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efta-02610938DOJ Data Set 11Other

EFTA02610938

Date
Unknown
Source
DOJ Data Set 11
Reference
efta-02610938
Pages
2
Persons
0
Integrity

Extracted Text (OCR)

EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
From: 1 <jeevacation@gmail.com> Sent: Thursday, December 6, 2018 12:13 PM To: Ken Starr Subject: Re: Thoughts on wh=t to do if anything.? lve asked marty to draft a response to include : 3 levels of Dal revi=w entire heirarchy o= USAO involved with AA in decision-making weakness of fed jurisdiction - going home (2243)„ no inducement as that term has evolved (2421), no trafficking for profit (1591 as then defined by caselaw) w=iver of liability inviting civil lawsuits that relied on NPA to limit defe=ses, recover millions as CVRA held in abeyance uniqueness of 2255 waivers and remedy =p class="MsoNormal"> over 11 yrs since executed - full performance of terms of agreement including plea to a state offense more onerous than the one the GI/State Atty selected sex re=istration no recivid=vism finality is an =nterest that has been prioritized in fed justice system no wrongdoing in negotiating the NPA: lawyers did their job, advocated, SD Fla followed Dal Crime Victim policy, SD Fla had their own independent litigation interests in not notifying certain "victims&qu=t; State treated me =n terms of work release, home detention just as they do others - equal tre=tment was a condition of NPA > wrote:=br> Ugh. Sorry= Sent from my i=hone On Dec 5, 2018, at 7:10 PM,1 <jeevacation@gmail.com <mailto:jeeracation@gmail.com> wrote:<=r> EFTA_R1_01806070 EFTA02610938 ht=ps://www.nbcnews.com/news/us-news/lawmakers-demand-probe-sex-offender-jeff=ey-epstein-s- sweetheart-deal-n944516 <https://www.nbcnews.com/news/us-news/lawmakers-demand-probe-s=x-offender-jeffrey- epstein-s-sweetheart-deal-n944516> The informa=ion contained in this communication is confidential, may be attorney-cl=ent privileged, may constitute inside information, and is intended only=for the use of the addressee. It is the property of JEE Unauthori=ed use, disclosure or copying of this communication or any part thereof=is strictly prohibited and may be unlawful. If you have received thiscommunication in error, please notify us immediately by return e-mail =r by e-mail to =eevacation@gmail.com <mailto:jeevacation@gmail.com> , and destroy this communication and all copies=thereof, including all attachments. copyright -all rights reserved <=div> please note The information contained in this communication is confidential, m=y be attorney-client privileged, may constitute inside information, and=is intended only for the use of the addressee. It is the property of Unauthorized use, disclosure or copying of this communication or=any part thereof is strictly prohibited and may be unlawful. If you hav= received this communication in error, please notify us immediately by<=r>return e-mail or by e-mail to jeevacation@gmail.com <mailto:jeevacation@gmail.com> , and destroy this communicati=n and all copies thereof, including all attachments. copyright -all rig=ts reserved --0000000000005f2424057c596b71-- conversation-id 319503 date-last-viewed 0 date-received 1544098378 flags 8590195713 remote-id 879191 2 EFTA_R1_01806071 EFTA02610939

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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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