From: Lesley Groff

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DOJ Data Set 9

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efta-efta00412498

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EFTA Disclosure

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From: Lesley Groff To: "Wakefield, Caitlin" Subject: Re: Urgent Date: Wed, 23 May 2012 20:55:34 +0000 Name is Thorbjoem Jagland! Will keep asking about a call Friday or monday and get back to you! Sent from my iPhone On May 23, 2012, at 4:26 PM, "Wakefield, Caitlin" Thanks Caitlin K. Wakefield Office of Governor Bill Richardson www.bilInehardson.com <image003..gif> 216 Washington Avenue, Santa Fe, NM 87501 I P.O. Box 9870. Santa Fe. NM 87504 wrote: From: Lesley Groff [mailto: Sent: Wednesday, May 23, 2012 2:25 PM To: Wakefield, Caitlin Subject: Re: Urgent i am trying to contact JE now!!. hang in.... 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. EFTA00412498 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! Caitlin K. Wakefield Office of Governor Bill Richardson www.billrichardson.com <imageOO1.gif> 216 Washington Avenue, Santa Fe, NM 87501 I P.O. Box 9870. Santa Fe. NM 87504 EFTA00412499

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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