EFTA00099352.txt

"In 2007, the government's investigation was resolved when it entered into I Non-Prosecution Agreement ("NPA") with Epstein"

"UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant"

"Epstein and his counsel entered into the NPA with Acosta, the United States Attorney for the SDFL"

"The government has concocted I federal Mann Act case against Ms. Maxwell"

"The government has concocted I federal Mann Act case against Ms. Maxwell"

"in exchange for Epstein's compliance with the terms and conditions therein, 'the United States also agrees that it will not institute any criminal cha"

"Mark S. Cohen Attorneys for Ghislaine Maxwell"

"I hereby certify that on January 25, 2021, I served by email... the within memorandum... upon the following: U.S. Attorney's Office, SDNY"

"Investigation into the U.S. Attorney's Office for the Southern District of Florida's Resolution of its 2006-2008 Federal Criminal Investigation of Jef"

"Epstein seeks "to resolve globally his state and federal criminal liability" and thus is agreeing to comply with the terms of the NPA"

"The Department of Justice's OPR, after investigating Acosta's handling of the Epstein case"

""United States Attorney's Office" and the Federal Bureau of Investigation ("FBI") have "conducted their own investigation into Epstein's background an"

""United States Attorney's Office" and the Federal Bureau of Investigation ("FBI") have "conducted their own investigation into Epstein's background""

"the NPA unambiguously precludes prosecution of Epstein's potential co-conspirators"

"senior levels of Main Justice were directly involved in the negotiation and approval of the NPA"

"the NPA was drafted and executed by the government's agents in the SDFL"

"The charges against Ms. Maxwell involve her alleged role as I co-conspirator of Epstein"

"prosecute Ms. Maxwell for alleged conduct with Epstein in the 1990s"

"the indictment alleges that Ms. Maxwell was I co-conspirator of Epstein"

"the parties to the NPA clearly intended to confer immunity on potential co-conspirators of Epstein, such as Ms. Maxwell"

"the government had every reason to foresee I potential prosecution of Epstein's co-conspirators in this District and... Ms. Maxwell's position"

"USAO-SDFL's involvement of the USAO for this District... after multiple layers of review within the Department of Justice"

"Epstein's counsel telling her that Epstein's intent was"

"the Assistant United States Attorney who negotiated the deal recalled Epstein's counsel telling her"

"the NPA's substantive provisions establish no such limit on the immunity for potential co-conspirators-or, for that matter, for Epstein himself"

"joint investigation by the Federal Bureau of Investigation and the United States Attorney's Office... encompasses not only 'offenses' from the 2001-07"

"joint investigation by the Federal Bureau of Investigation and the United States Attorney's Office... encompasses not only 'offenses' from the 2001-07"

"one of the three alleged victims referenced in the current indictment was interviewed by the USAO for the SDFL"

"the OPR concluded that Acosta "agreed to several unusual and problematic terms in the NPA without the consideration required under the circumstances.""

"potential co-cmilators of Epstein includin but not limited to MI"

"FBI's field offices in Santa Fe, New Mexico, and St. Thomas, Virgin Islands were contacted for assistance in the investigation. Exh. G (12/6/06 redact"

"the NPA unambiguously precludes prosecution of Epstein's potential co-conspirators, and the indictment in this case must be dismissed"

"Ms. Maxwell similarly has standing to enforce the co-conspirator immunity provision of the NPA"

"by charging Ms. Maxwell with conduct in which she allegedly engaged as part of I conspiracy with Epstein... the government has violated the NPA"

"the NPA unambiguously precludes prosecution of Epstein's potential co-conspirators, and the indictment in this case must be dismissed"

"the government has sought to substitute our client for Jeffrey Epstein"

"the Department of Justice's Office of Professional Responsibility ("OPR") found that Acosta exercised "poor judgment" and "agreed to several unusual a"

"the Assistant United States Attorney who negotiated the deal recalled Epstein's counsel telling her"

"Main Justice participated in the negotiation of the NPA"

"email from Villafana to Lefkowitz attaching draft NPA"

"email from Villafana to Lefkowitz attaching draft NPA"

"well its contact with witnesses in New York"