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865 KB
Extraction Summary
5
People
3
Organizations
1
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal filing (government opposition brief/memorandum)
File Size:
865 KB
Summary
This document is a page from a Government legal filing opposing Ghislaine Maxwell's motion to dismiss her indictment. The Government argues that the Non-Prosecution Agreement (NPA) signed by Jeffrey Epstein in Florida cannot logically grant Maxwell immunity for future crimes (specifically perjury) committed a decade later, nor grant her broader immunity than Epstein himself received. A footnote clarifies the scope of the original Florida investigation, noting that while Minor Victim-2 was interviewed then, Minor Victims 1 and 3 were not interviewed and did not speak to law enforcement until 2019.
People (5)
| Name | Role | Context |
|---|---|---|
| Jeffrey Epstein | Deceased Financier / Original Defendant |
Negotiated the NPA; document argues his co-conspirators cannot have broader immunity than he did.
|
| Ghislaine Maxwell | Defendant |
Referred to as 'The defendant' and 'Ms. Maxwell'; seeking dismissal of indictment based on Epstein's NPA.
|
| Minor Victim-1 | Victim |
Not interviewed by USAO-SDFL; agreed to speak with law enforcement in 2019.
|
| Minor Victim-2 | Victim |
Interviewed by USAO-SDFL.
|
| Minor Victim-3 | Victim |
Not interviewed by USAO-SDFL; agreed to speak with law enforcement in 2019.
|
Timeline (2 events)
2019
Minor Victim-1 and Minor Victim-3 agreed to speak with law enforcement.
Unknown
Unknown (Past)
Locations (1)
| Location | Context |
|---|---|
|
Jurisdiction of the original Epstein investigation (USAO-SDFL).
|
Relationships (2)
Maxwell is attempting to use the 'co-conspirator' provision in Epstein's NPA for immunity.
Document states USAO-SDFL interviewed Minor Victim-2.
Key Quotes (4)
"it would be exceedingly strange to interpret the “co-conspirator” provision to extend broader immunity than Epstein negotiated for himself."Source
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Quote #1
"the defendant seems to claim that the NPA immunized her for future crimes including, for example, perjury offenses that she is charged with committing almost a decade after the NPA was executed."Source
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Quote #2
"Ms. Maxwell respectfully requests that the Court dismiss the indictment."Source
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Quote #3
"Minor Victim-1 and Minor Victim-3 were never interviewed by the USAO-SDFL, and they did not agree to speak with law enforcement until 2019."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,640 characters)
Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 43 of 239
offenses enumerated in the NPA.9 While these same limitations are not repeated in the provision
that purports to immunize “co-conspirators,” these limitations apply with equal force across the
agreement, because that is the only common-sense way to read the NPA. Indeed, as noted
above in a related context, it would be exceedingly strange to interpret the “co-conspirator”
provision to extend broader immunity than Epstein negotiated for himself.
that purports to immunize “co-conspirators,” these limitations apply with equal force across the
agreement, because that is the only common-sense way to read the NPA. Indeed, as noted
above in a related context, it would be exceedingly strange to interpret the “co-conspirator”
provision to extend broader immunity than Epstein negotiated for himself.
The defendant may assert that the “co-conspirator” provision has absolutely no limitations,
but such an argument would lead to absurd results. In particular, in arguing that the “co-
conspirator” provision lacks any temporal or statutory limitations whatsoever, the defendant seems
to claim that the NPA immunized her for future crimes including, for example, perjury offenses
that she is charged with committing almost a decade after the NPA was executed. (Def. Mot. 1 at
32 (“For the foregoing reasons, Ms. Maxwell respectfully requests that the Court dismiss the
indictment.”)). Although the defendant does not highlight this point in her motion—perhaps
recognizing how absurd it would be—that is the natural consequence of her illogical interpretation
of the NPA. Despite advancing an argument that strains common sense, the defendant cites no
case in which a court has interpreted a plea agreement to bar prosecution for crimes that pre- or
post-dated the period covered by the agreement. The Government is aware of no such authority.
See United States v. Hallahan, 756 F.3d 962, 974 (7th Cir. 2014) (rejecting defense argument that
plea agreement barred prosecution for subsequent bail jumping, and, in interpreting the
but such an argument would lead to absurd results. In particular, in arguing that the “co-
conspirator” provision lacks any temporal or statutory limitations whatsoever, the defendant seems
to claim that the NPA immunized her for future crimes including, for example, perjury offenses
that she is charged with committing almost a decade after the NPA was executed. (Def. Mot. 1 at
32 (“For the foregoing reasons, Ms. Maxwell respectfully requests that the Court dismiss the
indictment.”)). Although the defendant does not highlight this point in her motion—perhaps
recognizing how absurd it would be—that is the natural consequence of her illogical interpretation
of the NPA. Despite advancing an argument that strains common sense, the defendant cites no
case in which a court has interpreted a plea agreement to bar prosecution for crimes that pre- or
post-dated the period covered by the agreement. The Government is aware of no such authority.
See United States v. Hallahan, 756 F.3d 962, 974 (7th Cir. 2014) (rejecting defense argument that
plea agreement barred prosecution for subsequent bail jumping, and, in interpreting the
9 By its plain terms, the NPA did not immunize Epstein for his “background,” as the defendant
suggests. (Def. Mot. 1 at 27). This provision refers, instead, to a list of “offenses” under federal
law. Indeed, it is unclear how any plea agreement could immunize a defendant’s “background.”
Similarly, the fact that the USAO-SDFL interviewed Minor Victim-2 does not mean that this case
“arose out of” the USAO-SDFL investigation, an assertion the defendant’s motion does not explain
or support with evidence. As the Indictment makes clear, the events underpinning the Indictment
involve multiple victims and specific legal charges that were not within the scope of the USAO-
SDFL investigation. As discussed in greater detail below, Minor Victim-1 and Minor Victim-3
were never interviewed by the USAO-SDFL, and they did not agree to speak with law enforcement
until 2019.
suggests. (Def. Mot. 1 at 27). This provision refers, instead, to a list of “offenses” under federal
law. Indeed, it is unclear how any plea agreement could immunize a defendant’s “background.”
Similarly, the fact that the USAO-SDFL interviewed Minor Victim-2 does not mean that this case
“arose out of” the USAO-SDFL investigation, an assertion the defendant’s motion does not explain
or support with evidence. As the Indictment makes clear, the events underpinning the Indictment
involve multiple victims and specific legal charges that were not within the scope of the USAO-
SDFL investigation. As discussed in greater detail below, Minor Victim-1 and Minor Victim-3
were never interviewed by the USAO-SDFL, and they did not agree to speak with law enforcement
until 2019.
16
DOJ-OGR-00002977
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