{
  "document_metadata": {
    "page_number": "33",
    "document_number": "142",
    "date": "02/04/21",
    "document_type": "court document",
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  "full_text": "Case 1:20-cr-00330-AJN Document 142 Filed 02/04/21 Page 33 of 38 courts/ghislain-maxwell-arrested-jeffrey-epstein-aide/2495762/). And the government has acknowledged, by omission, that one of the three alleged victims referenced in the current indictment was interviewed by the USAO for the SDFL. See Reply Mem. at 6 (\"two of the victims referenced in the Indictment were never approached or interviewed by the SDFL\"). As noted above, Epstein and his counsel sought to prevent prosecution against his putative co-conspirators to the maximum extent possible. Had the government intended to limit that protection to a specific time period or to violations of specific statutes, it could have done so. It did not. Thus, by charging Ms. Maxwell with conduct in which she allegedly engaged as part of a conspiracy with Epstein—conduct that predates the NPA—the government has violated the NPA. In sum, none of the three arguments proffered by the government regarding the applicability of the NPA is meritorious. Ms. Maxwell is a third-party beneficiary of the NPA with standing to enforce the co-conspirator immunity provision. The co-conspirator immunity provision binds all USAOs and is not limited to the SDFL. It imposes no limitation on the scope of covered conduct—and even if it did, the conduct alleged here would be covered. At most, the co-conspirator immunity provision is ambiguous, and thus must be construed against the government. Because the co-conspirator immunity provision bars the government's prosecution of Ms. Maxwell on charges arising out of her alleged conspiracy with Epstein, the indictment should be dismissed. II. In the Alternative, the Court Should Permit Discovery and Conduct an Evidentiary Hearing Regarding the Parties' Intent. The language of the NPA and the facts submitted herewith are more than sufficient for the Court to find that the NPA bars the prosecution of Ms. Maxwell, particularly when any 28 DOJ-OGR-00002605",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 142 Filed 02/04/21 Page 33 of 38",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "courts/ghislain-maxwell-arrested-jeffrey-epstein-aide/2495762/). And the government has acknowledged, by omission, that one of the three alleged victims referenced in the current indictment was interviewed by the USAO for the SDFL. See Reply Mem. at 6 (\"two of the victims referenced in the Indictment were never approached or interviewed by the SDFL\"). As noted above, Epstein and his counsel sought to prevent prosecution against his putative co-conspirators to the maximum extent possible. Had the government intended to limit that protection to a specific time period or to violations of specific statutes, it could have done so. It did not. Thus, by charging Ms. Maxwell with conduct in which she allegedly engaged as part of a conspiracy with Epstein—conduct that predates the NPA—the government has violated the NPA.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "In sum, none of the three arguments proffered by the government regarding the applicability of the NPA is meritorious. Ms. Maxwell is a third-party beneficiary of the NPA with standing to enforce the co-conspirator immunity provision. The co-conspirator immunity provision binds all USAOs and is not limited to the SDFL. It imposes no limitation on the scope of covered conduct—and even if it did, the conduct alleged here would be covered. At most, the co-conspirator immunity provision is ambiguous, and thus must be construed against the government. Because the co-conspirator immunity provision bars the government's prosecution of Ms. Maxwell on charges arising out of her alleged conspiracy with Epstein, the indictment should be dismissed.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "II. In the Alternative, the Court Should Permit Discovery and Conduct an Evidentiary Hearing Regarding the Parties' Intent.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "The language of the NPA and the facts submitted herewith are more than sufficient for the Court to find that the NPA bars the prosecution of Ms. Maxwell, particularly when any",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "28",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002605",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein",
      "Ms. Maxwell"
    ],
    "organizations": [
      "USAO",
      "SDFL",
      "DOJ"
    ],
    "locations": [],
    "dates": [
      "02/04/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "142",
      "DOJ-OGR-00002605"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ghislaine Maxwell, with a clear and legible format. The text is well-structured and divided into sections. There are no visible redactions or damage to the document."
}