-islands.html
[^4]: Carlson, Suzanne. "Court filings show V.I. First Lady's loyalty to Epstein." *Virgin Islands Daily News,* June 21, 2023. https://www.virginislandsdailynews.com/news/court-filings-show-v-i-first-ladys-loyalty-to-epstein/article_c2dca0a7-a243-5365-88c0-389c576ad022.html ; "U.S. Virgin Islands Attorney General Settles Sex Trafficking Case Against Estate Of Jeffrey Epstein And Co-Defendants For Over $105 Million," *U.S. Virgin Islands Department of Justice,* December 1, 2022. https://usvidoj.com/u-s-virgin-islands-attorney-general-settles-sex-trafficking-case-against-estate-of-jeffrey-epstein-and-co-defendants-for-over-105-million/
[^5]: Settlement Agreement and Release between the Government of the United States Virgin Islands and Leon Black, executed January 20, 2023 (as published by the U.S. Senate Committee on Finance). https://www.finance.senate.gov/imo/media/doc/usvi_black_settlement_agreement_-_executedpdf.pdf ; Government of the United States Virgin Islands v. Darren K. Indyke et al., No. ST-20-CV-14 (V.I. Super. Ct.), Second Amended Complaint, reproduced as ECF No. 1-1 in No. 1:22-cv-10904-JSR. https://web.archive.org/web/20260117011558/https://www.justice.gov/multimedia/Court%20Records/Government%20of%20the%20United%20States%20Virgin%20Islands%20v.%20JPMorgan%20Chase%20Bank,%20N.A.,%20No.%20122-cv-10904%20(S.D.N.Y.%202022)/001-01.pdf
[^6]: Carlson, Suzanne. "Docs confirm Bryan pressed for special treatment of sex offender." *Virgin Islands Daily News,* February 2, 2026, reporting four pages of FBI notes of an October 2, 2023 interview with Denise George released January 30, 2026. https://www.virginislandsdailynews.com/news/docs-confirm-bryan-pressed-for-special-treatment-of-sex-offender/article_5e9483c9-38d2-406c-8bb0-e5757ce287f2.html
[^7]: Deposition of James Dimon, May 26, 2023, Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 1:22-cv-10904-JSR (S.D.N.Y.). https://assets.bwbx.io/documents/users/iqjWHBFdfxIU/rQOuhi8KqiM0/v0 ; U.S. Department of Justice, Epstein Library, EFTA02808625, Court Records (Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 1:22-cv-10904), letter of John J. Butts, WilmerHale, ECF No. 187, June 9, 2023. https://www.justice.gov/epstein/files/Court%20Records/Government%20of%20the%20United%20States%20Virgin%20Islands%20v.%20JPMorgan%20Chase%20Bank%2C%20N.A.%2C%20No.%20122-cv-10904%20(S.D.N.Y.%202022)/EFTA02808625.pdf
[^8]: U.S. Department of Justice, Epstein Library, EFTA02806221, Court Records (Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 1:22-cv-10904), Declaration in support of motion for alternative service of subpoena upon Leslie Wexner, ECF No. 50-4, February 17, 2023. https://www.justice.gov/epstein/files/Court%20Records/Government%20of%20the%20United%20States%20Virgin%20Islands%20v.%20JPMorgan%20Chase%20Bank%2C%20N.A.%2C%20No.%20122-cv-10904%20(S.D.N.Y.%202022)/EFTA02806221.pdf
