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10 See, e.g., United States v. Andreas, 216 F.3d 645, 663 (7th Cir. 2000) (providing that individuals who are not parties to a plea agreement may enforce it, like other third-party beneficiaries, when the original parties intended the contract to directly benefit them as third parties). Petitioner’s alleged status as Epstein’s co-conspirator was the entire basis of her prosecution. The NPA’s language demonstrates that the parties anticipated that there were additional co-conspirators beyond those already known. By using “including but not limited to” before naming some individuals, the government knowingly extended the benefit of the bargain to other unnamed individuals who partici- pated in Epstein’s offenses. Whether the government attorneys personally knew the identities of every such person is beside the point; they certainly knew there could be others (hence the language). Ghislaine Maxwell’s name was well known to Epstein’s circle and was referenced in public reporting at the time of the NPA. But even if she had been entirely unknown, the broad language of the NPA evidences an intent to cover whoever might later be deemed a co-conspirator. Accordingly, Petitioner can rely on the immunity clause in the NPA. See, e.g., United States v. Florida West Intl Airways, 853 F.Supp.2d 1209, 1228 (S.D. Fla. 2012) (dismissing indictment against employee who fell within the class of employees described in plea agreement). The government’s suggestion that it would have drafted the agreement differently had it specifically had Petitioner in mind is both unprovable and irrelevant. If anything, the inclusion of specific names alongside a general category shows the parties knew some of the players and also wanted to cover any DOJ-OGR- 00000254