EFTA02095317

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DOJ Data Set 10

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efta-02095317

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EFTA Disclosure

Text extracted via OCR from the original document. May contain errors from the scanning process.

To: Lesle Gro Cc: Fran: Sent: Subject: Re: do you know of any spa not too$$$ I used to go to York Spa in Soho. Also great Jones spa Sent from my iPhone > On Sep 26, 2014, at 11:14 AM, Lesley Groff wrote: > HI .do either of you know of a spa (with massage, facial, standard stuff) that is not crazy expensive? is in town and wants to buy IIII a gift of a spa day but she can't find anything affordable. I don't really go to these places very often so really can't help her...could one of you recommend a place in the city by any chance? EFTA_R1_00696874 EFTA02095317

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DOJ Data Set 10OtherUnknown

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

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DOJ Data Set 9OtherUnknown