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13 terms that will not bind other federal prosecutors or agencies without their consent” and “the attorney for the government should explicitly limit the scope of his/her agreement to non-prosecution within his/her district.” Justice Manual § 9-27.630.? Given this instruction, when Department attorneys choose to draft a broad agreement, the court should enforce it as written. The NPA’s broad language served the government’s strategy at the time of the agreement. The Court should not permit the government to escape that language, even if that strategy may seem unwise or unintelligible with the benefit of hindsight. CONCLUSION The Court should grant review in this case to resolve the conflict among the circuits identified by petitioner and hold the Department of Justice to its word. Respectfully submitted, JEFFREY T. GREEN SARA ELIZABETH KROPF Co-Chair Amicus Counsel of Record Committee Kropr MosELEY SCHMITT NATIONAL ASSOCIATION OF PLLC CRIMINAL DEFENSE Lawyers 1100 H Street NW 1600 L Street NW Suite 1220 Washington, DC 20036 Washington, DC 20005 (202) 627-6900 sara@kmlawfirm.com Counsel for Amicus Curiae 3. Available at https://www.justice.gov/jm/jm-9-27000- principles-federal-prosecution#9-27.330 (accessed May 5, 2025). DOJ-OGR-00000213