[^9]: U.S. Department of Justice, Epstein Library, EFTA02808715, Court Records (Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 1:22-cv-10904), letter motion of Motley Rice to Judge Jed S. Rakoff seeking leave to reopen depositions, ECF No. 191, June 7, 2023, pp. 3-5. https://www.justice.gov/epstein/files/Court%20Records/Government%20of%20the%20United%20States%20Virgin%20Islands%20v.%20JPMorgan%20Chase%20Bank%2C%20N.A.%2C%20No.%20122-cv-10904%20(S.D.N.Y.%202022)/EFTA02808715.pdf ; U.S. Department of Justice, Epstein Library, EFTA02814941, Court Records (same case), Order of Judge Jed S. Rakoff on Dkt. 212, August 2023. https://www.justice.gov/epstein/files/Court%20Records/Government%20of%20the%20United%20States%20Virgin%20Islands%20v.%20JPMorgan%20Chase%20Bank%2C%20N.A.%2C%20No.%20122-cv-10904%20(S.D.N.Y.%202022)/EFTA02814941.pdf
[^10]: Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 1:22-cv-10904-JSR (S.D.N.Y.), Plaintiff's Statement of Material Facts, ECF No. 221 (filed July 24, 2023), paras. 123-124, 374. https://storage.courtlistener.com/recap/gov.uscourts.nysd.591653/gov.uscourts.nysd.591653.221.0.pdf
[^11]: U.S. Department of Justice, Epstein Library, EFTA02810827, Court Records (Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 1:22-cv-10904), Expert Report of Jorge Amador, Asia Advisors, LLC, June 16, 2023, Document 238-31, n. 53. https://www.justice.gov/epstein/files/Court%20Records/Government%20of%20the%20United%20States%20Virgin%20Islands%20v.%20JPMorgan%20Chase%20Bank%2C%20N.A.%2C%20No.%20122-cv-10904%20(S.D.N.Y.%202022)/EFTA02810827.pdf
[^12]: "JPMorgan Chase and Epstein survivor Jane Doe 1 reach $290 million settlement," *NPR,* June 12, 2023. https://www.npr.org/2023/06/12/1181675580/epstein-jane-doe-1-290-million-settlement-jpmorgan-chase ; "JPMorgan's $290 million settlement with Epstein accusers wins approval by U.S. judge," *CNBC / Reuters,* November 9, 2023. https://www.cnbc.com/2023/11/09/jpmorgans-290-million-settlement-with-epstein-accusers-wins-approval-by-us-judge.html
[^13]: U.S. Department of Justice, Epstein Library, EFTA02809635, Court Records (Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 1:22-cv-10904), Office of Professional Responsibility report of November 2020 as filed in the case. https://www.justice.gov/epstein/files/Court%20Records/Government%20of%20the%20United%20States%20Virgin%20Islands%20v.%20JPMorgan%20Chase%20Bank%2C%20N.A.%2C%20No.%20122-cv-10904%20(S.D.N.Y.%202022)/EFTA02809635.pdf

4
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@ -12,7 +12,7 @@ tags:
- Iran
- Israel
- USCustoms
summary: "The Hashemi Sting was a 1986 U.S. Customs undercover operation targeting illegal arms sales to Iran, prosecuted by U.S. Attorney Rudolph Giuliani's Southern District of New York office, which resulted in indictments of arms dealers including former Israeli general Avraham Bar-Am; it intersected directly with the Iran-Contra network and the October Surprise investigations, and its key informant Cyrus Hashemi died in London under disputed circumstances shortly after the sting concluded."
summary: "The Hashemi Sting was a 1986 U.S. Customs undercover operation against arms sales to Iran, prosecuted by Rudolph Giuliani's Southern District of New York office; its informant Cyrus Hashemi died in London that year."
