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Case 22-1426, Document 87, 07/27/2023, 3548202, Page14 of 35
Cir 1976). The OPR* (SA1-348) contains just such evidence of the negotiations
between the Government and Epstein’s counsel which, in corroborating an intent on
the part of the parties to draft a co-conspirator clause that provided broader
immunity, accords with the plain meaning of the NPA. This is so, notwithstanding
that the OPR relies almost exclusively on the distant recollection of government
employees whose judgment and professionalism were being questioned with little to
no input from Epstein’s attorneys as to who or what they intended or understood the
co-conspirator clause of the NPA to cover. See SA166.
The Government questions why Epstein would have sought a broader grant
of immunity for co-conspirators than for himself. Br.21. But the answer is provided
in the OPR. The line prosecutor remembered that defense counsel told her that
“Epstein wanted to make sure that he’s the only one who takes the blame for what
happened.” SA193. Indeed, the Government believed that Epstein’s conduct was his
own “dirty little secret” and did not have any specific evidence against Ms. Maxwell
even though they had interviewed Carolyn, the complainant in Count Six, and Annie
Farmer, two of the four women who testified at trial (SA193), and had also
4 The Department of Justice Office of Professional Responsibility investigated and
issued a report on the NPA (SA1-348) on issues tangential to the instant appeal, but
it provides a skeletal outline of the United States’ negotiation with a multitude of
Epstein’s counsel. In particular, the investigation was focused on “whether any of
the [Government actors were] influenced by corruption, bias, or other improper
motive...to include terms in the NPA that were favorable to Epstein.” SA166.
8
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Dates
Document Details
| Filename | DOJ-OGR-00021756.jpg |
| File Size | 755.8 KB |
| OCR Confidence | 95.2% |
| Has Readable Text | Yes |
| Text Length | 1,836 characters |
| Indexed | 2026-02-03 20:16:50.032670 |