UNITED STATES DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x • UNITED STATES OF AMERICA, • AFFIDAVIT OF CERTIFICATION PURSUANT TO LOCAL CRIMINAL RULE 16.1 GHISLAINE MAXWELL, • 20 Cr. 330 (MN) Defendant. x • STATE OF NEW YORK COUNTY OF NEW YORK SOUTHERN DISTRICT OF NEW YORK ) SS.: pursuant to Title 28, United States Code, Section 1746, hereby affirms under penalty of perjury: I. I am an Assistant United States Attorney in the Office of Audrey Strauss, Acting United States Attorney for the Southern District of New York. I am one of the Assistants who represents the Government in these proceedings. 2. I certify pursuant to Local Criminal Rule 16.1 that the Government has conferred in good faith with counsel to the defendant, Ghislaine Maxwell, regarding the Government's request to delay disclosure of certain materials to the defense, pursuant to Federal Rule of Criminal Procedure 16, and that the parties have been unable to reach agreement. 3. In particular
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x • UNITED STATES OF AMERICA, • AFFIDAVIT OF CERTIFICATION PURSUANT TO LOCAL CRIMINAL RULE 16.1 GHISLAINE MAXWELL, • 20 Cr. 330 (MN) Defendant. x • STATE OF NEW YORK COUNTY OF NEW YORK SOUTHERN DISTRICT OF NEW YORK ) SS.: pursuant to Title 28, United States Code, Section 1746, hereby affirms under penalty of perjury: I. I am an Assistant United States Attorney in the Office of Audrey Strauss, Acting United States Attorney for the Southern District of New York. I am one of the Assistants who represents the Government in these proceedings. 2. I certify pursuant to Local Criminal Rule 16.1 that the Government has conferred in good faith with counsel to the defendant, Ghislaine Maxwell, regarding the Government's request to delay disclosure of certain materials to the defense, pursuant to Federal Rule of Criminal Procedure 16, and that the parties have been unable to reach agreement. 3. In particular
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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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