From: "Wakefield, Caitlin"

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DOJ Data Set 9

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efta-efta00412445

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EFTA Disclosure

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From: "Wakefield, Caitlin" To: "Lesley Groff" <MIMIII > Subject: RE: Jeffrey Epstein Date: Wed, 23 May 2012 15:44:03 +0000 Gov never got back to me...Lets just leave it alone. :) THank you as always Caitlin K. Wakefield Office of Governor Bill Richardson office: mobile: fax: www.billrichardson.com 216 Washington Avenue, Santa Fe, NM 87501 1 P.O. Box 9870, Santa Fe, NM 87504 Original Message From: Lesley Groff [mailto: Sent: Tuesday, May 22, 2012 10:15 AM To: Wakefield, Caitlin Subject: Jeffrey Epstein Hey Caitlin...hope you had a nice weekend....Thank you for passing along Barbara Daniel's name to Jeffrey...were you able to pass the below on to the Gov. from Jeffrey? Did he have an answer?? (not sure if Jeffrey and the Gov ever spoke on this) tell bill the head of the nobel peace prize committee, and currently the sec general of the council of europe would like to change his agency , who at bills agency , does he suggest ...also, I never recd an answer regarding can the Gov. call Reid Weingarten...perhaps the two of them may have spoke on this?? Or do I need to approach Jeffrey again?? Let me know when you have a moment. Thanks, Lesley EFTA00412445

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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 9OtherUnknown