EFTA02127342

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efta-02127342

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EFTA Disclosure

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To: From: Sent: ue : : M Subject: Re: Today! Hahaha. Ok...JEE says there's a 645 thing too. I will try to get there! Thx for all of your help On Sep 24, 2013, at 2:18 PM, Lesley Groff wrote: HI You may 'check in' tn.whenever you like! It is ready! Let me ask JE on the Bill Richardson meeting... On Sep 24, 2013, at 2:10 PM, wrote: Hi there Two questions... 1. Is ready for check in? 2. Can I be late for mtg W Bill Richardson? Sounds like it is at 3pm today but likely can't get there till 330. Should I just skip? EFTA R1_00780931 EFTA02127342

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DOJ Data Set 9OtherUnknown

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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