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624 KB
Extraction Summary
3
People
4
Organizations
1
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal brief / court filing (appellate)
File Size:
624 KB
Summary
This document is page 27 of a legal filing (dated June 29, 2023) in the case against Ghislaine Maxwell. It argues that the District Court (Judge Nathan) correctly denied Maxwell's motions to dismiss without a hearing because the terms of Jeffrey Epstein's Non-Prosecution Agreement (NPA) with the Southern District of Florida were clear and did not bar Maxwell's prosecution. A footnote clarifies that even if the NPA applied, it would only cover specific counts (Count Six) and not others (Counts Three and Four) involving different victims and time periods.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant/Appellant |
Argues the District Court erred by denying motions to dismiss; claims protection under Epstein's NPA.
|
| Jeffrey Epstein | Deceased/Co-conspirator |
Mentioned regarding his Non-Prosecution Agreement (NPA) with USAO-SDFL.
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| Judge Nathan | Judge |
District Court judge who denied Maxwell's motions to dismiss and declined an evidentiary hearing.
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Organizations (4)
| Name | Type | Context |
|---|---|---|
| USAO-SDFL |
United States Attorney's Office for the Southern District of Florida; party to Epstein's NPA.
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| District Court |
The lower court that denied the motions.
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| OPR |
Office of Professional Responsibility; produced a report on the NPA's negotiation history.
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| U.S. Attorney’s Offices |
Federal prosecutorial offices generally.
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Timeline (2 events)
Unknown (Past)
Locations (1)
| Location | Context |
|---|---|
|
Jurisdiction where Epstein's NPA was signed (implied by USAO-SDFL).
|
Relationships (2)
Reference to the 'co-conspirator provision' in the NPA and Maxwell's attempt to use Epstein's NPA for immunity.
Discussion of whether USAO-SDFL immunized Maxwell via Epstein's NPA.
Key Quotes (4)
"Thus, Epstein’s NPA with the USAO-SDFL does not bar this prosecution of Maxwell, and Judge Nathan correctly denied the motions to dismiss."Source
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Quote #1
"the cases cited by Maxwell in support of her request for a hearing “mostly involved oral agreements where there was no written record of the full set of terms reached by the parties,”"Source
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Quote #2
"This is no such case. The NPA’s terms are clear."Source
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Quote #3
"Maxwell’s suggestion that the co-conspirator provision “is not limited to any particular offense or any time period” (Br.40) is based on the premise that the USAO-SDFL immunized Maxwell for any and all crimes, past or future"Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (1,541 characters)
Case 22-1426, Document 79, 06/29/2023, 3536060, Page40 of 93
27
Thus, Epstein’s NPA with the USAO-SDFL does not bar this prosecution of Maxwell, and Judge Nathan correctly denied the motions to dismiss.6
3. The District Court Did Not Abuse Its Discretion in Declining to Conduct a Hearing
Finally, Maxwell argues that the District Court erred by denying her motions to dismiss without an evidentiary hearing. (Br.38-40). But as Judge Nathan explained, the cases cited by Maxwell in support of her request for a hearing “mostly involved oral agreements where there was no written record of the full set of terms reached by the parties,” and all of which “involved defendants with first-hand knowledge of the negotiations.... This is no such case. The NPA’s terms are clear.” (A.145). Furthermore, Maxwell had “an unusually large amount of information about the NPA’s negotiation history in the form of the OPR report yet
6 Even if the NPA were deemed to apply here, it would only cover Count Six, which concerns a victim known to USAO-SDFL and a statute mentioned in the NPA, and not Counts Three and Four, which concern different or additional victims and offenses over an expanded time period. Maxwell’s suggestion that the co-conspirator provision “is not limited to any particular offense or any time period” (Br.40) is based on the premise that the USAO-SDFL immunized Maxwell for any and all crimes, past or future, and highlights the unreasonableness of reading the NPA to apply to other U.S. Attorney’s Offices.
DOJ-OGR-00021687
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