reach of the Non-Prosecution Agreement 2. Reply Memorandum in Support of Motion to Dismiss Counts One through Four of the Superseding Indictment as Time-Barred 3. Reply Memorandum in Support of Motion Under the Due Process Clause to Suppress All Evidence Obtained from the Government's Subpoena to and to

Ghislaine Maxwell respectfully submits this Memorandum in Support of her Motion to Dismiss Counts One Through Four of the Superseding Indictment as Time-Barred ("Motion"). The government's late-discovered zeal to attempt to prosecute Ms. Maxwell has forced it to reach back more than 25 years and bring char