This memorandum supports Ghislaine Maxwell's motion to dismiss the superseding indictment for breach of a non-prosecution agreement (NPA) with Jeffrey Epstein. It argues that the NPA, negotiated in 2007, provides immunity to Epstein's potential co-conspirators, including Maxwell, and should prevent her prosecution. The document details the NPA's terms, the government's alleged breach, and requests dismissal of the indictment or, alternatively, discovery and an evidentiary hearing.
documents/EFTA00099352.pdf
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