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efta-02428213DOJ Data Set 11Other

EFTA02428213

Date
Unknown
Source
DOJ Data Set 11
Reference
efta-02428213
Pages
1
Persons
0
Integrity

Extracted Text (OCR)

EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
To: in ' y i n mail.com] Cc: From: Lesley Groff Sent Wed 3/31/2010 4:49:32 PM Subject: RE: Monday, April 19 Got it! And have put in your schedule... From: Jeffrey Epstein [mailto:jeevacation©gmail.corn] Sent: Wednesday, March 31, 2010 12:45 PM To: Starr, Ken Cc: Boris Nikolic; Henry Rosovsky; Lesley Groff Subject: Re: Monday, April 19 great On Wed, Mar 31, 2010 at 12:26 PM, Starr, Ken wrote: Jeffrey: How about an early (11 am) lunch (so as to give us lots of time) at the Charles Hotel in Cambridge? Gratefully, Ken The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Jeffrey Epstein Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. EFTA_R1_01497606 EFTA02428213

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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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