created: 2026-05-15
updated: 2026-05-17
start: 1985-01-01
@ -20,7 +20,7 @@ end: 1986-12-31
location: "New York"
---
The Hashemi Sting was a joint U.S. Customs Service and FBI undercover operation conducted in 1985-1986 targeting illegal arms trafficking to [[Iran]], an operation that became entangled with the parallel [[Iran-Contra Affair]] and the [[October Surprise]] network through its principal informant, Iranian-American arms dealer Cyrus Hashemi. The operation resulted in indictments prosecuted by then-U.S. Attorney for the Southern District of New York [[Rudolph Giuliani]], and its aftermath raised serious questions about the relationship between legitimate law enforcement, intelligence operations, and the covert arms pipeline to Iran authorized at the highest levels of the [[Ronald Reagan|Reagan]] administration.[^1]
The Hashemi Sting was a joint U.S. Customs Service and FBI undercover operation conducted in 1985-1986 targeting illegal arms trafficking to [[Iran]], an operation that became entangled with the parallel [[Iran-Contra Affair]] and the [[October Surprise]] network through its principal informant, Iranian-American arms dealer Cyrus Hashemi. The operation resulted in indictments prosecuted by then-U.S. Attorney for the [[U.S. Attorney's Office for the Southern District of New York|Southern District of New York]] [[Rudolph Giuliani]], and its aftermath raised serious questions about the relationship between legitimate law enforcement, intelligence operations, and the covert arms pipeline to Iran authorized at the highest levels of the [[Ronald Reagan|Reagan]] administration.[^1]
### Cyrus Hashemi

4
40 - EVENTS/INTELLIGENCE_SCANDALS/PROMIS Software Scandal.md
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@ -15,7 +15,7 @@ tags:
- DoJ
- Software
- OctoberSurprise
summary: "The INSLAW Affair was a protracted legal and political scandal arising from allegations that the U.S. Department of Justice stole the PROMIS case management software from its developer, drove the company into bankruptcy, and distributed the software internationally, with intelligence agencies reportedly embedding a surveillance backdoor."
summary: "The INSLAW Affair was a legal and political scandal over allegations that the U.S. Department of Justice stole the PROMIS case management software from its developer and distributed it internationally with a surveillance backdoor."
start: 1982-03-01
end: 1998-08-31
location: "Washington, D.C."
@ -42,7 +42,7 @@ Bason's non-reappointment in 1988, when his four-year term expired after he soug
The Senate Permanent Subcommittee on Investigations (PSI) examined the INSLAW matter in 1989 and found "no proof" that [[Lowell Jensen]] and [[Edwin Meese]] had conspired to ruin INSLAW or steal its product, and "no proof of any connection between [[Earl Brian]] or [[Hadron]] and the Department with regard to the INSLAW contract." The Senate report did find, however, that DOJ official Thomas Stanton had "improperly tried to get special handling for Inslaw's bankruptcy" and criticized the Department for placing Brewer, a former INSLAW employee, in charge of the implementation contract.[^3]
The [[House Committee on the Judiciary|House Judiciary Committee]], chaired by Representative [[Jack Brooks]], conducted a three-year investigation from 1989 to 1992. Its September 10, 1992 report (House Report 102-857) reached substantially more damaging conclusions. The committee found "strong evidence...that the Department of Justice 'acted willfully and fraudulently,' and 'took, converted and stole,' Inslaw's Enhanced PROMIS by 'trickery fraud and deceit.'"[^1] The report cited an admission from Deputy Attorney General [[Arnold Burns]], who told DOJ Office of Professional Responsibility investigators in 1986 that INSLAW's proprietary rights claim was "legitimate" and that the government "would probably lose the case in court on this issue" - yet DOJ continued litigating against INSLAW.[^1]
The [[House Committee on the Judiciary|House Judiciary Committee]], chaired by Representative [[Jack Brooks]], conducted a three-year investigation from 1989 to 1992. Its September 10, 1992 report (House Report 102-857) reached substantially more damaging conclusions. The committee found "strong evidence...that the Department of Justice 'acted willfully and fraudulently,' and 'took, converted and stole,' Inslaw's Enhanced PROMIS by 'trickery fraud and deceit.'"[^1] The report cited an admission from Deputy Attorney General [[Arnold Burns]], who told [[Office of Professional Responsibility|DOJ Office of Professional Responsibility]] investigators in 1986 that INSLAW's proprietary rights claim was "legitimate" and that the government "would probably lose the case in court on this issue" - yet DOJ continued litigating against INSLAW.[^1]
The House Committee specifically examined the roles of Lowell Jensen and Edwin Meese in the affair. Jensen had developed DALITE (District Attorney's Automated Legal Information System), a competing case management software, while serving as Alameda County District Attorney; he was a member of the contract oversight committee at INSLAW's inception and later became Associate Attorney General and then Deputy Attorney General under Meese. The Committee found it "incredible that the Department, having made this determination [that INSLAW's proprietary rights claim was legitimate], would continue to pursue its litigation."[^1] Meese had served alongside Earl Brian in Governor [[Ronald Reagan|Reagan's]] California cabinet; Meese's wife purchased stock in a Brian-controlled company; Meese reportedly recused himself from PROMIS matters upon becoming Attorney General in February 1985, leaving Jensen to handle the issue.[^4]

109
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@ -0,0 +1,109 @@
---
category: "Law Enforcement & Legal"
tags:
- Event
- FederalCase
- CriminalCase
- GhislaineMaxwell
- JeffreyEpstein
- SexTrafficking
- SouthernDistrictOfNewYork
- EpsteinFilesTransparencyAct
alias:
- US v. Maxwell
- U.S. v. Maxwell
- United States v. Ghislaine Maxwell
- United States v. Maxwell (2020)
- Maxwell v. United States
summary: "Federal sex-trafficking prosecution of Ghislaine Maxwell in the Southern District of New York, ending in a 2021 conviction and 20-year sentence, whose grand jury record was unsealed under the Epstein Files Transparency Act."
