From: Lesley Groff

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DOJ Data Set 9

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efta-efta00319591

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EFTA Disclosure

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From: Lesley Groff To: "jeffrey E." <[email protected]> Subject: Re: Gov. Bill Richardson Date: Fri, 09 Sep 2016 21:27:22 +0000 Below from Brooke in Richardson's office: He's not in NYC on the 18th, but is in on the 19th. Sent from my iPhone On Sep 9, 2016, at 4:45 PM, jeffrey E. [email protected]> wrote: see if he is in for the 18th On Fri, Sep 9, 2016 at 4:43 PM, Lesley Groff wrote: Gov. Bill Richardson will come see you for dinner at 7pm on on ay Sept. 19th! Mon. Sept 19 2016 NY Reminder: James Ce to see Julia at 10am at 301 for computer issues 9:30-10:45am Annual Appt iv/Dr. Merrill (75 minutes) 44 East 67th Street (between Park & Madison) Suite 1 JOJO TO DRIVE YOU OR WALK? TBD Jean Huguen to organize contractor meeting at 71" 4:00pm Appt w/Nick Hawk 7:00pm DINNER w/Gov. Bill Richardson please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for EFTA00319591 the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA00319592

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DOJ Data Set 9OtherUnknown

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

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DOJ Data Set 10OtherUnknown