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efta-efta00176908DOJ Data Set 9Other

U.S. Department of Justice

Date
Unknown
Source
DOJ Data Set 9
Reference
EFTA 00176908
Pages
2
Persons
5
Integrity
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Summary

U.S. Department of Justice United States Attorney Southern District of Florida VIA UNITED MAIL Miss Dear Ms. December 12, 2008 SI -lob Re: Jeffrey Epstein Notification of Work Release By virtue of this letter, the United States Attorney's Office hereby provides you with notice that the U.S. Attorney's Office has learned that Jeffrey Epstein has applied to participate in the Palm Beach County Sheriff's Office's ("PBSO") work release program, and PBSO has granted that s ein is re rtedl work in for The Florida Science Foundation at . After work each day, Mr. Epstein returns to the Palm Beach County Stockade. While outside the Stockade, Mr. Epstein is electronically monitored via a GPS system and an ankle bracelet. Pursuant to the work release rules, Mr. Epstein is to go directly from the Stockade to his office, remain at the office throughout the work day, and then return directly to the Stockade. We regret that we were unable to inform you of these developments prior

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EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
U.S. Department of Justice United States Attorney Southern District of Florida VIA UNITED MAIL Miss Dear Ms. December 12, 2008 SI -lob Re: Jeffrey Epstein Notification of Work Release By virtue of this letter, the United States Attorney's Office hereby provides you with notice that the U.S. Attorney's Office has learned that Jeffrey Epstein has applied to participate in the Palm Beach County Sheriff's Office's ("PBSO") work release program, and PBSO has granted that s ein is re rtedl work in for The Florida Science Foundation at . After work each day, Mr. Epstein returns to the Palm Beach County Stockade. While outside the Stockade, Mr. Epstein is electronically monitored via a GPS system and an ankle bracelet. Pursuant to the work release rules, Mr. Epstein is to go directly from the Stockade to his office, remain at the office throughout the work day, and then return directly to the Stockade. We regret that we were unable to inform you of these developments prior to Mr. Epstein's release, but our Office was never notified of Mr. Epstein's application, and we only learned of his release more than six weeks after he began participating in the program. Should ou have an questions regarding the work release ro m, please direct your inquiries to Captain Palm Beach Sheriffs Office, It is my understanding that you have not retained counsel to represent you with regard to any litigation against Mr. Epstein. It is important that you inform me if you do hire an attorney so that I may communicate with you through that attorney, or if you change your EFTA00176908 MISS NOTIFICATION OF WORK RELEASE DECEMBER 12, 2008 PAGE 2 OF 2 address or telephone number. As I mentioned in my earlier correspondence, Robert Josefsberg and his firm were selected by an independent Special Master to represent the identified victims of Mr. Epstein with certain limitations, which Mr. Josefsberg can explain. Again, you have no obligation to select Mr. Josefsberg as your counsel, but if you would like to have Mr. Josefsber re resent you, you must contact him or his partner, Katherine Ezell, directly at or via e-mail at and (If you contact them via e-mail please reference . pstem in your e-mail.) Please note that, even if you decide not to pursue a claim against Mr. Epstein, Ms. Ezell has put together a team of counselors who can assist you with any counseling or other services that you might need. You also can continue to contact the FBI's Victim Services Coordinator, Twiler Smith, at My best wishes for a peaceful holiday season. R. Alexander Acosta INS cc: Robert Josefsberg, Esq. Katherine Ezell, Esq. EFTA00176909

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U.S. Department of Justice

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DOJ Data Set 9OtherUnknown

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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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U.S. Department of Justice

U.S. Department of Justice United States Attorney Southern District of Florida VIA FACSIMILE Michael R. Tein, Esq. Lewis Tein, P.L. 3059 Grand Avenue, Suite 340 Coconut Grove, FL 33133 Re: Jeffrey Epstein Dear Mr. Tein: 500 South Australian Ave.. Suite 400 West Palm Beach, FL 33401 (56!) 820-8711 Facsimile: (561) 820-8777 July 17, 2008 The Office has reviewed your "Notice of Continued Pendency of Federal Criminal Action," and we feel that it misrepresents the posture of the federal investigation. For example, you cite to In re Grand Jury, No. FGJ 07-103 (WPB), as evidence that the federal criminal action remains pending. That is a citation to Mr. Epstein's Motion to Quash a subpoena for computer equipment removed from Mr. Epstein's home after he and his attorneys were aware of the existence of the state investigation. Pursuant to the Non- Prosecution Agreement, that motion was supposed to have been withdrawn several months ago, and, therefore, is not "pending" in

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