start: 2020-06-29
location: "New York, New York"
relations:
- type: participant_in
with: "[[Ghislaine Maxwell]]"
reverse: true
role: "defendant"
start: 2020-06-29
fn: 1
- type: participant_in
with: "[[U.S. Attorney's Office for the Southern District of New York]]"
reverse: true
role: "prosecutor"
start: 2020-06-29
fn: 1
- type: participant_in
with: "[[Alison Nathan]]"
reverse: true
role: "presiding judge"
start: 2020-06-29
end: 2022-06-29
fn: 1
- type: participant_in
with: "[[Paul Engelmayer]]"
reverse: true
role: "presiding judge after reassignment"
fn: 9
- type: participant_in
with: "[[Todd Blanche]]"
reverse: true
role: "counsel for the United States"
start: 2025-07-18
fn: 9
- type: participant_in
with: "[[Thomas Massie]]"
reverse: true
role: "proposed amicus curiae"
start: 2026-01-13
end: 2026-01-21
fn: 11
- type: participant_in
with: "[[Ro Khanna]]"
reverse: true
role: "proposed amicus curiae"
start: 2026-01-13
end: 2026-01-21
fn: 11
created: 2026-09-25
updated: 2026-09-25
---
United States v. Maxwell (No. 1:20-cr-00330) is the federal criminal prosecution of [[Ghislaine Maxwell]] in the [[U.S. District Court for the Southern District of New York]] for her part in [[Jeffrey Epstein]]'s sexual abuse of minors. A grand jury indicted her under seal on June 29, 2020, ten months after Epstein's death; a jury convicted her on December 29, 2021 on five of six counts, and Judge [[Alison Nathan]] sentenced her on June 28, 2022 to 240 months. The [[Second Circuit]] affirmed in 2024, rejecting her claim to immunity under the [[Epstein non-prosecution agreement]], and the [[Supreme Court of the United States|Supreme Court]] denied review in October 2025. Under Judge [[Paul Engelmayer]] the closed docket became, in 2025 and 2026, a forum for the release of the grand jury record under the [[Epstein Files Transparency Act]].[^1][^2][^3]
### Indictment and Pretrial
The indictment was unsealed on July 2, 2020, the day agents of the [[Federal Bureau of Investigation]] arrested Maxwell at a property in [[New Hampshire]]. Its six counts charged her with facilitating Epstein's abuse of minor victims "from around 1994 to 1997." A first superseding indictment of July 10, 2020 added two perjury counts drawn from her 2016 deposition in [[Giuffre v. Maxwell]]. A second, of March 29, 2021, added a sex trafficking conspiracy count and a count of sex trafficking of a minor, extended the charged conduct into the early 2000s, and renumbered the perjury counts as Seven and Eight. Nathan entered the protective order governing discovery (ECF No. 36) on July 30, 2020.[^1]
Maxwell's lawyers, Mark S. Cohen of [[Cohen & Gresser]], Jeffrey S. Pagliuca and [[Laura Menninger|Laura A. Menninger]] of [[Haddon, Morgan and Foreman]], and Bobbi C. Sternheim, moved to dismiss for breach of the 2007 agreement, whose co-conspirator clause provided that "the United States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein." Nathan denied the motion with the other pretrial motions on April 16, 2021 (ECF No. 207). In an August 24, 2020 reply brief Pagliuca told Nathan that the government had subpoenaed from Giuffre's lawyers nearly 90,000 pages of civil discovery still under the Giuffre v. Maxwell protective order, more than half of the 165,000 pages of criminal discovery, while the Second Circuit and Judge [[Loretta Preska]] were deciding whether to unseal the same material; he asked leave to tell those courts under seal, warning that if they ordered Maxwell's deposition unsealed "without the benefit of this information," "the cat will be out of the bag."[^4][^5]
