From: Lesley Groff

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DOJ Data Set 9

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efta-efta00413326

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EFTA Disclosure

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From: Lesley Groff To: "Wakefield, Caitlin" Subject: Re: Re: Date: Wed, 09 May 2012 20:19:05 +0000 Super. Thx Sent from my iPhone On May 9, 2012, at 4:15 PM, "Wakefield, Caitlin" Confirmed. We will be there. Thanks wrote: From: Lesley Groff To: Wakefield, Caitlin Sent: Wed May 09 16:14:57 2012 Subject: Re: Hi Caitlin. Just reconfirming lunch tomorrow at 12:00 for the Governor at Jeffrey's home: 9 East 71st Street between 5th and Madison Thanks! Lesley On May 3, 2012, at 2:45 PM, Wakefield, Caitlin wrote: Thank you!! From: Lesley Groff To: Wakefield, Caitlin Sent: Thu May 03 14:42:09 2012 Subject: Re: Sure! not a problem at all. Jeffrey will see him at his home at noon instead of 1:00 on the 10th. thanks On May 3, 2012, at 2:00 PM, Wakefield, Caitlin wrote: Leslie, Is it possible to move the lunch up on the 10th to noon? Thanks, Caitlin Kelleher Wakefield EFTA00413326 Office of Governor Bill Richardson fdx www.billrichardson.com <image001.gif> 216 Washington Avenue, Santa Fe, NM 87501 I P.O. Box 9870. Santa Fe. NM 87504 EFTA00413327

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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