Epstein Secrets

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 Has Offered No Basis for Additional Discovery or a Hearing 21 II. The Indictment Is Timely 23 A. Statutory Background 24

v. Maxwell. 57 EFTA00100024 particular, this matter appears to be the only remaining active civil case in this District in which claims against Ghislaine Maxwell have been asserted." (20 Civ. 484 (DCF) (JGK), Dkt. No. 80 at 2). The defendant's baseless conjecture about the Government's supposedly nefarious re

x UNITED STATES OF AMERICA SI 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS

(Def. Mot. 1 at 32 ("For the foregoing reasons, Ms. Maxwell respectfully requests that the Court dismiss the

med in the proposed agreement, because the USAO was not interested in prosecuting those individuals if Epstein entered a plea. Villafana told OPR, [Ville considered Epstein to be the top of the food chain, and we wouldn't have been interested in prosecuting anyone else.' She did not consider the possi

b) Attorney involvement in and/or awareness of the Government's interest in any witness, subject, or t et of the E stein invests ation includin Ghislaine Maxwell, , Louella Ruboyo, Larry Morrison, Larry Visold, David Rogers, William Hammond, and Robert Roxburgh; c) All documents, correspondence, and other i

of the E stein invests ation includin Ghislaine Maxwell, , Louella Ruboyo, Larry Morrison, Larry Visold,

, or t et of the E stein invests ation includin Ghislaine Maxwell, , Louella Ruboyo, Larry Morrison, Larry

tification letter. The notification promises that the Justice Department would make its "best efforts" to protect Jane Doe No. 1's rights, including Ville reasonable right to confer with the attorney for the United States in the case" and "to be reasonably heard at any public proceeding in the distric

n of Epstein. b) Attorney involvement in and/or awareness of the Government's n witness, subject, or tar et of the Epstein i including )111%1;6 Maxwell, Larry Morrison, iso , David Rogers, William Hammond, and Robert Roxburgh; c) All documents, correspondence, and other information reflecting tel

tification letter. The notification promises that the Justice Department would make its "best efforts" to protect Jane Doe No. 1's rights, including Ville reasonable right to confer with the attorney for the United States in the case" and "to be reasonably heard at any public proceeding in the distric