U.S. Department of Justice
U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 November 2, 2020 BY FEDERAL EXPRESS PAE Attn. VA 22043 Re: United States v. Jeffrey Epstein Good day: Enclosed please find two 2 TB hard drives to be used in connection with the production being prepared from the "US v. Epstein (SW Returns)" Relativity database. Please do not hesitate to contact me at the number or email address below with any questions or concerns. by Enclosure Very truly yours, AUDREY STRAUSS Acting United States Attorney • • States Attorney EFTA00100771
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U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York, New York 10007 November 2, 2020 BY FEDERAL EXPRESS PAE Attn. VA 22043 Re: United States v. Jeffrey Epstein Good day: Enclosed please find two 2 TB hard drives to be used in connection with the production being prepared from the "US v. Epstein (SW Returns)" Relativity database. Please do not hesitate to contact me at the number or email address below with any questions or concerns. by Enclosure Very truly yours, AUDREY STRAUSS Acting United States Attorney • • States Attorney EFTA00100771
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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
Subject: Fw: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR
Subject: Fw: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS Date: Mon, 03 Aug 2020 15:51:10 +0000 Importance: Normal Attachments: U.S._v._Ghislaine_Maxwell_Indictment.pdf; Ghislaine_Maxwell_Indictment_PR.pdf Inline-Images: image001.png Hi who should we include for this release in the monthly news bulletin? ublic Affairs Specialist FBI New York Sent: Thursday, July 2, 20201:20 PM Subject: GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS UNITED STATES ATTORNEY'S OFFICE Southern District of New York GHISLAINE MAXWELL CHARGED IN MANHATTAN FEDERAL COURT FOR CONSPIRING WITH JEFFREY EPSTEIN TO SEXUALLY ABUSE MINORS Maxwell is Alleged to Have Facilitated, Participated in Acts of Abuse Additionally Charged With Perjury in Connection With 2016 Depositions Audrey Strauss, the Acting United States Attorney for the Southern District of New York, Will
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