From: Lesley Groff

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DOJ Data Set 9

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efta-efta00350444

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EFTA Disclosure

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From: Lesley Groff To: Brooke Lange Subject: Re: from Gov Bill Richardson Date: Mon, 30 Mar 2015 17:30:10 +0000 How nice! I will let Jeffrey know! Sent from my iPhone > On Mar 30, 2015, at 1:23 PM, Brooke Lange wrote: > • Hi Leslie: > Gov asked me to send you a quick note...he just wanted to see how Jeffrey is doing, and that he wishes him well. > No need for a call. Just a friendly email to say, "hi." > • Best wishes, > • Brooke Lange > Office of Governor Bill Richardson > 216 Washington Ave. > Santa Fe, NM 87501 EFTA00350444

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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

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DOJ Data Set 10OtherUnknown