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EFTA01944437EFTA01944441
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efta-01944438DOJ Data Set 10Other

EFTA01944438

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DOJ Data Set 10
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efta-01944438
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3
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EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
To: Lesley Gro From: Jeffrey Epstein Sent Fri 11/22/2013 7:22:16 PM Subject: Re: 5th December - Bern Lucerne Fund try 4th On Fri, Nov 22, 2013 at 8:18 PM, Lesley Groff wrote: Shall I make you an appt with Thijs and Pieter on Dec. 5th? Below email is your schedule for Dec. 5 Begin forwarded message: From: Lars Christiaanse Subject: 5th December - Date: November 22 2013 2:02:27 PM EST To: Cc: Mark Lloyd < Thijs Hovers Dear Lesley, Further to correspondence between Jeffrey and Mark Lloyd regarding an appointment on the 5th of December this morning I would like to connect you with Thijs Hovers via this email. Thijs and his business partner Pieter Taselaar are our partners in the Bern Lucerne Fund - the fund we would like to present to Jeffrey on the 5th of December. Attached you will find the latest presentation and newsletter of the fund, although Jeffrey is aware of the fund as we have discussed this in SantaFe in August. Could you perhaps liaise with Thijs directly to find a mutually convenient time on the 5th? Thijs is cc'ed on this email but his full contact details are: Thijs Hovers Lucerne Capital Management, LLC 35 Mason Street, Greenwich, CT In case Jeffrey would like me to join Thijs and Pieter on this appointment then please let me know as I will make my way up from Miami. Please do let me know in case you have any questions. All the very best, EFTA_R1_00405753 EFTA01944438 Lars Bern Dynamic LLP Lars A Christiaanse Partner US Cel: UK Mob UK DD: Thursday Dec. 5.2013 NY Reminder: Art Basal in Miami Dec. 5-8 11:30-2:00pm Appt w/Eileen Alexanderson and team at Leon Black's office 9 West 57* Street, Conference Room on 43rd Floor Eileen: 3:00pm Go See Screening of Woody Allen's Movie (Movie is 1 hour 35 minutes) Manhattan Film Center, 575 Park Ave., between 62"d and 63rd *********************************************************** The information contained in this communication is EFTA_R1_00405754 EFTA01944439 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_00405755 EFTA01944440

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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

239p
Court UnsealedFeb 5, 2021

Maxwell NPA

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ----------------------------------------------------------x UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. : : : : : : : : : 20 Cr. 330 (AJN) ----------------------------------------------------------X MEMORANDUM OF GHISLAINE MAXWELL IN SUPPORT OF MOTION TO DISMISS SUPERSEDING INDICTMENT FOR BREACH OF NON-PROSECUTION AGREEMENT Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue N

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