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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. DOJ-OGR-00021681

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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