3 This co-conspirator clause, containing no geographic limitation on where in the United States it could be enforced, was actively negotiated at the same time as the terms of Epstein’s protection for his own criminal prosecution, which was expressly limited to a bar on prosecutions in the Southern District of Florida only (App.26). A previous version of the co-conspirator language limited it to the Southern District of Florida before it was amended to refer more broadly to the “United States,” and the co-conspirator clause was relocated in the document. (App.95, 108-126). The NPA also contained an express recitation that it was not binding on the State Attorney’s office in Florida (App.30), but it contained no such recitation setting forth that it was not binding on other United States Attorney’s offices. Relying on the NPA, Epstein pleaded guilty in Florida state court on June 30, 2008, and fulfilled all his obligations under the NPA. B. Criminal Proceedings in the District Court. In July 2019, Epstein was indicted in the Southern District of New York on charges of sex trafficking and conspiracy related to conduct in Florida and New York between 2003 and 2005. The NPA did not pose an impediment to this indictment because Epstein’s protection therein had been limited to charges brought in the Southern District of Florida. Epstein died while incarcerated on August 10, 2019. One year later, after Epstein died in jail, Ghislaine Maxwell was indicted in the Southern District of New York for her alleged actions as a co-conspirator of Epstein, on charges that were the same as had been brought against Epstein. Initially, Maxwell was charged with crimes in the 1994 to 1997 timeframe, DOJ-OGR-00000045