EFTA02237581

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DOJ Data Set 11

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efta-02237581

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EFTA Disclosure

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To: Cc: Russell Hernandez From: Russell Hernandez Sent: Thur 2/15/2018 1:29:08 PM Subject: Re: Jeffrey Epstein Ycs ma'am Russell Hernandez On Feb 15, 2018, at 8:09 AM, wrote: Morning! Reconfirming you will come see Jeffrey today at 12pm! 9 East 71st Street between 5th and Madison il Y you, Assistant to Jeffrey Epstein Sent from my iPhone On Feb 13, 2018, at 3:12 PM, Russell Hernandez Thank you Great making the connection!!! Take care Russell Russell Hernandez On Feb 13, 2018, at 3:09 P wrote: Hi Russell..nice to chat with you today! Such a small world! Confirming you will come see Jeffrey on Thursday Feb. 15th at 12:00pm! Thanks and see you soon. e: EFTA_R1_01002987 EFTA02237581 Assistant to Jeffrey Epstein EFTA_R1_01002988 EFTA02237582

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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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