EFTA Document EFTA01894429

JP Morgan Jeffrey Epstein report

Case 1:22:cv-10904-JSR Document 191-4 Filed 06/20/23 Page 10f 23 EXHIBIT 4  Case 1:22-cv-10904-JSR Document 191-4 Filed 06/20/23 Page 2 of 23 Jes Staley appears to have a close relationship with lefrey Epstein, regularly communicating with hm and seeking advice from him including whi Epstein is incarcerated. Other employees also communicate with Epstein intermittently on a variety of matters. + On July 10, 2008 Staley write to Epstein, “I miss you. The word is in tough place. Hangin there.” E

EFTA Document EFTA01894617

EFTA Document EFTA01895466

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

EFTA Document EFTA01839593

EFTA Document EFTA01939945