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Discovery has revealed that during these negotiations, several drafts of the NPA were exchanged. See, e.g., Exh. C (9/17/07 email from Villafana to Lefkowitz attaching draft NPA); Exh. D (9/21/07 email from Villafana to Lefkowitz attaching draft NPA). In addition, the parties exchanged several drafts of
him to benefit third- parties," and therefore the defendant was a third-party beneficiary with standing to enforce the agreement. Id. at 609. Both Florida West and EI-Sadig illustrate how the government's argument that Ms. Maxwell lacks standing to enforce the NPA is contrary to bedrock principles of contra
Discovery has revealed that during these negotiations, several drafts of the NPA were exchanged. See, e.g., Exh. C (9/17/07 email from Villafana to Lefkowitz attaching draft NPA); Exh. D (9/21/07 email from Villafana to Lefkowitz attaching draft NPA). In addition, the parties exchanged several drafts of
him to benefit third- parties," and therefore the defendant was I third-party beneficiary with standing to enforce the agreement. Id. at 609. Both Florida West and EI-Sadig illustrate how the government's argument that Ms. Maxwell lacks standing to enforce the NPA is contrary to bedrock principles of contra
hree courts have applied the third-party beneficiary doctrine to confer standing on third parties to enforce immunity provisions in plea agreements. Florida West, 853 F. Supp. 2d at 1228; El- Sadig, 133 F. Supp. 2d at 608-09; United States v. CFWConst Co., 583 F. Supp. 197, 203 (D.S.C. 1984), aff'd, 749 F.2d
Page: EFTA00028889 →submitted an affidavit from Epstein's counsel, defense counsel notes that it has made several unsuccessful attempts to obtain information from Jay Lelkowitz, the attorney who was principally involved in negotiating the language of the NPA on Epstein's behalf. 17 EFTA00028900 --- PAGE BREAK --- CONCLU
Page: EFTA00028901 →Entities connected to both Jay Lefkowitz and Florida West

Jeffrey Epstein
PERSON
Alexander Acosta
PERSON
A. Marie Villafana
PERSON
United States
LOCATION
Department of Justice
ORGANIZATIONJane Doe
PERSON
Ken Starr
PERSONMartin Weinberg
PERSON
Bradley Edwards
PERSONthe Southern District
LOCATION
George W. Bush
PERSON
Prince Andrew
PERSON
Lesley Groff
PERSONFBI
ORGANIZATIONDarren Indyke
PERSONMaria Farmer
PERSON
Scarlett Johansson
PERSON
Ghislaine Maxwell
PERSONLourie
PERSON
Virginia Giuffre
PERSON