EFTA02238447

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DOJ Data Set 11

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efta-02238447

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To: Lesley Grof From: Brooke Lange Sent: Thur 3/8/2018 6:53:05 PM Subject: Re: Gov in NYC March 27-28 Hi Leslie: Looks like Gov could do breakfast on Tues, March 27 at 830am? Thoughts? Many thanks, Brooke Lange Office of Gov. Bill Richardson 216 Washington Ave. Santa Fe, NM 87501 > On Feb 27, 2018, at 10:29 AM, Lesley Groff wrote: > • Hi Brooke! Happy 2018 to you too! > We will include the Governor's dates on Jeffrey's itinerary! Jeffrey says he would Love to see the Governor while he is in NY_lets circle back to this as the date approaches... > Thanks, Lesley >> On Feb 27, 2018, at 11:52 AM, Brooke Lange wrote: >> Hi Lesley: » Happy 2018 to you! >> Gov will be in NYC on March 27 and 28. He'd like to stop by and say "hi" to Jeffrey as it's been a long time... » Many thanks, » Brooke Lange » Office of Gov. Bill Richardson » 216 Washington Ave. » Santa Fe NM 87501 EFTA_R1_01004948 EFTA02238447

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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