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st levied her accusations more than a decade ago. The Palm Beach FBI and the United States Attorney's Office for the Southern District of Florida ("USAO-SDFL") interviewed Accuser-4 in or around 2007 during their three- year investigation of Epstein's alleged sexual abuse (the "Florida Investigation"). And
NDICTMENT Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New
secutorial overreach. It is no mystery what happened here. The Palm Beach FBI and the U.S. Attorney's Office for the Southern District of Florida ("USAO-SDFL") conducted a thorough investigation of Jeffrey Epstein from 2006-2008 (the "Florida Investigation"), but decided not to prosecute him or his "pote
SEDING INDICTMENT Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim 33 West 19th Street - 4th Floor New York, N
squarely refutes the government's position. The co-conspirator immunity provision does not prohibit merely prosecutions by the USAO for the SDFL ("USAO-SDFL"), but by "the United States." This broad prohibition was intentional, as demonstrated by the express references elsewhere in the NPA to the United
FOR BREACH OF NON-PROSECUTION AGREEMENT Mark S. Cohen Christian R. Everdell COHEN & GRESSER LLP Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. Bobbi C. Stemheim Law Offices of Bobbi C. Stemheim Attorneys for Ghislaine Maxwell EFTA00065989 TABLE OF CONTENTS Page PRELIMINARY STATE
Entities connected to both USAO-SDFL and MORGAN & FOREMAN

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONJeffrey Pagliuca
PERSON
Michael Cohen
PERSONCohen & Gresser LLP
ORGANIZATION
Denver
LOCATIONthe Southern District
LOCATION
Colorado
LOCATIONJane Doe
PERSONR. Everdell
PERSON
Paul Cassell
PERSON
Bradley Edwards
PERSON
Prince Andrew
PERSONSecond Circuit
ORGANIZATION
Southern District of New York
ORGANIZATION
the University of Utah
ORGANIZATIONBobbi C. Sternheim
PERSON
Department of Justice
ORGANIZATION
Kenneth Marra
PERSON