EFTA Document EFTA01460709
Extracted Text (OCR)
EFTA DisclosureRelated Documents (6)
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
11 MAY 25-MAY 27 901_Redacted.pdf
Kristen M. Simkins From: Irons, Janet Sent: Wednesday, May 25, 2016 11-29 AM To: Richard C. Smith Cc: Jeffrey T. We Subject: Meeting with Prison Society tomorrow Hello Warden Smith, I'm writing in preparation for our meeting with you and Director Hite tomorrow at 9:30 to talk about the Law Library. We have been in touch with Kim Kelmor, Assistant Director ofthe Law Library at Penn State, who has experience with prison libraries. She has helpfully provided us with some questions and guida
EFTA Document EFTA01935774
EFTA01398754
EFTA02672609
EFTA02420041
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