DOJ-OGR-00021099.pdf

--- Page 1 --- **Case 22-1426, Document 59, 02/28/2023, 3475902, Page52 of 113** **Header** Case 22-1426, Document 59, 02/28/2023, 3475902, Page52 of 113 **Body** Moreover, the USAO-SDFL's involvement of the USAO for this District in its investigation of Epstein, as well its contact with witnesses in New York, reflect a coordinated effort that transcended the USAO-SDFL (Dkt 142, Exh. A at 46, 48, 60). From these facts, it affirmatively appears that the Government had every reason to foresee a potential prosecution of Epstein's co-conspirators in this District and, after multiple layers of review within the Department of Justice, intended to agree to preclude it. According to the OPR, the NPA originally read that it "resolves the federal criminal liability of the defendant and any co-conspirators in the Southern District of Florida...", but this language was modified and the final agreement was not so restricted as to the co-conspirators. Dkt 142, Exh. A at 74-75. The OPR demonstrates the trans-district scope of the investigation and the negotiations. * Dkt 142, Exh A at 27 n.38 (Feds considered arresting Epstein in the Virgin Islands, rather than Florida, indicating national scope of investigation); * Id. at 46 ([“[I]nvestigators had learned that Epstein used hidden cameras in his New York residence to record his sexual encounters”]); * Id. at 58 (AUSA Villafana requested "enough time to go to New York, pursue investigative steps involving two of Epstein's assistants, do **Footer** DOJ-OGR-00021099 **Page Number** 37