EFTA02122397

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DOJ Data Set 10

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efta-02122397

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EFTA Disclosure

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To: Lesley Groft[ From: linda Cunningham I transFORM Sent Thur 11/14/2013 7:02:21 PM Subject: Re: Closets Unfortunately, I have a daily commitment from 2:30 - 6:30 is there a morning next week that could work? Where are you currently residing>? On Thu, Nov 14, 2013 at 12:39 PM, Lesley Groff wrote: Hi Linda I will be in the city tomorrow for work. Could you come to me on Monday 18th. I could meet you at my current home at 2:30 Sent from my iPhone On Nov 14, 2013, at 11:48 AM, "linda Cunningham I transFORM" > wrote: > Hi - > I have drawings and pricing done. Wondered if you have any time free tomorrow morning? > Did you want to come see our showroom? Or would you rather I come back up there? > Linda Cunningham > Senior Designer > transFORM > 20 Jones St > New Rochelle, NY 10801 >P >F Linda Cunningham Senior Designer transFORM 20 Jones St New Rochelle, NY 10801 P F EFTA_R1_00757055 EFTA02122397

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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

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DOJ Data Set 9OtherUnknown