### Trial and Sentence
Trial began on November 29, 2021. Epstein's pilot [[Larry Visoski]] testified for the government; three accusers testified under pseudonyms and a fourth, [[Annie Farmer]], under her own name. On December 9 Nathan admitted Epstein's contact book as Government Exhibit 52 on the authentication of [[Juan Alessi]], the former [[Palm Beach, Florida|Palm Beach]] house manager (ECF No. 535). The jury of six women and six men deliberated about 40 hours over parts of six days and on December 29, 2021 convicted Maxwell of conspiracy to entice minors to travel to engage in illegal sex acts, conspiracy to transport minors, transportation of a minor, sex trafficking conspiracy and sex trafficking of a minor, acquitting her on Count Two. Nathan denied a new trial motion on April 1, 2022 after a juror's undisclosed history of childhood abuse, finding the omission "highly unfortunate, but not deliberate."[^1][^6]
At sentencing on June 28, 2022 Nathan calculated a Guidelines range of 188 to 235 months and imposed 240 months, as concurrent terms of 60 months on each conspiracy count, 120 months on the transportation count and 240 months on the count of sex trafficking of a minor, with 250,000 dollar fines on three counts, 750,000 dollars in all. She found that Maxwell had "directly, repeatedly, and over the course of many years participated in a horrific scheme to entice, transport, and traffic underage girls, some as young as 14, for sexual abuse by and with Jeffrey Epstein." The perjury counts were dismissed. A July 22, 2025 internal FBI email recorded that "[a]fter the conviction, the perjury charges were dropped to prevent the victims from testifying in another trial."[^6][^7]
### Appeal and Certiorari
A panel of Judges [[José A. Cabranes]], [[Richard C. Wesley]] and [[Raymond J. Lohier Jr.]] heard argument on March 12, 2024 and affirmed on September 17, 2024 (118 F.4th 256). Applying United States v. Annabi (1985), it held that "[a] plea agreement binds only the office of the United States Attorney for the district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction," found that "[n]othing before us indicates that USAO-SDNY had been notified or had approved of Epstein's NPA," and acknowledged that the circuits "have been split on this issue for decades." Rehearing was denied on November 25, 2024. The November 2020 report of the [[Department of Justice|Justice Department]]'s [[Office of Professional Responsibility]] on the Florida agreement was filed in both the district court and the appellate record. Maxwell petitioned the Supreme Court on April 10, 2025 (No. 24-1073), asking whether a promise made on behalf of "the United States" by a U.S. Attorney in one district binds prosecutors in other districts; the Solicitor General opposed on July 14, 2025, and certiorari was denied on October 6, 2025.[^2][^3][^8]
### The 2025 Interview and the Grand Jury Record
On July 18, 2025 Deputy Attorney General [[Todd Blanche]], formerly [[Donald Trump]]'s personal criminal defense lawyer, entered an appearance for the United States in the closed case (ECF No. 784) and moved to unseal the grand jury transcripts (ECF No. 785). He questioned Maxwell under a grant of limited use immunity in [[Tallahassee, Florida|Tallahassee]] on July 24 and 25, and on August 1 she was moved to the minimum-security [[Federal Prison Camp Bryan]] in Texas. Engelmayer, to whom the case had passed after Nathan's elevation to the Second Circuit, denied the unsealing motion on August 11, 2025 (ECF No. 809, 794 F. Supp. 3d 215), holding that Rule 6(e) barred disclosure and that the "special circumstances" exception did not apply.[^9]
