Subject: Re: Fwd (TEL) Prosecutors in Ghislaine Maxwell Case Ask for Halt to Civil Proceed

EFTA Document EFTA01654937

From: "

From: " " To: ' " < E> Cc: " )" Subject: RE: additional Epstein information request Date: Tue, 02 Jun 2020 22:42:52 +0000 As we expected might happen, we have gotten effectively the same question / request from counsel to another plaintiff as we did from counsel to several months ago — i.e., whether the Government is able to produce records that would be relevant to an ongoing civil lawsuit against Epstein's estate, among other individuals. This request was made by counsel to who is the main victim in what we expect will be an upcoming case against Ghislaine Maxwell, so we've been in touch with her counsel a number of times. And of course as with any victim, we don't want to unnecessarily impede her litigation. In the first instance, though, because her attorney does not have experience with the Touhy process, I think it would make sense, subject to input from you and John, to send her attorney basically the same letter you sent Robbie back in January, to get the ball

EFTA Document EFTA01684300

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

iltattOll0 (Rev Olen Subpoena to lcoth Itcfoc titoill lun

iltattOll0 (Rev Olen Subpoena to lcoth Itcfoc titoill lun UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA TO: SUBPOENA TO TESTIFY BEFORE GRAND JURY PG) 07-103(4PB) -Tuts. No. OLY-05/1 SUBPOENA FOR: Lei PERSON d DOCUMENT(S) OR OEUECT(S) YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury of the United States District Court at the place, date, and time specified below. PLACE United States District Court 701 Clematis Street West Palm Beach. Fonda 33401 COURTROOM Grand Jury Room DA IE AND TIME 7/1/2008 10:30 am YOU ARE ALSO COMMANDED to bring with you the following documents) or object(s):• ALL DOCUMENTS AND INFORMATION REFERENCED IN THE ATTACHMENT TO THIS SUBPOENA. K Pleat see additional information on re' • This subpoena shall remain in el behalf of t i c ;our., (BY) Deputy lent • rt by the court or by an officer acting on HONE NUMBER OF ASSISTANT U S ATTORNEY This subpoena is issued on application Assistant U.S. Attorney 500 outh

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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