This memorandum argues against invalidating Jeffrey Epstein's Non-Prosecution Agreement (NPA) as a remedy for a CVRA violation. It emphasizes the constitutional requirement for the government to adhere to plea bargains and NPAs, highlighting Epstein's full compliance with the NPA terms. The document discusses the implications of equitable and judicial estoppel, noting that petitioners previously relied on the NPA to establish liability in civil cases. It also argues that the CVRA cannot invalidate executive discretion in entering NPAs, stressing the potential negative consequences of invalidating such agreements.
documents/EFTA00812291.pdf
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