After the Epstein Files Transparency Act became law on November 19, 2025, Assistant U.S. Attorney Sean Buckley renewed the motion (ECF No. 810). Engelmayer took victim submissions through a dedicated Justice Department mailbox, docketed three redacted victim letters (ECF No. 818), and on December 9, 2025 granted the motion and modified the 2020 protective order, subject to the Act's victim-privacy provision (ECF No. 820). In the parallel docket of [[United States v. Epstein]], Judge [[Richard M. Berman]] reached the same two results a day apart from Engelmayer at each stage.[^9][^10]
On January 13, 2026 Representatives [[Thomas Massie]] and [[Ro Khanna]], the Act's sponsors, moved to appear as amici curiae and asked for "a special master or independent monitor," telling the court that the Department had "publicly released only 12,285 documents" of "more than 2 million documents potentially responsive to the Act" and that "DOJ cannot be trusted with making mandatory disclosures under the Act" (ECF Nos. 837, 838). Letters from victims, including one from [[Haley Robson]] transmitted by the government (ECF No. 843), were cited in support. Engelmayer denied the motion on January 21, 2026 (ECF No. 844): "This federal criminal case does not give the Court jurisdiction over, or authority to supervise, DOJ's compliance with the EFTA, a civil records-disclosure statute." He described the case as "effectively closed," with Maxwell's pro se motion under 28 U.S.C. 2255, filed December 17, 2025 (ECF No. 830), "the only outstanding item." Status letters over the name of the U.S. Attorney, [[Jay Clayton]], followed on January 15 and 31 (ECF Nos. 839, 847). The government's letters of February 12 and April 21, 2026 concerned the schedule for its response to the section 2255 motion, and the docket remained active on July 31, 2026 (ECF No. 866).[^11][^12]
### Footnotes
[^1]: United States v. Maxwell, No. 1:20-cr-00330 (S.D.N.Y.), Indictment (sealed June 29, 2020, unsealed July 2, 2020); S1 Superseding Indictment (July 10, 2020); S2 Superseding Indictment (March 29, 2021); Protective Order, ECF No. 36 (July 30, 2020); Opinion and Order, ECF No. 207 (April 16, 2021); Memorandum Opinion and Order, ECF No. 535 (Dec. 9, 2021), CourtListener docket 17318376. https://www.courtlistener.com/docket/17318376/united-states-v-maxwell/
[^2]: United States v. Maxwell, No. 22-1426-cr, slip op. at 3-4, 6-12, 23-25 (2d Cir. Sept. 17, 2024) (Cabranes, Wesley, Lohier, JJ.), reported at 118 F.4th 256, quoting the NPA at A-178 and United States v. Annabi, 771 F.2d 670, 672 (2d Cir. 1985). https://storage.courtlistener.com/pdf/2024/09/17/united_states_v._maxwell.pdf
[^3]: Maxwell v. United States, No. 24-1073 (U.S.), Petition for a Writ of Certiorari (April 10, 2025); Brief for the United States in Opposition (July 14, 2025); certiorari denied, 146 S. Ct. 93 (Oct. 6, 2025). https://www.supremecourt.gov/docket/docketfiles/html/public/24-1073.html ; https://www.justice.gov/epstein/doj-disclosures/court-records-maxwell-v-united-states-no-24-1073-us-2025-petition-cert
[^4]: United States v. Maxwell, No. 1:20-cr-00330 (S.D.N.Y.), Notice of Motion to Dismiss Superseding Indictment for Breach of Non-Prosecution Agreement, ECF No. 141 (filed Feb. 4, 2021). https://storage.courtlistener.com/recap/gov.uscourts.nysd.539612/gov.uscourts.nysd.539612.141.0.pdf
