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efta-efta00224759DOJ Data Set 9Other

Memorandum

Memorandum subject Memorandum seeking Travel Authorization Operation Leap Year Date June 20, 2008 1 0 I. INTRODUCTION This memorandum seeks travel authorization to travel to New York from Junc 19 to June 20. 2008, in connection with Operation Leap Year. II. THE PROPOSED TRAVEL AND ITS PURPOSE As you know, we plan to present a final indictment to the grand jury in approximately two weeks. Since our original planned indictment, we have learned about a series of victims in New York and the possible involvement of Epstein's two New York-based assistants, Lesley Groff and Cecilia Steen. The inclusion of New York victims would be a great benefit to the indictment, and we would like to interview some key people in New York in order to include that evidence in the indictment. Accordingly, I propose to travel to New York on the afternoon of Thursday, June 19 to conduct interviews on Friday. June 20, 2008.1 F so will be traveling, although they may stay longer. First, we wo

Date
Unknown
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DOJ Data Set 9
Reference
EFTA 00224759
Pages
4
Persons
4
Integrity

Summary

Memorandum subject Memorandum seeking Travel Authorization Operation Leap Year Date June 20, 2008 1 0 I. INTRODUCTION This memorandum seeks travel authorization to travel to New York from Junc 19 to June 20. 2008, in connection with Operation Leap Year. II. THE PROPOSED TRAVEL AND ITS PURPOSE As you know, we plan to present a final indictment to the grand jury in approximately two weeks. Since our original planned indictment, we have learned about a series of victims in New York and the possible involvement of Epstein's two New York-based assistants, Lesley Groff and Cecilia Steen. The inclusion of New York victims would be a great benefit to the indictment, and we would like to interview some key people in New York in order to include that evidence in the indictment. Accordingly, I propose to travel to New York on the afternoon of Thursday, June 19 to conduct interviews on Friday. June 20, 2008.1 F so will be traveling, although they may stay longer. First, we wo

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Memorandum subject Memorandum seeking Travel Authorization Operation Leap Year Date June 20, 2008 1 0 I. INTRODUCTION This memorandum seeks travel authorization to travel to New York from Junc 19 to June 20. 2008, in connection with Operation Leap Year. II. THE PROPOSED TRAVEL AND ITS PURPOSE As you know, we plan to present a final indictment to the grand jury in approximately two weeks. Since our original planned indictment, we have learned about a series of victims in New York and the possible involvement of Epstein's two New York-based assistants, Lesley Groff and Cecilia Steen. The inclusion of New York victims would be a great benefit to the indictment, and we would like to interview some key people in New York in order to include that evidence in the indictment. Accordingly, I propose to travel to New York on the afternoon of Thursday, June 19 to conduct interviews on Friday. June 20, 2008.1 F so will be traveling, although they may stay longer. First, we would like to interview he has been identified by two victims as someone who recruited numerous others to Epstein's New York residence. We know the- was going to Epstein's home when she was 14, and it is possible that she was going there as early as 13. This trip is contingent upon approval from the Justice Department of our immunity request for Yesterday I spoke with someone at the Witness Immunity Unit who stated that we 'I may decide to stay in New York on Friday night in order to sec a college friend. If I do, will pay for the hotel room on Friday night and any difference in the airfares. EXHIBIT B-132 Case No. 08-80736-CV-MARRA P-008379 EFTA00224759 should have the approval by early next week! In addition, a witness here in the Palm Beach area came forward recently to inform the FBI about a link between Epstein and the MC' Modeling Agency. The witness stated that Epstein and the head of MC2, Jean Luc Brunel, worked together to obtain fraudulent visas to bring potential models to the United States. The witness stated that Epstein selected some of the underage girls to come to the United States even though Brunel never intended to use them as models so that Epstein could engage in sexual activity with them. Brunei's name appears on several of the message pads recovered during the search of Epstein's home. Some of the messages describe young girls that he would like Epstein to meet (including a 16-year-old who would "teach Russian" to Epstein). The FBI previously tried to interview Brunel, but he refused to speak with them. The Palm Beach witness has told the FBI that a former MC' employee is willing to speak with the FBI about the fraud. Yesterday, the FBI in New York arrested two Bear Steams employees for securities fraud related to Bear Steams hedge funds involved in the subprime loan crisis. Epstein has been reported as one of the creators of those hedge funds in financial news sources. The agents here are contacting the New York agents to determine if Epstein is a target/subject of the New York investigation and also to find out whether the two employees are cooperating and would be willing to speak with us. For the foregoing reasons, I recommend that the Office approve the costs of a hotel room and a flight for my travel to New York. 'Travel plans will not be made until the immunity is confirmed. -2- Case No. 08-80736-CV-MARRA P-008380 EFTA00224760 %AO110 I Kcv 04(07) Suttpxna In Ica,fy litforc Grand Jury UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA TO SUBPOENA TO TESTIFY BEFORE GRAND JURY Ira 07-103(WM-rues. No. OLY-55/1 SUBPOENA FOR: Eg PERSON ftI DOCUMENTS) OR OBJECTS) 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 Distract Court 701 Clematis Street West Palm Beech. Florida 33401 CX)1111114OOM Grand Jury Room DA1T. AND TIME 7/1/2008 10.30 am YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s):• ALL DOCUMENTS AND INFORMATION REFERENCED IN THE ATTACHMENT TO THIS SUBPOENA. D Please see additional information on rem • This subpoena shall remain in el behalf of t e court • If erg, opplee able enter -et In by the court or by an officer sting on NAME. , ADDRESS AND PHONE NUMBER Of ASSISTANT U S. ATTORNEY Ann Mane C. WistsAs. Assistant U.S. Attorney 500 South Australian Avenue, Suite 400 West Per Beech, Florida 334014235 Tel (561) 8204711, ext 3047 Case No. 08-80736-CV-MARRA P-008381 EFTA00224761 ATTACHMENT TO GRA ADDRESSED TO LY-85/I PLEASE BRING THE FOLIO WING DOCUMENTS, ITEMS, AND INFORM/1/4'11ON WITH YOU '1O YOUR GRAND JURY APPEARANCE: I. Any and all notes, letters, cards, gifts, payments, photographs, or other items that you Cecilia Steen, Lesley Groff, Ghislaine Maxwell, and/or any other employee or associate of Jeffrey Epstein. 2. Any and all photographs, whether printed or digital, ofJeffrey Epstein, , Cecilia Steen, Lesley Groff, Ghislaine Maxvit , other employee or associate of Jeffrey Epstein. 3. Any and all e-mails, instant messages, chats, text messages. voicemails, or telephone messages that you have sent to and/or received from Jeffrey Epstein, Cecilia Steen, Lesley Groff, Ghislaine Maxwell, and/or any other employee or associate of Jeffrey Epstein. 4. A list of all telephone numbers (cellular and "land line"), e-mail addresses, screen names, addresses, and any other contact information that you have for the following persons during the period of January I, 2003 to the present: a. yourself; b. Jeffrey Epstein; f. Cecilia Steen; g. Lesley Groff; h. Ghislaine Maxwell; i. any person(s) who introduced you to Jeffrey Epstein and/or Ghislaine Maxwell; j. any person(s) whom you introduced to Jeffrey Epstein and/or Ghislaine Maxwell; k. any person(s) who communicated with you to arrange appointments to meet with Jeffrey Epstein and/or Ghislaine Maxwell. 5. Any billing statements for telephone service (cellular and "land line") for any telephone you used during the period of January I. 2003 to the present. Case No. 08-80736-CV-MARRA P-008382 EFTA00224762

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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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