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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

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

EFTA Document EFTA01654956

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

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

Subject: RE: Ghislaine Maxwell arrest, court appearance -- from Reuters

Subject: RE: Ghislaine Maxwell arrest, court appearance -- from Reuters Date: Thu, 02 Jul 2020 13:38:59 +0000 We have — a few minutes before this posted. Thanks. From: Sent: Thursday, July 2, 2020 9:38 AM To: Cc: Subject: Re: Ghislaine Maxwell arrest, court appearance -- from Reuters We should notify OPA if we have not yet done so. Sent from my iPhone On Jul 2, 2020, at 9:19 AM, > wrote: Jeffrey Epstein Confidante Ghislaine Maxwell Arrested, Sources Say Maxwell was accused in a civil suit of allegedly helping Epstein traffic underage girls; he died by suicide awaiting trial last year By Jonathan Dienst Joe Valiquette Tom Winter and Sarah Fitzpatrick • Published 52 seconds ago • Updated 41 seconds ago Ghislaine Maxwell, the British socialite and heiress who became a confidante of disgraced financier Jeffrey Epstein and was later accused of involvement in his alleged sexual crimes, has been arrested by the FBI, two senior law enforcement sources tell News 4 New York.