EFTA01480594

EFTA01660803

EFTA01297668

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

Bee: "Berman Geoffrey (USANYS

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.

SDNY News Clips, Wednesday, August 14, 2019

SDNY News Clips, Wednesday, August 14, 2019 SDNY News Clips Wednesday, August 14, 2019 Contents Public Corruption 2 Epstein 2 General Crimes 14 Sprecher 14 Violent and Organized Crime 20 Walter 20 Civil Division 22 NYCHA 22 Securities and Commodities Fraud 24 Margulies 24 Sharma and Farkas 26 Matters of Interest 28 Obama-era counsel Greg Craig's trial postponed; new jury to be selected 28 Epstein Saga Puts Spotlight on Crime Victim's Rights Act 30 Donziger Faces Criminal Contempt Prosecution Team at Seward & Kissel 34 Jail Where Epstein Died Has Record of Security Blunders 36 2nd Circuit's Decision Could Embolden Federal Anti-Corruption Prosecutors 38 1 EFTA00094388 SDNY News Clips, Wednesday, August 14, 2019 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. They w