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Extracted Text (OCR)
Case 22-1426, Document 79, 06/29/2023, 3536060, Page34 of 93
21
the prosecution of co-conspirators without clearly say-
ing so.” (A.142).2
Maxwell also points to the NPA provision stating
that “Epstein seeks to resolve globally his state and
federal criminal liability.” (A.175). Based on that
statement, Maxwell argues that Epstein’s purpose in
negotiating the NPA was to “obtain a global resolution
that would, among other things, provide maximum
protection for any alleged co-conspirators.” (Br.34).
But the cited provision only says that Epstein sought
to resolve “his” liability, not anyone else’s. Further-
more, under Maxwell’s reading, Epstein bargained for
a truly “global” resolution only for his co-conspirators,
and limited his own “global” resolution expressly to the
USAO-SDFL. There is no reason to believe that Ep-
stein expressly sought and obtained broader immunity
for his co-conspirators than he did for himself. (See
also SA107 n.125 (observing that a supervisor at the
USAO-SDFL “pointed out that the NPA was not a
3 Maxwell also relies on draft plea agreements
which “expressly defined the term ‘United States’ as
limited to” USAO-SDFL. Those plea agreements—
which differed significantly from the NPA—also use
both the terms “United States” and “United States At-
torney’s Office for the Southern District of Florida,” in-
cluding using the USAO-SDFL term expressly in the
context of the co-conspirator provision. (See, e.g.,
Dkt.142, Ex. F at 2). This point only highlights the par-
ties’ understanding at all times that their negotiations
merely bound the USAO-SDFL, and not the entire fed-
eral government.
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Extracted Information
Dates
Document Details
| Filename | DOJ-OGR-00021681.jpg |
| File Size | 664.4 KB |
| OCR Confidence | 94.7% |
| Has Readable Text | Yes |
| Text Length | 1,655 characters |
| Indexed | 2026-02-03 20:15:57.358354 |