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efta-02434015DOJ Data Set 11Other

EFTA02434015

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Unknown
Source
DOJ Data Set 11
Reference
efta-02434015
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2
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0
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EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
To: Jeffrey Epsteinueevacation©gmailcom] From: Lesley Groff Sent Mon 12/7/2009 5:36:44 PM Subject: RE: Got it!! From: Jeffrey Epstein [mailto:jeevacation@gmail.com] Sent: Monday, December 07, 2009 12:36 PM To: Lesley Groff Subject: Re: is coning tonight. form new york zeff is supposed to be fed cxing me somthign On Mon, Dec 7, 2009 at 12:34 PM, Lesley Groff < > wrote: I called Zeff...he is unsure what you are telling him...he does not know who is and does not know what package you are speaking of. Mark is in the office now if you would like to speak with him. Mark: 212 580 7090 ext 201 From: Jeffity Epstein Imailto:sevacationOgmail.coml Sent: Monday, December 07, 2009 12:16 PM To: Lesley Groff Subject: you can tell zeff that ■ is coming tonight and can bring his package The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Jeffrey Epstein Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to ieevacation@gmail.com, and EFTA_R1_01505478 EFTA02434015 destroy this communication and all copies thereof, including all attachments. The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Jeffrey Epstein Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to jeevacation@gmail.com, and destroy this communication and all copies thereof, including all attachments. EFTA_R1_01505479 EFTA02434016

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Emailieevacation@gmail.com
Emailjeevacation@gmail.com
Phone212 580 7090
Phone2434015
Phone2434016

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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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States for illicit purposes. Epstein and Brunel allegedly housed the models in apartments located at

States for illicit purposes. Epstein and Brunel allegedly housed the models in apartments located at 2 Larry Visoski or "Lawrence P. Visoski" is Epstein's longtime pilot. EXHIBIT: TIMELINE OF PAYMENTS TO (OR ON BEHALF OF) POTENTIAL CO-CONSPIRATORS (PAYMENTS > $10,000) 1)xli 12/4/2013 lil NI I I( I \In N kut MC Model Management' k \10( \I $25,000 BENEFICIARY B %NE TD Bank BENEFICIARY WIRING ACCOUNT ACCOUNT # Jeffrey Epstein WIRING ACCOUNT # IN IRE DETAILS/ INSTRUCTIONS N/A 12/10/2013 MC2 Model Mana • ement $29,440 SunTrust Bank Jeffrey Epstein N/A 12/11/2013 Larry Visoski $225,000 Bank of America Jeffrey Epstein N/A 12/20/2013 Visoski $16,676 Bank of America Jeffrey Epstein Petty cash 1/21/2014 MC Model Maim • ement $25,000 TD Bank Jeffrey Epstein N/A 1/21/2014 $14,000 JP Morgan Chase Jeffrey Epstein N/A 4/10/2014 301/66 owners Co ° $182,219 Citibank Jeffrey Epstein N/A 5/2/2014 301/66 Owners Corp $50,000 Citibank Jeffrey

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