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efta-efta00038276DOJ Data Set 8Correspondence

EFTA00038276

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DOJ Data Set 8
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efta-efta00038276
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EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
asiewasiti,tho, & mil/'dn S ni ts ericAta /o7 osse,fie tgo.,49„,./ aohnonia &it/ /7,/,9 cateivir r..z„,/ , 4. cmdedof,, 4. July 17, 2020 United States Attorney's Office The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 Attn: Audrey Strauss Acting United States Attorney Re: 91A1040 Dear Ms. Strauss: Please be advised that I have represented who is currently an inmate at Clinton Correctional Facility. By way of background I is a former Special Agent with the FBI and a former decorated Lt. Colonel and helicopter pilot who served our country with honor and distinction during the Vietnam War. has informed me he believes he possesses important information relative to the death of Jeffrey Epstein along with information regarding Ghislaine Maxwell and he possesses relevant information to an individual named J. Doe who visited him while an inmate in prison. I am respectfully requesting as a former Assistant United States Attorney and a present practicing attorney that you utilize your good office to interview who seeks to lend you assistance in this investigation. It is my respectful opinion that possesses important and vital information that can assist in the interest of justice. Thank you for your consideration in this matter. Respectfully submitted, c-rnva--"41 V 2,n-r- ANTHONY V. LOMBARDINO EFTA00038276

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel - EFTA00039421 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case 3 A. The NPA Does Not Bind the Southern District of New York 4 1. The Text of the Agreement Does Not Contain a Promise to Bind Other Districts 5 2. The Defendant Has Offered No Evidence That the NPA Binds Other Districts 9 B. The NPA Does Not Immunize Maxwell from Prosecution 15 1. The NPA Is Limited to Particular Crimes Between 2001 and 2007 15 2. The NPA Does Not Confer Enforceable Rights on Maxwell 17 C. The Defendant

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