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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

DS9 Document EFTA00298259

From: "Bulletin Intelligence" <[email protected]>

From: "Bulletin Intelligence" <[email protected]> To: "[email protected]" <[email protected]> Subject: [EXTERNAL EMAIL] - FBI Public Affairs News Briefing Monday, April 26, 2021 Date: Mon, 26 Apr 2021 10:27:35 +0000 c Importan e: Normal Mobile version and searchable archives available at fbi.bulletinintelligence.com. 'L; 1 B1 News Briefing TO: THE DIRECTOR AND SENIOR STAFF DATE: MONDAY, APRIL 26, 2021 6:30 AM EDT TODAY'S TABLE OF CONTENTS LEADING THE NEWS • Garland Signals More Investigations Into Local Police Departments Will Be Forthcoming. CAPITOL VIOLENCE NEWS • FBI Using Facial Recognition, Undercover Operations To Arrest Capitol Rioters. • Growing Number Of Those Arrested In Capitol Siege Probe Have Military, Law Enforcement, Or Government Ties. • Two Kansas Women Charged In Capitol Riot Probe. • FBI Arrests Man Who Boasted On Dating App Of Storming Capitol. • Texas Couple Charged With Assaulting Officers During Capitol Siege.

EFTA Document EFTA01417448

7/15/2019 KYC Print DB PWM GLOBAL KYC/NCA: PART A KYC Case # : 01344537 One sheet must be established per relationship - list all accounts included in the relationship 1. Relationship Details Relationship Name: Relationship Manager: EPSTEIN, JEFFREY RELATIONSHIP:00000483290 Paul Morris New PWM Relationship Relationship to PWM: If existing, please indicate since when the relationship exists, provide reason for new profile and attach old profile: Update of KYC #01133113. Trustees ha

Memorandum

Memorandum Subject Re: Operation Leap Year Date May 1, 2007 (Revised 9/13/07) (2nd Revision 2/19/08)' To From R. Alexander Acosta, United States Attorney First Assistant United States Attorney Chief, Criminal Division MAUSA, Northern Region , Chief, Northern Region I. Introduction This memorandum seeks approval for the attached indictment char in Jeffrey Epstein, Min a/k/a' JEGE Inc., and Hyperion Air, Inc. The proposed indictment contains 60 counts and seeks the forfeiture of Epstein's Palm Beach home and two airplanes? The FBI has information regarding Epstein's whereabouts on May 16th and May 19th and they would like to arrest him on one of those dates. Epstein is considered an extremely high flight risk' and, from information we have received, a continued danger 'The second revision amends the Jane Doe numbering system to correspond with the most recent indictment. It also removes the references to the overt acts and substantive allegations related to each

EFTA Document EFTA01650531