DOJ-OGR-00021758.jpg
Extracted Text (OCR)
Case 22-1426, Document 87, 07/27/2023, 3548202, Page16 of 35
agreement. SA100, SA105 fn.122. However, that language, limiting co-conspirator
immunity to the Southern District of Florida, was removed from the final signed
NPA. SA166-167fn.237, fn.239, & fn.240. The intentional excision of this limiting
language from the draft version of the co-conspirator clause establishes that that
limitation was not intended to apply to the co-conspirator clause. Indeed, it is
difficult to imagine any clearer evidence than the purposeful removal of that limiting
language, especially as it is replaced by the term “United States.” And to punctuate
this point, the U.S. Attorney himself as part of a final review and edit of the NPA,
instructed the line prosecutor to restore the reference to Epstein’s desire to reach a
global agreement of his State and Federal criminal liabilities. SA110.
The Government denies that Main Justice was involved in the plea
negotiations. Br. 22. But the OPR demonstrates that Andrew C. Lourie, Deputy
Assistant Attorney General for the Department’s Criminal Division and Chief of
Staff to Assistant Attorney General Alice Fisher, was actively participating in a
critical phase of plea negotiations in September “from his new post at the
Department in Washington, DC.” SA101. After his transfer, he continued to be
consulted on the negotiations and apprised of their status. He repeatedly rendered
opinions, trying to close the deal involving a plea agreement and the NPA (SA106,
110). On September 24, 2007, Lourie, now stationed in Washington D.C. at Main
DOJ-OGR-00021758
Extracted Information
Document Details
| Filename | DOJ-OGR-00021758.jpg |
| File Size | 672.2 KB |
| OCR Confidence | 95.0% |
| Has Readable Text | Yes |
| Text Length | 1,601 characters |
| Indexed | 2026-02-03 20:16:52.089173 |