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Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 113 of 349 it had identified as victims.'*! The USAO, with the good faith approval of Epstein’s counsel, would select an attorney representative for the victims, whom Epstein would pay. Timing: Epstein would make his best efforts to enter his guilty plea and be sentenced by October 26, 2007. The USAO had no objection to Epstein self-reporting to begin serving his sentence by January 4, 2008. Immunity: The USAO would not initiate criminal charges against “any potential co-conspirator of Epstein,” including four named personal assistants. Other: Epstein was obligated to undertake discussions with the State Attorney’s Office to ensure compliance with this agreement. Epstein waived his right to appeal. Epstein agreed that he would not be afforded any benefits with respect to gain time or other rights, opportunities, and benefits not available to any other inmate. The federal investigation would be suspended and all pending legal process held in abeyance unless and until Epstein violated any term of the agreement. Evidence “requested by or directly related to” the pending legal process, “including certain computer equipment,” would be kept inviolate until all the NPA terms had been satisfied. Breach: The USAO would be required to notify Epstein of any alleged breach of the agreement within 90 days of the expiration of the term of home confinement, and would be required to initiate prosecution within 60 days thereafter. Disclosure: The parties “anticipate[d]” that the agreement would not be made part of any public record, and if the USAO received a Freedom of Information Act request or compulsory process commanding disclosure of the agreement, it would provide notice to Epstein before making any disclosure. !* That evening, Lefkowitz emailed Lourie to express concern about the notification he understood would be given to Chief Reiter, stating, “I am very concerned about leaks unduly prejudicing Jeffrey [Epstein] in the media.”'°? He added, “I have enjoyed working with you on He The USAO had not informed the defense of the victims’ identities at this point. The parties anticipated that the USAO would send Epstein’s attorneys a list of victims when Epstein fulfilled his obligation under the NPA to enter his state guilty pleas. 12 The final NPA is attached as Exhibit 3 to this Report. 133 On October 3, 2007, the Miami FBI media officer notified the USAO that the New York Post had reported that federal authorities were not going to pursue federal charges against Epstein. According to the Post, Epstein would plead guilty to soliciting underage prostitutes, “in a deal that will send him to prison for about 18 months,” followed by “a shorter period of house confinement,” and, according to “sources,” federal authorities had “agreed to drop their 86 DOJ-OGR-00004410