From: '
From: ' To: ' Cc: ' (USANYS)" Subject: Re: Jeffrey Epstein/Nicholas Tartaglione Date: Thu, 25 Jul 2019 11:33:35 +0000 Inline-Images: image001.png Also, did he lob the same accusation at Epstein's camp, who might have a reason to leak information to counter a narrative that Epstein tried to harm himself Assistant U.S. Attorney 212-637-1023 On Jul 24, 2019, at 23:39, Begin forwarded message: From: Bruce Barket < Date: July 24, 2019 at 11:30:12 PM EDT To: "Adam Johnson < Cc: " (USANYS)" Subject: Fwd: Jeffrey Epstein/Nicholas Tartaglione > wrote: This comes on the heels of our complaints to the Court. It seems someone in your facility has leaked false information about Nick. Bruce Barket Barket, Epstein, Kearon, Aldea & LoTurco Begin forwarded message: From: Tracy Connor Date: July 24, 2019 at 11:08:48 PM EDT To: ' Subject: Jeffrey Epstein/Nicholas Tartaglione Hello, EFTA00096215 Trying to c ' • story that says your client was questioned about a possible a
Summary
From: ' To: ' Cc: ' (USANYS)" Subject: Re: Jeffrey Epstein/Nicholas Tartaglione Date: Thu, 25 Jul 2019 11:33:35 +0000 Inline-Images: image001.png Also, did he lob the same accusation at Epstein's camp, who might have a reason to leak information to counter a narrative that Epstein tried to harm himself Assistant U.S. Attorney 212-637-1023 On Jul 24, 2019, at 23:39, Begin forwarded message: From: Bruce Barket < Date: July 24, 2019 at 11:30:12 PM EDT To: "Adam Johnson < Cc: " (USANYS)" Subject: Fwd: Jeffrey Epstein/Nicholas Tartaglione > wrote: This comes on the heels of our complaints to the Court. It seems someone in your facility has leaked false information about Nick. Bruce Barket Barket, Epstein, Kearon, Aldea & LoTurco Begin forwarded message: From: Tracy Connor Date: July 24, 2019 at 11:08:48 PM EDT To: ' Subject: Jeffrey Epstein/Nicholas Tartaglione Hello, EFTA00096215 Trying to c ' • story that says your client was questioned about a possible a
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EFTA00016736
From: Bruce Barket <bbarket@barketepstein.com>
From: Bruce Barket <bbarket@barketepstein.com> To: "Adam Johnson cal0johnson@bop. gov>" Cc: '° (USANYS)" Subject: Fwd: Jeffrey Epstein/Nicholas Tartaglione Date: Thu, 25 Jul 2019 03:30:12 +0000 Inline-Images: image001.png > This comes on the heels of our complaints to the Court. It seems someone in your facility has leaked false information about Nick. Bruce Barket Barket, Epstein, Kearon, Aldea & LoTurco 666 Old Country road Garden City, NY 11530 (516) 745 1500 - O (516) 287 7230 - M Barket Epstein.com Begin forwarded message: From: Tracy Connor <Tracy.connor@thedailybeast.com> Date: July 24, 2019 at 11:08:48 PM EDT To: "bbarket@barketepstein.com" <bbarket@barketepstein.com> Subject: Jeffrey Epstein/Nicholas Tartaglione Hello, Trying to confirm this NBC story that says your client was questioned about a possible attack on Jeffrey Epstein at the MCC. I'm at 646-354-3792. Can you call? Tracy Connor Executive editor P 212.315.4522 I M 646.354.3792 Join Beast In
EFTA00022361
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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Epstein Depositions
10. 11. 12. l3. 14. 16. 17. l8. 19. Jeffrey Epstein v. Bradley J. Edwards, et Case No.: 50 2009 CA Attachments to Statement of Undisputed Facts Deposition of Jeffrey Epstein taken March 17, 2010 Deposition of Jane Doe taken March 11, 2010 (Pages 379, 380, 527, 564?67, 568) Deposition of LM. taken September 24, 2009 (Pages 73, 74, 164, 141, 605, 416) Deposition ofE.W. taken May 6, 2010 (1 15, 1.16, 255, 205, 215?216) Deposition of Jane Doe #4 (32-34, 136) Deposition of Jeffrey Eps
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