[^5]: U.S. Department of Justice, Epstein Library, EFTA00088205, DataSet 9, letter, Jeffrey S. Pagliuca, Haddon, Morgan and Foreman, P.C., to Hon. Alison J. Nathan, "Re: Reply in Support of Request to Modify Protective Order (Under Seal), United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)," August 24, 2020. https://www.justice.gov/epstein/files/DataSet%209/EFTA00088205.pdf
[^6]: "Ghislaine Maxwell Sentenced To 20 Years In Prison," U.S. Attorney's Office, Southern District of New York, June 28, 2022. https://www.justice.gov/usao-sdny/pr/ghislaine-maxwell-sentenced-20-years-prison-conspiring-jeffrey-epstein-sexually-abuse ; "Ghislaine Maxwell trial: Jury finds she sex trafficked a minor for Jeffrey Epstein, guilty on five of six counts," *CNN,* December 29, 2021. https://www.cnn.com/2021/12/29/us/ghislaine-maxwell-trial-wednesday ; "Juror's omissions will not trigger Ghislaine Maxwell retrial," *Courthouse News Service,* April 2022. https://www.courthousenews.com/jurors-omissions-will-not-trigger-ghislaine-maxwell-retrial/
[^7]: U.S. Department of Justice, Epstein Library, EFTA00161422, DataSet 9, internal email chain, "Re: Ghislaine Maxwell," July 22, 2025, EFTA00161422 to EFTA00161424. https://www.justice.gov/epstein/files/DataSet%209/EFTA00161422.pdf
[^8]: U.S. Department of Justice, Epstein Library, EFTA02830776, Court Records (United States v. Maxwell, No. 1:20-cr-00330 (S.D.N.Y. 2020)), Office of Professional Responsibility report of November 2020 as filed in the case. https://www.justice.gov/epstein/files/Court%20Records/United%20States%20v.%20Maxwell%2C%20No.%20120-cr-00330%20(S.D.N.Y.%202020)/EFTA02830776.pdf ; U.S. Department of Justice, Epstein Library, EFTA02844213, Court Records (United States v. Maxwell, No. 22-1426 (2d Cir. 2022)), Document 1-1. https://www.justice.gov/epstein/files/Court%20Records/United%20States%20v.%20Maxwell%2C%20No.%2022-1426%20(2d%20Cir.%202022)/EFTA02844213.pdf
[^9]: United States v. Maxwell, No. 1:20-cr-00330 (S.D.N.Y.), ECF Nos. 784, 785 (July 18, 2025); Opinion and Order, ECF No. 809 (Aug. 11, 2025), reported at 794 F. Supp. 3d 215; Renewed Motion to Unseal, ECF No. 810 (Nov. 24, 2025); Order, ECF No. 811; victim letters, ECF No. 818 (Dec. 5, 2025); Opinion and Order, ECF No. 820 (Dec. 9, 2025), 2025 WL 3522378. https://www.courtlistener.com/docket/17318376/united-states-v-maxwell/ ; "Ghislaine Maxwell moved to federal prison camp in Texas," *CNN,* August 1, 2025. https://www.cnn.com/2025/08/01/politics/ghislaine-maxwell-federal-prison-texas
[^10]: United States v. Epstein, No. 1:19-cr-00490 (S.D.N.Y.), Decision and Order, ECF No. 77 (Aug. 20, 2025); Decision and Order, ECF No. 92 (Dec. 10, 2025), CourtListener docket 15887848. https://www.courtlistener.com/docket/15887848/united-states-v-epstein/
[^11]: United States v. Maxwell, No. 20 Cr. 330 (PAE) (S.D.N.Y. Jan. 21, 2026), Opinion and Order, ECF No. 844, denying motion of Reps. Massie and Khanna (ECF Nos. 837, 838). https://www.nysd.uscourts.gov/sites/default/files/2026-01/Maxwell%2020cr330%20-%20Opinion%20%26%20Order%201.21.26.pdf
[^12]: United States v. Maxwell, No. 1:20-cr-00330 (S.D.N.Y.), Pro Se Motion to Vacate under 28 U.S.C. 2255, ECF No. 830 (Dec. 17, 2025); letters, ECF Nos. 839 (Jan. 15, 2026), 843 (Jan. 20, 2026), 847 (Jan. 31, 2026), 852 (Feb. 12, 2026), 856 (April 21, 2026), 866 (July 31, 2026). https://www.courtlistener.com/docket/17318376/united-states-v-maxwell/