DOJ-OGR-00021681.pdf

--- Page 1 --- **Document Header:** * Case: 22-1426 * Document: 79 * Date: 06/29/2023 * Page: 3536060 * Page Number: 34 of 93 **Main Text:** the prosecution of co-conspirators without clearly saying so." (A.142).3 Maxwell also points to the NPA provision stating that "Epstein seeks to resolve globally his state and federal criminal liability." (A.175). Based on that statement, Maxwell argues that Epstein's purpose in negotiating the NPA was to "obtain a global resolution that would, among other things, provide maximum protection for any alleged co-conspirators." (Br.34). But the cited provision only says that Epstein sought to resolve "his" liability, not anyone else's. Furthermore, under Maxwell's reading, Epstein bargained for a truly "global" resolution only for his co-conspirators, and limited his own "global" resolution expressly to the USAO-SDFL. There is no reason to believe that Epstein expressly sought and obtained broader immunity for his co-conspirators than he did for himself. (See also SA107 n.125 (observing that a supervisor at the USAO-SDFL "pointed out that the NPA was not a Maxwell also relies on draft plea agreements which "expressly defined the term 'United States' as limited to" USAO-SDFL. Those plea agreements - which differed significantly from the NPA - also use both the terms "United States" and "United States Attorney's Office for the Southern District of Florida," including using the USAO-SDFL term expressly in the context of the co-conspirator provision. (See, e.g., Dkt.142, Ex. F at 2). This point only highlights the parties' understanding at all times that their negotiations merely bound the USAO-SDFL, and not the entire federal government. **Footer:** * DOJ-OGR-00021681