Memorandum
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Memorandum Subwc Date Addendum to Operation Leap Year Pros Memo June 14, 2007 To From R. Alexander Acosta, United States Attorney A. Marie Villafafia Jeff Sloman, First Assistant United States Attorney Matthew Menchel, Chief, Criminal Division Andrew Lourie, MAUSA, Northern Region Karen Atkinson, Chief, Northern Region In response to concerns raised regarding charging counts related to those girls whose credibility has been attacked by attorneys for Epstein, I asked the case agents to work on corroborating the statements of those girls. This addendum reports on those efforts related to Jane Doe #6 (Alex H.) Jane Doe #6 is the girl who saw Epstein most frequently, and there were more than 250 telephone calls between Jane Doe #6 and Sarah Kellen. Jane Doe #6 is one of the girls who reports the most sexual activity with Epstein, including oral sex, sexual activity with Nadia Marcinkova, and forced sexual intercourse with Epstein. The statements that we sought to corro
Persons Referenced (7)
“...equently, and there were more than 250 telephone calls between Jane Doe #6 and Sarah Kellen. Jane Doe #6 is one of the girls who reports the most sexual activity with Epstein, including oral sex, se...”
Nadia MarcinkovaUnited StatesJeff SlomanUnited States AttorneyAndrew Lourie“...st Assistant United States Attorney Matthew Menchel, Chief, Criminal Division Andrew Lourie, MAUSA, Northern Region Karen Atkinson, Chief, Northern Region In response to concerns raised regarding ...”
Alexander Acosta“...c Date Addendum to Operation Leap Year Pros Memo June 14, 2007 To From R. Alexander Acosta, United States Attorney A. Marie Villafafia Jeff Sloman, First Assistant United States Attorney Matt...”
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EFTA DisclosureRelated Documents (6)
EPSTEIN INVESTIGATION TIMELINE
EPSTEIN INVESTIGATION TIMELINE Date To From Re: Exhibit # 5/1/2006 State Attorney Barry E. ICrischer Michael S. Reiter, Chief of Police for Town of Palm Beach Letter urging State Attorney to proceed with probable cause affidavits and case filing packages or to recuse himself 5/23/2006 File Opening Documents for Operation Leap Year 7/24/2006 Michael S. Reiter, Chief of Police for Town of Palm Beach Letter noting that Palm Beach Police Chief was unhappy with State Attorney's handling of case and was referring matter to the FBI for investigation 7/26/2006 South Florida Sun-Sentinel Article Regarding Chief Reiter's referral of case to FBI 8/2/2006 Subpoena to Colonial Bank (return date 8/18/06) 8/2/2006 Subpoena to Washington Mutual (return date 8/18/06) 8/2/2006 Subpoena to Capital One (return date 8/18/06) 8/2/2006 Subpoena to Chase (return date 8/18/06) 8/2/2006 Subpoena to Hyperion Air, Inc. (return date 8/18/06) 8/2/2006 Subpoena to JEGE, Inc. (
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA SI 20 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 - EFTA00099941 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 Yolk 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
Farmer, Jaffe, Weissing,
Farmer, Jaffe, Weissing, Edwards, Fistos £t Lehrman, P.L. 'Ovid Pam ftoisl pet WWW.PATITTOJUSTKE.COM 425 North Andrews Avenue • Suite 2 Fort Lauderdale, Florida 33301 4 00 "ti e 6.‘ tk i r atire CalkAllfle alvdtr aIINNEV rar ,NYTTENNINIP PITNEY 'OWES 02 !F $003 , 50 0 000i3V, wit JAN 2i 2,2!3 .a4P En M ZIP t20-12E 3330 Dexter Lee A. Marie Villafatia 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 EFTA00191396 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2, Petitioners, 1. UNITED STATES, Respondent. SEALED DOCUMENT EFTA00191397 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANE DOE #2, Petitioners, UNITED STATES, Respondent. SEALED DOCUMENT MOTION TO SEAL Petitioners Jane Doc No. 1 and Jane Doe No. 2, joined by movants Jane Doe No. 3 and Jane Doe No. 4, move to file the attached pleading and supporti
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
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 - EFTA00077606 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
UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-CI V-Marra/Matthewman JANE DOE # I and JANE DOE #2, Petitioners, I UNITED STATES OF AMERICA, Respondent. UNITED STATES' RESPONSE TO PETITIONERS' FIRST REOUEST FOR ADMISSIONS TO THE GOVERNMENT The United States (hereinafter the "government") hereby responds to Jane Doe #1 and Jane Doe #2's First Request for Admissions to the Government Regarding Questions Relevant to Their Pending Action Concerning the Crime Victims Rights Act (hereinafter the "Request for Admissions"), and states as follows:' I. The government admits that the FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses. Except as otherwise admitted above, the government denies Request No. I. The government's res
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