From: Lesley Groff

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

States for illicit purposes. Epstein and Brunel allegedly housed the models in apartments located at

States for illicit purposes. Epstein and Brunel allegedly housed the models in apartments located at 2 Larry Visoski or "Lawrence P. Visoski" is Epstein's longtime pilot. EXHIBIT: TIMELINE OF PAYMENTS TO (OR ON BEHALF OF) POTENTIAL CO-CONSPIRATORS (PAYMENTS > $10,000) 1)xli 12/4/2013 lil NI I I( I \In N kut MC Model Management' k \10( \I $25,000 BENEFICIARY B %NE TD Bank BENEFICIARY WIRING ACCOUNT ACCOUNT # Jeffrey Epstein WIRING ACCOUNT # IN IRE DETAILS/ INSTRUCTIONS N/A 12/10/2013 MC2 Model Mana • ement $29,440 SunTrust Bank Jeffrey Epstein N/A 12/11/2013 Larry Visoski $225,000 Bank of America Jeffrey Epstein N/A 12/20/2013 Visoski $16,676 Bank of America Jeffrey Epstein Petty cash 1/21/2014 MC Model Maim • ement $25,000 TD Bank Jeffrey Epstein N/A 1/21/2014 $14,000 JP Morgan Chase Jeffrey Epstein N/A 4/10/2014 301/66 owners Co ° $182,219 Citibank Jeffrey Epstein N/A 5/2/2014 301/66 Owners Corp $50,000 Citibank Jeffrey

EFTA01971481

Epstein Palm Beach house investigation reveals staff involvement, appointment books, and alleged sale of internal notes

Epstein Palm Beach house investigation reveals staff involvement, appointment books, and alleged sale of internal notes The passage provides concrete details about Epstein's operation—staff names, alleged appointment books, and a house manager’s claim he tried to sell internal notes—for potential follow‑up. It ties a billionaire financier and his associate Ghislaine Maxwell to systematic sexual abuse, implicating the FBI and Palm Beach Police. While many elements are already public, the specific claim of a $50,000 sale of “golden nugget” notes and the list of staff members offer actionable leads, meriting a strong but not blockbuster score. Key insights: Staff members Sarah Kellen, Adriana Ross, Lesley Groff, and Marcinkova were named in the FBI investigation and allegedly managed a daily massage appointment book.; Ghislaine Maxwell is identified as a recruiter of underage girls.; House manager Alfredo Rodriguez claims he possessed notes/emails about massage appointments and attempted to sell them for $50,000.

FD-302 (Rev. 3-8-10)

Jeffrey Epstein house details and alleged MC2 trafficking links

The passage repeats widely reported allegations about Epstein’s activities and mentions known associates (Jean‑Luc Brunel, Ghislaine Maxwell, Nadia Marcinkova). It adds a claim that Epstein gave $1 mi Alleged $1 million payment from Epstein to Jean‑Luc Brunel for MC2 startup Former bookkeeper claims MC2‑linked girls were trafficked on Epstein’s private jets Four staff members (Sarah Kellen, Adrian