EFTA01301240

EFTA Document EFTA01683110

Epstein Depositions

10. 11. 12. l3. 14. 16. 17. l8. 19. Jeffrey Epstein v. Bradley J. Edwards, et Case No.: 50 2009 CA Attachments to Statement of Undisputed Facts Deposition of Jeffrey Epstein taken March 17, 2010 Deposition of Jane Doe taken March 11, 2010 (Pages 379, 380, 527, 564?67, 568) Deposition of LM. taken September 24, 2009 (Pages 73, 74, 164, 141, 605, 416) Deposition ofE.W. taken May 6, 2010 (1 15, 1.16, 255, 205, 215?216) Deposition of Jane Doe #4 (32-34, 136) Deposition of Jeffrey Eps

EFTA00019565

EFTA Document EFTA01711655

UNITED STATES DISTRICT COURT

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

Subject: RE: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB)

Subject: RE: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB) Date: Mon, 26 Aug 2019 21:48:47 +0000 Inline-Images: image001.jpg; image002.jpg Hi Ted, We were very grateful to Ms. or her courage in speaking with us today. For Ms. you all? 8/29 would be best. My recollection is that we planned to begin at 5pm EST—is that still the best time for Assistant United States Attorney Southern District of New York 1 St. Andrew's Plaza New York, NY 10007 From: Teri Gibbs Sent: Monday, August 26, 2019 1:52 PM To: ) Cc: Colleen Mullen ) < )*ca Subject: Re: CONFIDENTIAL: Victim Reports Against Jeffrey Epstein, 19 Cr. 490 (RMB) Hi It was great to meet you, this morning. Thank you for patience with Ms. i speaking to you was quite challenging or er. For Ms. terview, she is available on either 8/29 or 8/30 for the rescheduled video call. Please email us back at st convenience confirming the interview time. Thank you, Teri On Fri, Aug 23, 2019 at 1:25