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me, in violation of 18 U.S.C. §§ 2423 and 2. Counts Five and Six charge the defendant with perjury, in violation of 18 U.S.C. § 1623.i ARGUMENT I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA"
in illegal sex acts, and aiding and abetting the same, in violation 18 U.S.C. §§ 2422 and 2. Count Three charges the defendant with conspiring with Epstein and others to transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371. Count Four charges the defendant with transporti
NARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant
f America Assistant United States Attorneys - Of Counsel - EFTA00102999 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
aw principles that apply to conflicting state laws. Annabi is the binding law of this Circuit, and this Court must apply it. 14 EFTA00103039 B. The NPA Does Not Immunize Maxwell from Prosecution Even if the NPA bound this District—which it does not—the NPA provides no basis for dismissing the Indictment. The NPA does not pr
e, in violation of 18 U.S.C. §§ 2423 and 2. Counts Five and Six charge the defendant with perjury, in violation of 18 U.S.C. § 1623. 1 ARGUMENT I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA"
in illegal sex acts, and aiding and abetting the same, in violation 18 U.S.C. §§ 2422 and 2. Count Three charges the defendant with conspiring with Epstein and others to transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371. Count Four charges the defendant with transporti
NARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant
f America Assistant United States Attorneys - Of Counsel - EFTA00099941 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 Yolk 4 1. The Text of the Agreement
aw principles that apply to conflicting state laws. Annabi is the binding law of this Circuit, and this Court must apply it. 14 EFTA00099981 B. The NPA Does Not Immunize Maxwell from Prosecution Even if the NPA bound this District—which it does not—the NPA provides no basis for dismissing the Indictment. The NPA does not pr
me, in violation of 18 U.S.C. §§ 2423 and 2. Counts Five and Six charge the defendant with perjury, in violation of 18 U.S.C. § 1623.1 ARGUMENT I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA"
in illegal sex acts, and aiding and abetting the same, in violation 18 U.S.C. §§ 2422 and 2. Count Three charges the defendant with conspiring with Epstein and others to transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371. Count Four charges the defendant with transporti
NARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant
f America Assistant United States Attorneys - Of Counsel - EFTA00077606 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
aw principles that apply to conflicting state laws. Annabi is the binding law of this Circuit, and this Court must apply it. 14 EFTA00077646 B. The NPA Does Not Immunize Maxwell from Prosecution Even if the NPA bound this District—which it does not—the NPA provides no basis for dismissing the Indictment. The NPA does not pr
me, in violation of 18 U.S.C. §§ 2423 and 2. Counts Five and Six charge the defendant with perjury, in violation of 18 U.S.C. § 1623.1 ARGUMENT I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA"
in illegal sex acts, and aiding and abetting the same, in violation 18 U.S.C. §§ 2422 and 2. Count Three charges the defendant with conspiring with Epstein and others to transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371. Count Four charges the defendant with transporti
NARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant
f 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
aw principles that apply to conflicting state laws. Annabi is the binding law of this Circuit, and this Court must apply it. 14 EFTA00039461 B. The NPA Does Not Immunize Maxwell from Prosecution Even if the NPA bound this District—which it does not—the NPA provides no basis for dismissing the Indictment. The NPA does not pr
me, in violation of 18 U.S.C. §§ 2423 and 2. Counts Five and Six charge the defendant with perjury, in violation of 18 U.S.C. § 1623.1 ARGUMENT I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement ("NPA"
illegal sex acts, and aiding and abetting the same, in violation of 18 U.S.C. §§ 2422 and 2. Count Three charges the defendant with conspiring with Epstein and others to transport minors to participate in illegal sex acts, in violation of 18 U.S.C. § 371. Count Four charges the defendant with transporti
NARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant
f America Assistant United States Attorneys - Of Counsel - EFTA00095067 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
aw principles that apply to conflicting state laws. Annabi is the binding law of this Circuit, and this Court must apply it. 14 EFTA00095106 B. The NPA Does Not Immunize Maxwell from Prosecution Even if the NPA bound this District—which it does not—the NPA provides no basis for dismissing the Indictment. The NPA does not pr
Entities connected to both Jeffrey Epstein and The NPA Does Not Immunize Maxwell

Lesley Groff
PERSONDarren Indyke
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
John F. Kennedy
PERSON
George Mitchell
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Sarah Kellen
PERSONJane Doe
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSONMartin Weinberg
PERSON
Julie K. Brown
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATION
Reid Weingarten
PERSONFBI
ORGANIZATION
A. Marie Villafana
PERSON