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Extraction Summary
4
People
5
Organizations
1
Locations
2
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal filing / court document (government response)
File Size:
788 KB
Summary
This document is page 38 of a legal filing in United States v. Ghislaine Maxwell (Case 1:20-cr-00330). The government argues that the Non-Prosecution Agreement (NPA) signed by the USAO-SDFL with Jeffrey Epstein did not bind other districts. It cites the November 2020 DOJ Office of Professional Responsibility (OPR) report, noting that while USAO-SDFL prosecutor Maria Villafaña consulted with DOJ Child Exploitation Chief Andrew Oosterbaan, this does not support the defendant's claim of a wider immunity promise.
People (4)
| Name | Role | Context |
|---|---|---|
| Jeffrey Epstein | Subject of investigation |
Subject of the 2006-2008 investigation and the Non-Prosecution Agreement (NPA).
|
| The Defendant | Defendant in Case 1:20-cr-00330-PAE |
Context implies Ghislaine Maxwell (based on case number), arguing that the NPA protects her.
|
| Andrew Oosterbaan | Chief of CEOS (DOJ) |
Chief of the Department of Justice Child Exploitation and Obscenity Section; consulted during investigation and plea ...
|
| Maria Villafaña | Line Prosecutor |
Prosecutor for USAO-SDFL who sent a draft of the NPA to the CEOS Chief.
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| USAO-SDFL |
United States Attorney's Office for the Southern District of Florida; handled the original Epstein investigation and ...
|
|
| Department of Justice (DOJ) |
Federal executive department.
|
|
| Office of Professional Responsibility (OPR) |
Investigated the circumstances of the NPA and issued a report in November 2020.
|
|
| Child Exploitation and Obscenity Section (CEOS) |
Section of the DOJ consulted during the investigation.
|
|
| Washington Post |
Media outlet cited in footnote for publishing the OPR report.
|
Timeline (2 events)
2006-2008 period (implied)
2020-11-12
Publication of OPR Report
Washington Post (published)
Department of Justice Office of Professional Responsibility
Locations (1)
| Location | Context |
|---|---|
|
Jurisdiction where the original Epstein investigation and NPA took place.
|
Relationships (2)
Villafaña sent Oosterbaan a draft of the NPA.
Oosterbaan attended a meeting where defense counsel pitched against prosecution.
Key Quotes (3)
"The defendant’s failure to offer any evidence is fatal to her claim."Source
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Quote #1
"defense counsel made a pitch that Epstein should not be prosecuted."Source
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Quote #2
"USAO-SDFL intended to bind other districts, much less that the USAO-SDFL communicated a promise to Epstein that the NPA would extend beyond the USAO-SDFL."Source
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Quote #3
Full Extracted Text
Complete text extracted from the document (2,304 characters)
Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 38 of 239
would not, without more, establish that the USAO-SDFL intended to bind other districts, much
less that the USAO-SDFL communicated a promise to Epstein that the NPA would extend beyond
the USAO-SDFL. The defendant’s failure to offer any evidence is fatal to her claim.
less that the USAO-SDFL communicated a promise to Epstein that the NPA would extend beyond
the USAO-SDFL. The defendant’s failure to offer any evidence is fatal to her claim.
Although it is not the Government’s burden to address and rebut every innuendo or
conclusory statement in the defendant’s motion, it is significant here that the circumstances of the
NPA have been extensively litigated in a civil lawsuit, and have also been investigated by the
Department of Justice’s Office of Professional Responsibility (“OPR”), resulting in a report of
OPR’s findings (the “OPR Report”).6 The records of both matters provide no support for the
defendant’s claims.
conclusory statement in the defendant’s motion, it is significant here that the circumstances of the
NPA have been extensively litigated in a civil lawsuit, and have also been investigated by the
Department of Justice’s Office of Professional Responsibility (“OPR”), resulting in a report of
OPR’s findings (the “OPR Report”).6 The records of both matters provide no support for the
defendant’s claims.
The OPR Report notes that the USAO-SDFL periodically consulted with the Chief of the
Department of Justice Child Exploitation and Obscenity Section (“CEOS”), Andrew Oosterbaan,
during the investigation and plea discussions, and that the CEOS Chief attended a meeting with
defense counsel, during which defense counsel made a pitch that Epstein should not be prosecuted.
November 2020 Report, United States Department of Justice, Office of Professional
Responsibility, at 61-62. However, although the line prosecutor, Maria Villafaña, subsequently
sent the CEOS Chief a draft of the NPA, the OPR Report reflects that the CEOS Chief reported to
Department of Justice Child Exploitation and Obscenity Section (“CEOS”), Andrew Oosterbaan,
during the investigation and plea discussions, and that the CEOS Chief attended a meeting with
defense counsel, during which defense counsel made a pitch that Epstein should not be prosecuted.
November 2020 Report, United States Department of Justice, Office of Professional
Responsibility, at 61-62. However, although the line prosecutor, Maria Villafaña, subsequently
sent the CEOS Chief a draft of the NPA, the OPR Report reflects that the CEOS Chief reported to
6 The defendant’s motion cites to the executive summary of the OPR Report. However, the entire
report is publicly available, is attached as Exhibit 3 hereto, and has been widely reported on and
published by the media. See, e.g., “Read the report: Investigation into the U.S. Attorney’s Office
for the Southern District of Florida’s Resolution of Its 2006–2008 Federal Criminal Investigation
of Jeffrey Epstein and Its Interactions with Victims during the Investigation,” Wash. Post (Nov.
12, 2020), https://www.washingtonpost.com/context/read-the-report-investigation-into-the-u-s-
attorney-s-office-for-the-southern-district-of-florida-s-resolution-of-its-2006-2008-federal-
criminal-investigation-of-jeffrey-epstein-and-its-interactions-with-victims-during-the-
investigation/db9373e8-22f8-4712-b4a7-be844d162de0/.
report is publicly available, is attached as Exhibit 3 hereto, and has been widely reported on and
published by the media. See, e.g., “Read the report: Investigation into the U.S. Attorney’s Office
for the Southern District of Florida’s Resolution of Its 2006–2008 Federal Criminal Investigation
of Jeffrey Epstein and Its Interactions with Victims during the Investigation,” Wash. Post (Nov.
12, 2020), https://www.washingtonpost.com/context/read-the-report-investigation-into-the-u-s-
attorney-s-office-for-the-southern-district-of-florida-s-resolution-of-its-2006-2008-federal-
criminal-investigation-of-jeffrey-epstein-and-its-interactions-with-victims-during-the-
investigation/db9373e8-22f8-4712-b4a7-be844d162de0/.
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DOJ-OGR-00002972
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