This memorandum supports Ghislaine Maxwell's motion to dismiss the superseding indictment, arguing that the indictment violates the terms of a Non-Prosecution Agreement (NPA) made with Jeffrey Epstein. The document outlines the structure and negotiation of the NPA, arguing that it provides immunity to potential co-conspirators like Maxwell. It challenges the government's interpretation of the NPA and requests dismissal of the indictment or, alternatively, discovery and an evidentiary hearing.
documents/EFTA00065989.pdf
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