Case 1:20-cv-00833-PAE Document 51 Filed 04/28/21 Page 1 of 1
Case 1:20-cv-00833-PAE Document 51 Filed 04/28/21 Page 1 of 1 U.S. Department of Justice United States Attorney Southern District of New York 86 Chambers Street New York, New York 10007 April 28, 2021 By ECF The Honorable Paul A. Engelmayer United States District Judge Southern District of New York 40 Foley Square New York, NY 10007 Re: The New York Times Co. v. Federal Bureau of Prisons, 20 Civ. 833 (PAE) Dear Judge Engelmayer: This Office represents defendant the Federal Bureau of Prisons ("BOP") in this Freedom of Information Act ("FOIA"), 5 U.S.C. § 552, action brought by plaintiff the New York Times Company (the "Times") seeking the release of certain records related to Jeffrey Epstein. I write respectfully pursuant to Rule 4.B.2 of the Court's Individual Rules and Practices in Civil Cases to seek leave to file under seal and ex parte a letter to the Court, which will be filed contemporaneously with this public letter on ECF and electronically related to it. A
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Case 1:20-cv-00833-PAE Document 51 Filed 04/28/21 Page 1 of 1 U.S. Department of Justice United States Attorney Southern District of New York 86 Chambers Street New York, New York 10007 April 28, 2021 By ECF The Honorable Paul A. Engelmayer United States District Judge Southern District of New York 40 Foley Square New York, NY 10007 Re: The New York Times Co. v. Federal Bureau of Prisons, 20 Civ. 833 (PAE) Dear Judge Engelmayer: This Office represents defendant the Federal Bureau of Prisons ("BOP") in this Freedom of Information Act ("FOIA"), 5 U.S.C. § 552, action brought by plaintiff the New York Times Company (the "Times") seeking the release of certain records related to Jeffrey Epstein. I write respectfully pursuant to Rule 4.B.2 of the Court's Individual Rules and Practices in Civil Cases to seek leave to file under seal and ex parte a letter to the Court, which will be filed contemporaneously with this public letter on ECF and electronically related to it. A
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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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