From: Lesley Groff <MIEll

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DOJ Data Set 9

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efta-efta00708292

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EFTA Disclosure

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From: Lesley Groff <MIEll > To: Jefffrey Epstein <jeevacation®gmail.com> Subject: Bill Richardson Date: Tue, 12 Apr 2011 15:30:01 +0000 LM for Bill Richardson on his personal cell and spoke to Janis (his assisant) re you would like to speak with him. On his cell, I left him the msg that you have an interesting opportunity for him. Janis says Richardson is traveling today and she will send him an email as well. Bill Richardson: Janis cell: EFTA00708292

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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