EFTA01783310

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DOJ Data Set 10

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efta-01783310

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EFTA Disclosure

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From: Lesley Groff Sent: Monday, September 19, 2016 9:18 AM To: Jeff .je Eistein Subject: re her schedule today (sent at 11:14 last night:: Hi Leslie. Sorry I have been =tudying all day (like always haha) tomorrow school until 6 and then I =m viewing an apartment around 6:30 ish after that I am free. But I =unno when I will finish the viewing but guessing maybe 7-7:30 =sh Mon. Sept. 19, 2016 NY 9:30-10:45am Annual =/i>Appt w/Dr. Merrill (75 minutes 44 East 67th Street (between Park & Madison) Suite 1 JOJO TO DRIVE YOU OR WALK? 11:00am Appt w/Jean Huguen and contractor meeting at 71st =jean.huguen@albertopinto.com <mailto:jean.huguen@albertopinto.com> ) NEED JEAN TO CONFIRM 11AM (11:30am James Ce at house to work on new iPhones) 3:00pm Appt w/Vincenzo Lozzo 4:00pm Appt w/Nick Hawk = 7:00pm DINNER w/Gov. Bill Richardson (Brooke, Bill's assistant EFTA_R1_00103827 EFTA01783310

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Emailjean.huguen@albertopinto.com

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DOJ Data Set 9OtherUnknown

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

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DOJ Data Set 10OtherUnknown