From: Lesley Groff

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DOJ Data Set 9

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efta-efta00393713

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EFTA Disclosure

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From: Lesley Groff To: "Kelleher, Caitlin" I Subject: Re: Monday Date: Tue, 12 Mar 2013 14:07:57 +0000 ok,...Iet me know. On Mar 12, 2013, at 9:57 AM, Kelleher, Caitlin wrote: He has a flight to CA on the 19th. But let me double check with him. Caitlin Kelleher Office of Governor Bill Richardson From: Lesley Groff Sent: Tuesday, Ma , To: Kelleher, Caitlin Subject: Re: Monday Caitlin, Jeffrey will be in NY March 19th...any chance the Gov. could do dinner this night? (he flies in this date) On Mar 12, 2013, at 9:27 AM, Kelleher, Caitlin wrote: Thanks much Caitlin Kelleher Office of Governor Bill Richardson <image001.jpg>cimage002.jpg> From: Lesley Gro Sent: Tuesday, Mfa To: Kelleher, Caitlin Subject: Re: Monday Hello Caitlin! Let me double check JE's calendar...will get back to you. EFTA00393713 On Mar 12, 2013, at 9:13 AM, Kelleher, Caitlin wrote: Hi Leslie!! Is Jeffrey in NY on Monday? Can he do dinner if so? Let me know, please. Thanks, Caitlin Kelleher Office of Governor Bill Richardson <image001.jpg>cimage002.jpg> No virus found in this message. Checked by AVG - www.avg.com Version: 2012.0.2240/ Virus Database: 2641/5664 - Release Date: 03/11/13 No virus found in this message. Checked by AVG - www.avg.com Version: 2012.0.2240 / Virus Database: 2641/5664 - Release Date: 03/11/13 EFTA00393714

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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