efic eirdiehip
efic eirdiehip S iners erieleta tateAvr rozo„ , 4. sia444, 4. July 17, 2020 United States Attorney's Office The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 Attn: Audrey Strauss Acting United States Attorney Re: Richard Taus 91A1040 Dear Ms. Strauss: Please be advised that I have represented Richard Taus who is currently an inmate at Clinton Correctional Facility. By way of background Richard Taus is a former Special Agent with the FBI and a former decorated Lt. Colonel and helicopter pilot who served our country with honor and distinction during the Vietnam War. Richard Taus has informed me he believes he possesses important information relative to the death of Jeffrey Epstein along with information regarding Ghislaine Maxwell and he possesses relevant information to an individual named J. Doe who visited him while an inmate in prison. I am respectfully requesting as a former Assistant United States Attorney and a present practici
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efic eirdiehip S iners erieleta tateAvr rozo„ , 4. sia444, 4. July 17, 2020 United States Attorney's Office The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 Attn: Audrey Strauss Acting United States Attorney Re: Richard Taus 91A1040 Dear Ms. Strauss: Please be advised that I have represented Richard Taus who is currently an inmate at Clinton Correctional Facility. By way of background Richard Taus is a former Special Agent with the FBI and a former decorated Lt. Colonel and helicopter pilot who served our country with honor and distinction during the Vietnam War. Richard Taus has informed me he believes he possesses important information relative to the death of Jeffrey Epstein along with information regarding Ghislaine Maxwell and he possesses relevant information to an individual named J. Doe who visited him while an inmate in prison. I am respectfully requesting as a former Assistant United States Attorney and a present practici
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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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