EFTA01659961

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-CI V-Marra/Matthewman JANE DOE # I and JANE DOE #2, Petitioners, I UNITED STATES OF AMERICA, Respondent. UNITED STATES' RESPONSE TO PETITIONERS' FIRST REOUEST FOR ADMISSIONS TO THE GOVERNMENT The United States (hereinafter the "government") hereby responds to Jane Doe #1 and Jane Doe #2's First Request for Admissions to the Government Regarding Questions Relevant to Their Pending Action Concerning the Crime Victims Rights Act (hereinafter the "Request for Admissions"), and states as follows:' I. The government admits that the FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses. Except as otherwise admitted above, the government denies Request No. I. The government's res

EFTA01325051

Kirkland & Ellis Letter (June 19, 2008) from Kenneth Starr urging DOJ Deputy Attorney General to halt federal prosecution of Jeffrey Epstein

Kirkland & Ellis Letter (June 19, 2008) from Kenneth Starr urging DOJ Deputy Attorney General to halt federal prosecution of Jeffrey Epstein The document provides a detailed, contemporaneous account of alleged prosecutorial misconduct, a violated Non‑Prosecution Agreement, and mentions high‑level officials (Deputy Attorney General, Assistant U.S. Attorneys, former President Bill Clinton) that could be pursued for further investigation. It includes specific dates, subpoena details, and names of attorneys, offering concrete leads, but the claims are largely unverified and rely on the law firm’s advocacy, limiting its immediate explosiveness. Key insights: Letter dated June 19, 2008 from Kenneth W. Starr (Kirkland & Ellis) to Deputy Attorney General John Roth.; Claims that the federal grand jury investigation was re‑started in violation of a September 24, 2007 Non‑Prosecution Agreement with Epstein.; Alleges misconduct by Assistant U.S. Attorneys Villafana and Sloman, including alleged self‑dealing and conflict‑of‑interest.

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

Case 9:08-cv-80736-KAM Document 329 Entered on FLSD Docket 06/23/2015 Page 1 of 2

DOJ EFTA Data Set 10 document EFTA01325031

EFTA Document EFTA01718407