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efta-01858073DOJ Data Set 10Other

EFTA01858073

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efta-01858073
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EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
To: William R. Schere From: Jeffrey Epstein Sent Fri 7/8/2011 3:40:47 AM Rothstein needed Edwards to file complaints , to show to investors. In the third week of july they had an all hands meeting , where ken jenne brought in 15 boxes of epstein files. Brad and jaffc file a fed complaint on july 18 234 pages, but instruct beth willaimson , not to serve me. they misspell Espstein. so that we would not find it on pacer. (Beth should be interviewed by the USAO , she will with immunity get you your deep pocket.) Though brad at his depo denied filing it. there is a subsequent email from him to beth, on oct 18 asking her to prepare a similar fed case to be file under EW, This is also the time scott is trying to get d3 money in. He emails that he is afraid of losing the Epstein cases to other lawyers. Scott was invited in by edwards on Qtask on the epstein cases. The only case scott asked to be included on. I think a package sent over to the USAO is in order. They should also examine the ( pre BRAD , 302 sworn statement , with the post brad story„ they should interview and currrently in jail) The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Jeffrey Epstein Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA_R1_00258385 EFTA01858073

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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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