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Document 148-5

AI Analysis

Summary: This document is an exhibit filed in the case against Ghislaine Maxwell, listing the defense's requests for documents related to the Non-Prosecution Agreement negotiations between the government and Jeffrey Epstein, as well as communications between government agencies and attorneys for accusing witnesses. The requests cover a range of topics, including meetings between SDNY prosecutors and attorneys for accusing witnesses in 2016 and 2018.
Significance: This document is potentially important as it reveals the scope of the defense's requests for documents related to the NPA negotiations and meetings between SDNY prosecutors and attorneys for accusing witnesses, which may be relevant to the case against Ghislaine Maxwell.
Key Topics: Non-Prosecution Agreement (NPA) negotiations between the government and Jeffrey Epstein Communications between government agencies and attorneys for accusing witnesses Meetings between SDNY prosecutors and attorneys for accusing witnesses regarding Epstein and Maxwell
Key People:
  • Jeffrey Epstein - Subject of the Non-Prosecution Agreement and criminal investigation
  • Ghislaine Maxwell - Associate of Epstein and subject of the SDNY investigation
  • Bradley Edwards - Attorney for accusing witnesses
  • David Boies - Attorney for accusing witnesses
Document Type
Exhibit
Date
02/04/21
Pages
2
Folder
IMAGES001

Full Text

Case 1:20-cr-00330-AJN Document 148-5 Filed 02/04/21 Page 1 of 2 Exhibit E DOJ-OGR-00002724 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 148-5 Filed 02/04/21 Page 2 of 2 DOCUMENTS RELATED TO DEFENSE MOTIONS 1. All written and oral communications concerning the negotiations relating to the Non-Prosecution Agreement ("NPA") signed by Jeffrey Epstein on September 24, 2007. Such communications include: a. All communications between the government - including, but not limited to, attorneys and staff at the U.S. Attorney's Office for the Southern District of Florida, the United States Attorney's Office for Southern District of New York, the Department of Justice, state prosecutor's offices, the FBI, and any other federal and state investigative agencies - and Mr. Epstein's attorneys. b. All communications between and among any government employees including, but not limited to, attorneys and staff at the U.S. Attorney's Office for the Southern District of Florida, the United States Attorney's Office for Southern District of New York, the Department of Justice, state prosecutor's offices, the FBI, and any other federal and state investigative agencies. c. Unredacted copies of all emails and other correspondence between the government and Mr. Epstein's attorneys concerning the negotiation of the NPA, previously produced by the government on August 13, 2020. See, e.g., SDNY_GM_00134069 et seq. 2. All written and oral communications and other documents concerning any meetings between the attorneys for the accusing witnesses-including, but not limited to, Bradley Edwards, David Boies, Sigrid McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, Spencer Kuvin, and Jack Scarola (the "Attorneys")-and prosecutors and staff from the United States Attorney's Office for the Southern District of New York ("SDNY") concerning Jeffrey Epstein and/or Ghislaine Maxwell. a. This request includes all communications and documents related to any meetings that took place in or about 2016 in which certain of the Attorneys met with SDNY prosecutors to ask SDNY to initiate a criminal investigation into Mr. Epstein and Ms. Maxwell. See New York Daily News, "Manhattan Federal Prosecutors Declined to Pursue Jeffrey Epstein and Ghislaine Maxwell in 2016: Sources" (Oct. 13, 2020), https://www.nydailynews.com/new-york/ny-jeffrey-epstein-maxwell-case-20201013-imzh7lzdrzdgrbbs7vc6bfnszu-story.html; see also Bradley J. Edwards, Relentless Pursuit: My Fight for the Victims of Jeffrey Epstein, at 281. b. This request also includes all communications and documents related to any meetings between any of the Attorneys and SDNY prosecutors and staff concerning or relating to Mr. Epstein and/or Ms. Maxwell that took place in or about 2018, when the government asserts that it began the SDNY investigation into this case (see Dkt. 63), or at any time thereafter. 1948992.1 DOJ-OGR-00002725

Individual Pages

Page 1 - DOJ-OGR-00002724
Case 1:20-cr-00330-AJN Document 148-5 Filed 02/04/21 Page 1 of 2 Exhibit E DOJ-OGR-00002724
Page 2 of 2 - DOJ-OGR-00002725
Case 1:20-cr-00330-AJN Document 148-5 Filed 02/04/21 Page 2 of 2 DOCUMENTS RELATED TO DEFENSE MOTIONS 1. All written and oral communications concerning the negotiations relating to the Non-Prosecution Agreement ("NPA") signed by Jeffrey Epstein on September 24, 2007. Such communications include: a. All communications between the government - including, but not limited to, attorneys and staff at the U.S. Attorney's Office for the Southern District of Florida, the United States Attorney's Office for Southern District of New York, the Department of Justice, state prosecutor's offices, the FBI, and any other federal and state investigative agencies - and Mr. Epstein's attorneys. b. All communications between and among any government employees including, but not limited to, attorneys and staff at the U.S. Attorney's Office for the Southern District of Florida, the United States Attorney's Office for Southern District of New York, the Department of Justice, state prosecutor's offices, the FBI, and any other federal and state investigative agencies. c. Unredacted copies of all emails and other correspondence between the government and Mr. Epstein's attorneys concerning the negotiation of the NPA, previously produced by the government on August 13, 2020. See, e.g., SDNY_GM_00134069 et seq. 2. All written and oral communications and other documents concerning any meetings between the attorneys for the accusing witnesses-including, but not limited to, Bradley Edwards, David Boies, Sigrid McCawley, Peter Skinner, Stanley Pottinger, Paul Cassell, Spencer Kuvin, and Jack Scarola (the "Attorneys")-and prosecutors and staff from the United States Attorney's Office for the Southern District of New York ("SDNY") concerning Jeffrey Epstein and/or Ghislaine Maxwell. a. This request includes all communications and documents related to any meetings that took place in or about 2016 in which certain of the Attorneys met with SDNY prosecutors to ask SDNY to initiate a criminal investigation into Mr. Epstein and Ms. Maxwell. See New York Daily News, "Manhattan Federal Prosecutors Declined to Pursue Jeffrey Epstein and Ghislaine Maxwell in 2016: Sources" (Oct. 13, 2020), https://www.nydailynews.com/new-york/ny-jeffrey-epstein-maxwell-case-20201013-imzh7lzdrzdgrbbs7vc6bfnszu-story.html; see also Bradley J. Edwards, Relentless Pursuit: My Fight for the Victims of Jeffrey Epstein, at 281. b. This request also includes all communications and documents related to any meetings between any of the Attorneys and SDNY prosecutors and staff concerning or relating to Mr. Epstein and/or Ms. Maxwell that took place in or about 2018, when the government asserts that it began the SDNY investigation into this case (see Dkt. 63), or at any time thereafter. 1948992.1 DOJ-OGR-00002725