Case 1:15-cv-07433-RWS Document 658 Filed 03/03/17 Page 1 of 1

DS9 Document EFTA00590749

EFTA01702202

EFTA01682184

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

[REDACTED - Survivor] Deposition May 2016

Case Document 1090-32 Filed 07/30/20 Page 1 of 89 EXHIBIT Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 2 of 89 GIUFFRE VS. MAXWELL Deposition [REDACTED - Survivor] 05/03/2016 _______________________________________________________________________ Agren Blando Court Reporting & Video, Inc. 216 16th Street, Suite 600 Denver Colorado, 80202 303-296-0017 Agren Blando Court Reporting & Video, Inc. Page 3 of 89 Case 1:15-cv-07433-LAP Document 1090-32 Filed 07/30/20 Page 1 IN THE UNI

Haddon. Morgan and Foreman, e c

Haddon. Morgan and Foreman, e c Laura A. Menninger II A I> DO N MORGAN FOREMAN April 6. 2016 Via Email ISO East 10th Avenue Denver. Colorado 80203 Re: Giuffre Maxwell, 15-cv-07433-RWS I appreciate your taking the time to talk to me yesterday. As you know, I represent Ghislaine Maxwell in the United States District Court for the Southern District of New York in a defamation action brought by Plaintiff :aka Jane Doe #3). During the course of discovery disputes Ms. Sigrid McCawley, counsel for represented to the Hon. Robert W. Sweet that my client is "under investigation" by an unidentified law enforcement agency. She argues, therefore, that she can withhold documents based initially on a supposed "investigative privilege" and then later on a "public interest privilege." I am unaware as to how either of these supposed "privileges" would apply to 10•1114,1imi Regardless, because you are the only person employed by the government who I am aware has knowledge of some of