EFTA02234653

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DOJ Data Set 11

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efta-02234653

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EFTA Disclosure

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To: Russell Hernandez( Cc: Russell Hernandez( From: Sent Mon 1/15/2018 8:32:27 PM Subject Re: Jeffrey Epstein Russell, Jeffrey is suggesting you bring a landscape architect with you tomorrow...any chance? He wants to fly you around the islands ... Sent from my iPhone On Jan 15, 2018, at 12:26 PM, Russell Hernandez wrote: Yes got it Russell Hernandez On Jan 15, 2018, at 12:03 PM, wrote: Russell! You may already be aware, but just in case , St Thomas is an hour ahead of us. They don't recognize daylight savings time. A want to make sure you are up and out on time tomorrow ** Sent from my iPhone EFTA_R1_00993911 EFTA02234653

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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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DOJ Data Set 10OtherUnknown

EFTA02528889

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