EFTA00027298
Extracted Text (OCR)
EFTA DisclosureRelated Documents (6)
U.S. Department of Justice
U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Motto Building One Saint Andrew's Plaza New York. New York 10007 July 28, 2020 VIA ECF The Honorable Alison J. Nathan United States District Court Southern District of New York United States Courthouse 40 Foley Square New York, New York 10007 Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN) Dear Judge Nathan: The Government respectfully submits this letter with respect to the protective order to be entered in the above-captioned case, and to respond to the defendant's letter and submission of July 27, 2020 (the "Defendant Letter" or "Def. Ltr.") (Dkt. 29). The Government and defense counsel have conferred regarding a protective order several times via telephone and email between July 9, 2020, and today, including as recently as this morning. The Government and defense counsel have come to an agreement on much of the proposed protective order. However, the parties
Rol Slack lir „kite'
Rol Slack lir „kite' 2/949 Arcrwite a." 2434 7 Antai, Liu) 3 cut, , 4,/e EFTA00183732 KIRKLAND & ELLIS LLP AND AfilL/ArtO PART/H.3We; ' Cntercup Cantor 163 East 53'd Street New York, New York 10022-4611 WNW rwerA.COM September 2, 2008 VIA FACSIMILE (56D 820-8777 United States Attorney's Office Southern District of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Re:Jeffrey Bpstein Dear • Facsimile: In response to your letter dated August 26, 2008, I am confirming that Mr. Goldberger should continue to be listed as the contact pawn in the' mended victim notification letters and should receive the carbon copies of thoso letters as they are sent. • Also, we plan on speaking to Mr. Josofsberg this week to discuss a procedure for paying his fees. We intend to comply fully with the agreement and Mr. Epstein will pay Mr. Josfsberg's usual and customary hourly rates for his work pursuant to the agreement facilitating settlements unde
Case 9:08-cv-80736-KAM Document 50
Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 0372112011 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2 v. UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION FOR ORDER DIRECTING THE U.S. ATTORNEY'S OFFICE NOT TO WITHHOLD RELEVANT EVIDENCE COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and through undersigned counsel, to move for an order from this Court directing the U.S. Attorney's Office not to suppress material evidence relevant to this case. The Court should enter an order, as it would in other criminal or civil cases, requiring the Government to make appropriate production of such evidence to the victims. BACKGROUND In discussions with the U.S. Attorney's Office about this case, counsel for Jane Doe #1 and Jane Doe #2 inquired about whether the Office would voluntarily provide to the victims information in its possession that was mater
Subject:
From: To: Subject: - u is airs ews ne Ing e nes ay, u y 29, 2020 Date: Wed, 29 Jul 2020 10:25:50 +0000 c Importan e: Normal Mobile version and searchable archives available at fbi.bulletinintelligence.com. 1B1 News Briefing TO: THE DIRECTOR AND SENIOR STAFF DATE: WEDNESDAY, JULY 29, 2020 6:30 AM EDT TODAY'S TABLE OF CONTENTS LEADING THE NEWS • Barr Spars With Democrats At Contentious House Hearing. • Barr Says Democrats Have Tried To "Discredit" Him. • Barr Says Bash Investigating "High Number Of Unmaskings" During Obama Administration. PROTESTS • Memo Reveals Federal Agents Sought Role In Suppressing Protests Since Start. • New Mexico Governor Addresses Concerns About Federal Agents In Albuquerque. • Report: US, Oregon In Talks About Pulling Agents From Portland. • Portland Fines Federal Government For Unpermitted Fence Outside Courthouse. • US Park Police Head: Decision To Clear Protesters Not Linked To Trump "Photo Op." • Hundreds Of Cases Involving LAPD Off
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
90A-NY-3151227 Serial 64
90A-NY-3151227 Serial 64 FD-302 (Rev. 5-8-10) •1 of 1. FEDERAL BUREAU OF INVESTIGATION Date of entry 08/28/2019 On August 16, 2019, at the Metropolitan Correctional Center (MCC) III , New York, NY, Special Agent (SA) , SA , TFO , OIG Investigator and MCC Lt. interviewed LEONARDO FERNANDEZ, MCC Inmate #86824-054. After being advised of the identities of the agents and the purpose of the interview, FERNANDEZ provided the following information: On Friday (August 09, 2019), FERNANDEZ was housed in Cell 218 on L-TIER of the Special Housing Unit within MCC. He received a visit from his girlfriend, TYRELYSHANTI CRIAG, that day. He was suspected of receiving contraband at the visit and was placed in the dry room for approximately 25 hours. FERNANDEZ was then moved to K tier Cell 111. FERNANDEZ last day being housed in L Tier was Friday (August 9, 2019) prior to his visit. FERNANDEZ remembers that JEFFREY EPSTEIN would be in legal from approximately 9am to 9pm and he was
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