EFTA02439830

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DOJ Data Set 11

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efta-02439830

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EFTA Disclosure

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To: Jeffrey Epstein[jeeyacation©gmail.com] From: Mark Fisher Sent: Wed 7/15/2009 1:53:11 PM Subject: Re: Steeplechase Kicking tires. Most distressed sellers are still holding, hoping and praying. Looking for something interesting to do besides yoga every day. Too much free time. Looking for some place/someone interesting to work with/for. > 1 more week/ what are you doing:/? > • On Wed, Jul 15, 2009 at 9:42 AM, Mark Fisher < > wrote: >> >> I was on the Boardwalk at Coney Island and Steeplechase Park yesterday. » I >> thought and you and wanted to to say hi. » How are you? » What's next? >> EFTA_R1_01513614 EFTA02439830

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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 10CorrespondenceUnknown