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Case 22-1426, Document 117, 11/01/2024, 3636586, Page9 of 51 limitation were negotiated. SA78. Relying on the NPA, Epstein pled guilty in state court on June 30, 2008, and fulfilled all his promises. SA137. In July of 2019, Epstein was indicted in the SDNY on charges of sex trafficking and conspiracy related to conduct in Florida and New York between 2003 and 2005. He died by suicide on August 10, 2019. One year later, Maxwell was indicted. Initially, Maxwell was charged with crimes in the 1994 to 1997 timeframe, in an apparent effort to circumvent the time frame covered by the NPA. However, on March 29, 2021, the SDNY added in its superseding indictment, a sex trafficking offense (Count Six) related to conduct and offenses wholly within the timeframe and subject matter covered by the NPA and contained in the proposed indictment in SDFL that was resolved by the NPA. A114. Doc 293 at p10 as referenced in A45. Maxwell moved to dismiss the indictment based on the clear language of the NPA. Alternatively, in the event that the court determined that the language of the NPA was ambiguous, Maxwell, who was not a party to the agreement, sought discovery and a hearing to establish affirmative evidence of intent to bind other districts consistent with the plain language in the co-conspirator clause. Her motion was denied without a hearing or discovery. > A145. The District Court found that 8 While the District Court did not order discovery, it did order the government to disclose to Maxwell “any evidence supporting a defense under the NPA.” A145. The government responded DOJ-OGR-00021833