EFTA02498521

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Unknown

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DOJ Data Set 11

Reference

efta-02498521

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Integrity

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EFTA Disclosure

Text extracted via OCR from the original document. May contain errors from the scanning process.

From: jeffrey E. <[email protected]> Sent: Tuesday, June 16, 2015 3:25 PM To: Ann Rodriquez Subject: Re: also the three large cushioins that we brought with us sho=ld be brought today to the plane .. have jermain set up the ex=ra outdoor speakers at the tiki hut. On Tue, Jun 16, 2015 at 11:22 AM, Ann R=driquez > wrote: Ok. I'll go see him right no=. Ann R. On Jun 16, 2015, at 11:13 AM, jeffrey E. <=jeevacation@gma=l.com <mailto:[email protected]> wrote: lets get a an of renaisance wax . thompson will direct=you and some van dyck brown pigment. pl=ase note The information contained in this communication is con=idential, may be attorney-client privileged, may constitute inside info=mation, and is intended only for the use of the addressee. It is the pr=perty of JEE Unauthorized use, disclosure or copying of this comm=nication or any part thereof is strictly prohibited and may be unlawful= If you have received this communication in error, please notify us imm=diately by return e-mail or by e-mail to [email protected] <mailto:jeevacation@=mail.com> , and destroy this=communication and all copies thereof, including all attachments. copyri=ht -all rights reserved =C2 please note EFTA_R1_01623978 EFTA02498521 The information contained in this co=munication is confidential, may be attorney-client privileged, may c=nstitute inside information, and is intended only for the use of the ad=ressee. It is the property of JEE Unauthorized use, disclosure or co=ying of this communication or any part thereof is strictly prohibitedand 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]<h>, and destroy this communication and all copies thereof, including =11 attachments. copyright -all rights reserved 2 EFTA_R1_01623979 EFTA02498522

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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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