EFTA00013494

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

5122 a 2, 1:31 PM

5122 a 2, 1:31 PM WIKIPEDIA Jeffrey Epstein - Wikipedia Jeffrey Epstein Jeffrey Edward Epstein (flpstin/ EP-steenAl January 20, 1953 — August to, 2019) was an American financier and convicted sex offender.13)[4] Epstein, who was born and raised in Brooklyn, New York Citr, began his professional life by teaching at the Dalton School in Manhattan, despite lacking a college degree. After his dismiccsl from the school, he entered the banking and finance sector, working at Bear Stearns in various roles; he eventually started his own firm. Epstein developed an elite social circle and procured many women and children; he and some of his associates then sexually abused them Is&DNA. In zoo ice in Palm Beach Florida be an investi atin Epstein after a parent complained that he had sexually abused her 14-year-old dauv,hter.g. Epstein pleaded guilty and was convicted in 2008 by a Florida state court of procuring a child for prostitution and of soliciting a prostitute.a-9.1 He ser

Alleged Collusion Between Federal Prosecutors and Jeffrey Epstein in Secret Plea Deal

The passage details specific names of senior prosecutors and legal officials (e.g., Alexander Acosta, Alan Dershowitz, Jack Goldberger, Roy Black, former U.S. Attorney Guy Lewis, Kenneth Starr) discus Emails and letters suggest prosecutors coordinated with Epstein’s lawyers to keep the deal confident Alexander Acosta is named as having been “unduly measured” by Epstein and involved in the agreemen

(USAFLS)

(USAFLS) From: Sent: Monday, June 02, 2008 4:25 PM To: Villafana, Ann Marie C. (USAFLS) Subject: draft letter to DAG I t.'"...1. ;Or • > EXHIBIT B-127 08-80736-CV-MARRA P-014941 57 EFTA00224728 U.S. Department of Justice United States Attorney Southern District of Florida Airs: Assistant LAS Auorney 99N.& eth Street Aftam: Ft 33132 (305) 961-9100 DELIVERY BY FEDERAL EXPRESS June 2, 2008 Honorable Mark Filip Office of the Deputy Attorney General United States Department of Justice 950 Pennsylvania Avenue, N.W. Washington, D.C. 20530 Re: Jeffrey Epstein Dear Judge Filip, Jeffrey Epstein is a part-time resident of Palm Beach County, Florida. In 2006, the Federal Bureau of Investigation began investigating allegations that, over a two-year period, Epstein paid approximately 28 minor females from Royal Palm Beach High School to come to his house for sexual favors. In July 2006, the matter was presented to AUSA A. Marie Villafana of our West Palm Beach b

EFTA00014007

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-CI V-Marra/Matthewman JANE DOE # I and JANE DOE #2, Petitioners, I UNITED STATES OF AMERICA, Respondent. UNITED STATES' RESPONSE TO PETITIONERS' FIRST REOUEST FOR ADMISSIONS TO THE GOVERNMENT The United States (hereinafter the "government") hereby responds to Jane Doe #1 and Jane Doe #2's First Request for Admissions to the Government Regarding Questions Relevant to Their Pending Action Concerning the Crime Victims Rights Act (hereinafter the "Request for Admissions"), and states as follows:' I. The government admits that the FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO") conducted an investigation into Jeffrey Epstein ("Epstein") and developed evidence and information in contemplation of a potential federal prosecution against Epstein for many federal sex offenses. Except as otherwise admitted above, the government denies Request No. I. The government's res