From: Lesley Groff <1

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DOJ Data Set 9

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efta-efta00412192

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EFTA Disclosure

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From: Lesley Groff <1 To: "Wakefield, Caitlin" < Subject: Re: Urgent Date: Fri, 25 May 2012 13:32:15 +0000 You bet. Sent from my iPhone On May 25, 2012, at 9:31 AM, "Wakefield, Caitlin" < Yes indeed. Thank you much From: Lesley Groff < To: Wakefield, Caitlin Sent: Fri May 25 09:27:44 2012 Subject: Re: Urgent > wrote: Hi have sent JE a couple of emails reminding him to call the Gov at 10am eastern time at Just making sure on your end it is all good! Sent from my iPhone On May 23, 2012, at 5:24 PM, "Wakefield, Caitlin" < wrote: thx Caitlin K. Wakefield Office of Governor Bill Richardson www.bilIncharcIson.corn <image001.gif> 216 Washington Avenue. Santa Fe. NM 87501 I P.O. Box 9870. Santa Fe. NM 87504 From: Lesley Groff [mailto: Sent: Wednesday, May 23, 2012 3:23 PM To: Wakefield, Caitlin Subject: Re: Urgent EFTA00412192 Terrific! Thanks so much Sent from my iPhone On May 23, 2012, at 5:18 PM, "Wakefield, Caitlin" < > wrote: yes 10am ET will work. best # i Thank you Caitlin K. Wakefield Office khardson office. mobilo fax www.bilinchardson.com <image001.gib 216 Washington Avenue. Santa Fe. NM 87501 I P.O. Box 9870. Santa Fo. NM 87504 From: Lesley Groff [mailto Sent: Wednesday, May 23, 2012 3:12 PM To: Wakefield, Caitlin Subject: Re: Urgent Caitlin, Jeffrey says he can speak Friday. Would a 10am NY time call work? What number should he call to reach the Governor? Sent from my iPhone On May 23, 2012, at 4:18 PM, "Wakefield, Caitlin" > wrote: So Governor wants to give Jeffrey's fried from the nobel peace prize committee a personal, formal introduction to Washington Speakers. I jumped the gun. Please send me their name and Governor will probably go higher than the woman I gave you. Also Gov wants to speak with Jeffrey too if possible about his recent trip to Spain and the above item. Please advise if he is free on Friday or Monday. Thank you! EFTA00412193 Caitlin K. Wakefield Office of Governor Bill Richardson wwmbiurichardson.com <image001.gif> 216 Washington Avenue, Santa Fe, NM 87501 I P.O. Box 9870, Santa Fe. NM 87504 EFTA00412194

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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