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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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From: Cc: Bee: "Berman Geoffrey (USANYS Subject: SDNY News Clips Wednesday, August 14, 2019 Date: Wed, 14 Aug 2019 21:15:07 +0000 Attachments: 2019 8-14.pdf SDNY News Clips Wednesday, August 14, 2019 EFTA00094360 Contents Public Corruption Epstein General Crimes Sprecher Violent and Organized Crime Walter Civil Division NYCHA Securities and Commodities Fraud Margulies Sharma and Farkas Matters of Interest Obama-era counsel Greg Craig's trial postponed; new jiLD, to be selected Epstein Saga Puts Spotlight on Crime Victim's Rights Act Donziger Faces Criminal Contempt Prosecution Team at Seward & Kissel Jail Where Epstein Died Has Record of Security Blunders 2nd Circuit's Decision Could Embolden Federal Anti-Corruption Prosecutors Public Corruption Epstein Jeffrey Epstein Raped Me When I Was 15 NYT By [REDACTED - Survivor] 8/14/19 The first time I stepped into Jeffrey Epstein's mansion on the Upper East Side in the fall of 2001, I noticed his security cameras.
o r oc
o r oc As C EFTA00186839 United States District Court SOUTHERN DISTRICT OF FLORIDA TO: Chase Bank USA, N.A. National Subpoena Processing 7610 W. Washington Street IN1-4054 Indianapolis, IN 46231 SUBPOENA TO TESTIFY BEFORE GRAND JURY FGJ 07-103(WPB)-Tues./No. OLY-40 SUBPOENA FOR: [I PERSON DOCUMENTS OR OBJECT[S] YOU ARE HEREBY COMMANDED to appear and testify before the Grand Jury ofthe United States District Court at the place, date and time specified below. PLACE: United States District Courthouse 701 Clematis Street West Palm Beach, Florida 33401 ROOM: Grand Jury Room DATE AND TIME: April 17, 2007 1:00 pm* YOU ARE ALSO COMMANDED to bring with you the following document(s) or object(s): See attachments *Please coordinate your complian confirm the date and time , and location of our a warance with Special Agen ederal Bureau of Investigation, Telephone: This subpoena shall remain in effect until you are granted leave to depart by the court or by an offic
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