Ghislaine Maxwell's legal team argues for the dismissal of certain counts in the S2 Superseding Indictment, citing a Non-Prosecution Agreement (NPA) that they claim bars prosecution on these counts. They also argue that prosecuting Maxwell on these counts would violate the Double Jeopardy Clause and that some counts are time-barred. The memorandum includes a request for a Bill of Particulars and the production of certain statements as Brady material.
documents/EFTA00103758.pdf
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