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Case 22-1426, Document 59, 02/28/2023, 3475902, Paged1 of 113 intended to insulate defendants from prosecution which they had no reason to foresee.”), aff'd, 867 F.2d 1425 (2d Cir. 1988). Unlike standard non-prosecution agreements, the NPA here was heavily negotiated. Negotiations began in January 2007, lasted for a period of eight months, and were “extensive” and involved the Department of Justice. The parties exchanged several drafts of an alternative plea agreement under which Epstein would have pled guilty to a federal offense. See, e.g., Dkt 142, Exh. E (9/15/07 email from Villafana to Lefkowitz attaching draft information and plea agreement); Dkt 142, Exh. F (draft plea agreement). Notably, those drafts of the plea agreement, unlike the NPA, expressly defined the term “United States” as limited to the United States Attorney for the SDFL. The Office of Professional Responsibility’s Report of the USAO-SDFL’s resolution of its 2006-2008 investigation of Epstein (““OPR”) (Dkt 142, Exh. A), reflects that negotiations involved the entire hierarchy of the USAO for the SDFL, all of whom signed off on the NPA. Senior levels of Main Justice were directly involved in the negotiation and approval of the NPA, even to the extent that separate presentations regarding the NPA were made to, and approval of the NPA was obtained from, the Office of the Deputy Attorney General. Further, the NPA itself reflects the involvement of the FBI. A174; Dkt 142, Exh. A at 1-2, 94-97, 103-18. 36 DOJ-OGR- 00021098