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Case 1:20-cr-00330-PAE Document 295 Filed 05/25/21 Page5 of 26 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK AR RE RR RRs Xx UNITED STATES OF AMERICA -V.- i S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. ec RRR SRE REET! x PRELIMINARY STATEMENT The Government respectfully submits this memorandum in opposition to the defendant’s supplemental pre-trial motions, dated May 7, 2021 (the “Defense Motions”). For the reasons that follow, and for the reasons set forth in the Government’s memorandum in opposition to the defendant’s twelve pre-trial motions, dated February 26, 2021, and the Court’s Opinion and Order, dated April 16, 2021 (Dkt. No. 207, the “April Opinion” or “Apr. Op.”), the Defense Motions should be denied in their entirety. First, the non-prosecution agreement between Jeffrey Epstein and the U.S. Attorney’s Office for the Southern District of Florida does not apply to this District and does not bar the prosecution of the defendant. Second, the Double Jeopardy Clause does not prohibit the prosecution of the defendant, who has never previously risked conviction for the sex trafficking offenses contained in Counts Five and Six of Indictment S2 20 Cr. 330 (the “S2 Indictment’). Third, Counts Five and Six of the S2 Indictment, which plainly involve the sexual abuse of minors, are timely under 18 U.S.C. § 3283, which provides an extended statute of limitations for such crimes. Fourth, the defendant’s claim that the Government delayed in bringing the S2 Indictment fails as a matter of law and fact. Fifth, the defendant’s motion to dismiss certain conspiracy counts DOJ-OGR-00004712