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This document is a Reply Memorandum filed by Ghislaine Maxwell's defense team on March 15, 2021, supporting her motion to dismiss the indictment based on the Non-Prosecution Agreement (NPA) Jeffrey Epstein signed in Florida. Maxwell argues that the NPA's clause immunizing 'potential co-conspirators of Epstein' explicitly covers her and bars the current prosecution in the Southern District of New York. The defense contends that the government's attempt to limit the NPA geographically (to Florida) or to specific crimes is contradicted by the plain text of the agreement and legal precedent regarding plea agreements.