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20250424150144637_24-__PetitionForWritOfCertiorari_1
24- PetitionForWritOfCertiorari 1
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No. 24-____
IN THE
Supreme Court of the United States
————
GHISLAINE MAXWELL, AKA SEALED DEFENDANT 1,
Petitioner,
v.
UNITED STATES OF AMERICA,
Respondent.
————
On Petition for Writ of Certiorari to the
United States Court of Appeals
for the Second Circuit
————
PETITION FOR WRIT OF CERTIORARI
————
DAVID OSCAR MARKUS
Counsel of Record
MARKUS/MOSS PLLC
40 N.W. Third Street
Penthouse One
Miami, FL 33128
(305) 379-6667
dmarkus@markuslaw.com
Counsel for Petitioner
April 10, 2025
WILSON-EPES PRINTING CO., INC. – (202) 789-0096 – WASHINGTON, D.C. 20002
QUESTION PRESENTED
This Court long has recognized that “when a plea
rests in any significant degree on a promise or
agreement of the prosecutor, so that it can be said to
be part of the inducement or consideration, such
promise must be fulfilled.” Santobello v. New York, 404
U.S. 257 (1971). And, of course, it is well settled that
plea agreements and non-prosecution agreements are
interpreted using ordinary principles of contract
construction, requiring that the plain language of the
agreement must govern interpretation and that
ambiguities must be resolved against the Government.
Nevertheless, Circuits are split on whether promises
in a plea agreement in one district on behalf of the
“United States” o
[…]