EFTA01780460

EFTA01812018

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

reached in this case, and other information in the possession of the victims, it is also possible that

reached in this case, and other information in the possession of the victims, it is also possible that other improper relationships exist between Government agents and Epstein. Please provide any documents, correspondence, and other information regarding the possibility of any improper relationship, including: a) involvement in and/or awareness of any aspect of the Government's criminal investigation and/or possible prosecution/non-prosecution of Epstein; b) Attorney liklimenvolvement in and/or awareness of the Government's interest."( witness, subject, or target of the Epstein investigation, including Sarah Ghislaine Maxwell, Nadia Marcinkova, Lesley Groff, [REDACTED - Survivor], Louella Ruboyo, Larry Morrison, Larry Visoki, David Rogers, William Hammond, and Robert Roxburgh; c) All documents, correspondence, and other information reflecting telephone calls (includin telephone logs and telephone billing statements) made by or received by m Jeffrey Epstein, the Florida Science

Epstein Depositions

10. 11. 12. l3. 14. 16. 17. l8. 19. Jeffrey Epstein v. Bradley J. Edwards, et Case No.: 50 2009 CA Attachments to Statement of Undisputed Facts Deposition of Jeffrey Epstein taken March 17, 2010 Deposition of Jane Doe taken March 11, 2010 (Pages 379, 380, 527, 564?67, 568) Deposition of LM. taken September 24, 2009 (Pages 73, 74, 164, 141, 605, 416) Deposition ofE.W. taken May 6, 2010 (1 15, 1.16, 255, 205, 215?216) Deposition of Jane Doe #4 (32-34, 136) Deposition of Jeffrey Eps

EFTA Document EFTA01481462

TABLE OF CONTENTS COMPANY SEARCH Page 2 PUBLICATIONS Pages 3-6 OFAC Pages 7-25 EFTA01481462 COMPANY SEARCH K THIS IS NOT A STATEMENT OF GOOD STANDING t HYPERLINK "https://sos-res.state.de.us/tin/FieldDesc.jsp" \l "FILE NUMBER" \t "none" UFile Number:U 4251036 B HYPERLINK "https://sos- res.state.de.us/tin/FieldDesc.jsp" \l "INCORPORATION DATE OR FORMATION DATE" \t "none" RIncorporation Date / Formation Date:2 11/14/2006A(mm/dd/yyyy) U HYPERLINK "https://sos-res.state.de.us/tin/Fie

From: '

From: ' To:' . (USAFLS)" </O=USA/OU=FLS/CN=RECIPIENTS/CN > (USAFLS)" Subject: RE: Epstein Date: Wed, 09 Jan 2008 21:54:49 +0000 Importance: Normal Hey M— I am going to come down tomorrow to gather the boxes and talk with M. He has some ideas on the indictment. Are you free for a non-Epstein coffee? Just to get out of the office? From: (USAFLS) Sent: Wednesda January 09, 2008 4:44 PM To: Cc: Acosta, Alex (USAFLS); Subject: Epstein . (USAFLS) We just informed Jay Lefkowitz and Ken Starr that CEOS will provide a lawyer to join the SDFL team regarding Jeffrey Epstein. We advised that that lawyer will be an expert in the area and, more importantly, someone who has a national perspective concerning these matters. We also advised them that the CEOS lawyer will begin to review the investigative materials and defense submissions to determine how best to proceed. Lefkowitz said that he believes that is a fair way to proceed and requested that the CEOS lawyer contact him to a