DOJ-OGR-00000232.pdf

--- Page 1 --- **Document Text Extraction** The following text is extracted from the document image: **Page Number** 9 **Paragraph** While petitioner emphasizes (Pet. 18) the paragraph stating that Epstein sought "to resolve globally his state and federal criminal liability," Pet. App. 25a, even as to "his" federal liability specifically, the agreement by its terms protected him from federal prosecution only "in this District," id. at 26a; see id. at 9a (court of appeals observing that "where the NPA is not silent, the agreement's scope is expressly limited to the Southern District of Florida"). The NPA's coconspirators clause, which "also agrees" to forgo certain prosecution of co-conspirators, cannot reasonably be construed as reflecting some "global[]" scope broader than the Florida-based state and federal charges that Epstein resolved for himself. It would be extremely strange if the NPA left Epstein himself open to federal prosecution in another district—as eventually occurred, see p. 5, supra—while protecting his coconspirators from prosecution anywhere. Contrary to petitioner's claim, such an implausible reading cannot be inferred simply because the coconspirators clause is one of the places where "the United States" is used instead of "the United States Attorney" or "the United States Attorney's Office." As noted above, the NPA variously referred to the U.S. Attorney, the USAO, and the United States, and at least some of those uses of "the United States" plainly referred specifically to the USAO. See, e.g., Pet. App. 26a (using terms interchangeably in paragraph on notice); id. at 30a (noting that Epstein had "agree[d]" "[a]t the United States' request" to provide certain information); cf. Kirksaeng v. John Wiley & Sons, Inc., 568 U.S. 519, 540 (2013) ("different words used in different parts of the same statute [can] mean roughly the same thing"). The term **Footer** DOJ-OGR-00000232