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860 KB
Extraction Summary
4
People
5
Organizations
2
Locations
3
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal brief / court filing (government response)
File Size:
860 KB
Summary
This document is a page from a Government filing in the Ghislaine Maxwell case (1:20-cr-00330) arguing that the Southern District of New York (USAO-SDNY) was not involved in Jeffrey Epstein's Non-Prosecution Agreement (NPA). The Government asserts that communications between the Southern District of Florida (USAO-SDFL) and SDNY were solely regarding an old civil lawsuit from the 1990s, not plea negotiations. The text refutes defense claims involving 'Main Justice' and provides context on an AUSA who left the SDNY in April 2007.
People (4)
| Name | Role | Context |
|---|---|---|
| Epstein | Subject of investigation |
Mentioned in relation to plea negotiations, the NPA, and a civil lawsuit from the 1990s.
|
| The Defendant | Defendant (Ghislaine Maxwell) |
Party filing the motion (Def. Mot. 1) and making allegations about Main Justice involvement.
|
| Prosecutor in the USAO-SDFL | Government Official |
Spoke with an Assistant U.S. Attorney in New York regarding a civil lawsuit.
|
| Assistant U.S. Attorney (New York/SDNY) | Government Official |
Handled a civil lawsuit relating to Epstein in the 1990s; left USAO-SDNY on or about April 29, 2007.
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| USAO-SDFL |
United States Attorney's Office for the Southern District of Florida; negotiated with Epstein.
|
|
| USAO-SDNY |
United States Attorney's Office for the Southern District of New York; denied involvement in plea negotiations.
|
|
| Main Justice |
Department of Justice Headquarters; defendant alleges senior levels were involved in NPA negotiations.
|
|
| Civil Division |
Division within the US Attorney's Office where the NY AUSA worked in the 1990s.
|
|
| Criminal Division |
Division where the NY AUSA worked in the 2000s.
|
Timeline (3 events)
2007-04-29
Assistant U.S. Attorney referenced in privilege log left the USAO-SDNY.
New York
NY AUSA
Locations (2)
| Location | Context |
|---|---|
|
Location of the USAO-SDNY.
|
|
|
Jurisdiction of USAO-SDFL.
|
Key Quotes (4)
"Grasping at straws, the defendant points to a notation in the privilege log..."Source
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Quote #1
"Put simply, those communications provide no indication that the USAO-SDNY was involved in plea negotiations with Epstein."Source
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Quote #2
"In sum, the privilege log in no way establishes that other districts were involved in negotiating the NPA, much less that Epstein was promised that the NPA would bind other districts."Source
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Quote #3
"Instead, without any citation, she broadly alleges that 'senior levels of Main Justice were directly involved in the negotiation and approval of the NPA.'"Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,610 characters)
Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 37 of 239
The privilege log also does not establish that the USAO-SDFL involved other U.S.
Attorney’s Offices in plea negotiations with Epstein. Grasping at straws, the defendant points to
a notation in the privilege log, which contains an entry for handwritten notes, reflecting that the
prosecutor in the USAO-SDFL spoke with an Assistant U.S. Attorney in New York. (Def. Mot. 1
at 22). The notes referenced in the privilege log are attached hereto as Exhibit 1. As the notes
reflect, the prosecutor at the USAO-SDFL reached out to an Assistant U.S. Attorney at the USAO-
SDNY to ask about a civil lawsuit relating to Epstein that was handled by the Civil Division of
this Office in the 1990s. The Government is producing to defense counsel today emails that
confirm that this was the nature of the contact.⁵ One of those emails is attached hereto as Exhibit
2 for the Court’s reference. Put simply, those communications provide no indication that the
USAO-SDNY was involved in plea negotiations with Epstein. Rather, the USAO-SDFL asked
about an old civil case involving Epstein that an AUSA at the USAO-SDNY happened to handle
years earlier. In sum, the privilege log in no way establishes that other districts were involved in
negotiating the NPA, much less that Epstein was promised that the NPA would bind other districts.
Attorney’s Offices in plea negotiations with Epstein. Grasping at straws, the defendant points to
a notation in the privilege log, which contains an entry for handwritten notes, reflecting that the
prosecutor in the USAO-SDFL spoke with an Assistant U.S. Attorney in New York. (Def. Mot. 1
at 22). The notes referenced in the privilege log are attached hereto as Exhibit 1. As the notes
reflect, the prosecutor at the USAO-SDFL reached out to an Assistant U.S. Attorney at the USAO-
SDNY to ask about a civil lawsuit relating to Epstein that was handled by the Civil Division of
this Office in the 1990s. The Government is producing to defense counsel today emails that
confirm that this was the nature of the contact.⁵ One of those emails is attached hereto as Exhibit
2 for the Court’s reference. Put simply, those communications provide no indication that the
USAO-SDNY was involved in plea negotiations with Epstein. Rather, the USAO-SDFL asked
about an old civil case involving Epstein that an AUSA at the USAO-SDNY happened to handle
years earlier. In sum, the privilege log in no way establishes that other districts were involved in
negotiating the NPA, much less that Epstein was promised that the NPA would bind other districts.
The defendant proffers no other documentary evidence beyond the privilege log. Instead,
without any citation, she broadly alleges that “senior levels of Main Justice were directly involved
in the negotiation and approval of the NPA.” (Def. Mot. 1. at 22). This vague and unsworn
allegation is not evidence. Moreover, any contacts between the USAO-SDFL and Main Justice
without any citation, she broadly alleges that “senior levels of Main Justice were directly involved
in the negotiation and approval of the NPA.” (Def. Mot. 1. at 22). This vague and unsworn
allegation is not evidence. Moreover, any contacts between the USAO-SDFL and Main Justice
____________________
⁵ In response to the allegations raised by the defense’s motion, the Government identified the
underlying notes referenced in the privilege log. The Government is producing those underlying
notes, as well as the relevant emails, to defense counsel today. The Government has also been
informed by a human resources representative that payroll records reflect that the Assistant U.S.
Attorney referenced in the privilege log left the USAO-SDNY on or about April 29, 2007, months
before the NPA was executed. Although the Government has been informed that Human
Resources records do not contain information regarding a division transfer, the Government
understands from colleagues that the Assistant U.S. Attorney worked in the Civil Division in the
1990s and worked in the Criminal Division in the 2000s.
⁵ In response to the allegations raised by the defense’s motion, the Government identified the
underlying notes referenced in the privilege log. The Government is producing those underlying
notes, as well as the relevant emails, to defense counsel today. The Government has also been
informed by a human resources representative that payroll records reflect that the Assistant U.S.
Attorney referenced in the privilege log left the USAO-SDNY on or about April 29, 2007, months
before the NPA was executed. Although the Government has been informed that Human
Resources records do not contain information regarding a division transfer, the Government
understands from colleagues that the Assistant U.S. Attorney worked in the Civil Division in the
1990s and worked in the Criminal Division in the 2000s.
10
DOJ-OGR-00002971
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