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efta-02526185DOJ Data Set 11Other

EFTA02526185

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DOJ Data Set 11
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efta-02526185
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EFTA Disclosure
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From: Jeffrey Epstein <jeevacation@gmail.com> Sent: Thursday, July 30, 2009 7:47 PM To: Gerald Barton Subject: Re: Antigua no On Thu, Jul 30, 2009 at 3:44 PM, Geral= Barton < <mailto: a»</span> wrote:<br><blockquote class=> DISCLAIMER: This e-mail message, including any attached=files and subsequent replies, is intended only for the exclusive use of the indiv=dual or entity to which it is addressed and may contain information that is proprietary, privileged, confidential and/or exempt from disclosure under=20 applicable law. If the reader of this e-mail message is not the intended recipient, you are hereby notified that any viewing, copying, disclosure or=20 distribution of this communication is strictly prohibited. If you have rece=ved this e-mail in error, please notify the sender immediately by either teleph=ne or e-mail, and delete the original and any copies from your computer system= Thank you. From: Jeffrey Eps=ein [mailto:jeevacat=on@gmail.com <mailto:jeevacation@gmail.com> Sent: Thursday, July 30, 2009 2:35 PM To: Gerald Barton Subject: Re: Antigua jerry get info in the two islands as well. I understand that he =wns two properties on st croix , but nothing great On Thu anon <=pan dir="ltr" <mailt > wrote: Thomas, When we last met you talked ab=ut the desirability of a marina in Antigua. I told you that Antigua is a country that we are very familiar with in that my Eastern Caribbean partn=r, Sir Charles Williams, owns and operates in Antigua, the asphalt plant, th= quarry, the cement block plant, and is the country's largest contractor. Yesterday we were approached b= those managing the assets of Alan Sanford, for the receiver, ascertaining our=20 interest in the 49 pieces of property that he owns on Antigua, which incl=de 1,500 acres and two private islands, and I was told that he was planning = marina on one of his pieces of property. In a large receivership like=20 this, it is often possible to buy wholesale the entire ownership, because=it is complicated and probably looks like the inside of a goat's stomach=-- has a little bit of everything there. We are therefore pondering the merit o= buying these assets wholesale and then selling them off retail, leaving a=few choice pieces of development property with no basis. EFTA_R1_01666363 EFTA02526185 If you have any interest in pu=suing this with us, please let me know. Jerry Gerald G. Barton Landmark Land Company= Inc. P.O. Box 1880<=div> Upper Marlboro, MD =20 20773 DISCLAIMER: This e-mail message, including any attach=d files and subsequent replies, is intended only for the exclusive use of the individual or entity to which it is addressed and may contain information=that is proprietary, privileged, confidential and/or exempt from disclosure un=er applicable law. If the reader of this e-mail message is not the intended=20 recipient, you are hereby notified that any viewing, copying, disclosure =r distribution of this communication is strictly prohibited. If you have received this e-mail in error, please notify the sender immediately by ei=her telephone or e-mail, and delete the original and any copies from your com=uter system. Thank you. 2 EFTA_R1_01666364 EFTA02526186

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Emailjeevacation@gmail.com
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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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