{ "document_metadata": { "page_number": "16", "document_number": "142", "date": "02/04/21", "document_type": "court document", "has_handwriting": false, "has_stamps": false }, "full_text": "Case 1:20-cr-00330-AJN Document 142 Filed 02/04/21 Page 16 of 38\nprosecuted. Nor does the NPA contain any language limiting its binding effect on other USAOs, as standard agreements typically do.\nB. The Negotiation of the NPA\nUnlike standard non-prosecution agreements, the NPA here was heavily negotiated. Negotiations began in January 2007, lasted for a period of eight months, and were “extensive.” In re Wild, 955 F.3d 1196, 1198-99 (11th Cir.), reh'g en banc granted, opinion vacated, 967 F.3d 1285 (11th Cir. 2020). Discovery has revealed that See, e.g., Exh. C ; Exh. D . In addition, . See, e.g., Exh. E ; Exh. F . Id. It is our understanding that the negotiations involved the entire hierarchy of the USAO for the SDFL, all of whom signed off on the NPA. Discovery indicates that . Further, the investigation leading up to the NPA was not limited to the SDFL: A privilege log produced by the government in civil litigation indicates that the USAO-SDFL involved the USAO for this District in its investigation of Epstein, and that attorneys from the USAO-SDFL traveled to New York and interviewed and/or subpoenaed New York-based witnesses. Privilege Log, Doe v. United States, Case No. 9:08-CV-80736 (S.D. Fla.), Dkt. No. 212-1 (filed July 19, 2013) (“SDFL Privilege Log”), at 4, 5, 7. Moreover, 11 DOJ-OGR-00002588", "text_blocks": [ { "type": "printed", "content": "Case 1:20-cr-00330-AJN Document 142 Filed 02/04/21 Page 16 of 38", "position": "header" }, { "type": "printed", "content": "prosecuted. Nor does the NPA contain any language limiting its binding effect on other USAOs, as standard agreements typically do.", "position": "top" }, { "type": "printed", "content": "B. The Negotiation of the NPA", "position": "top" }, { "type": "printed", "content": "Unlike standard non-prosecution agreements, the NPA here was heavily negotiated. Negotiations began in January 2007, lasted for a period of eight months, and were “extensive.” In re Wild, 955 F.3d 1196, 1198-99 (11th Cir.), reh'g en banc granted, opinion vacated, 967 F.3d 1285 (11th Cir. 2020). Discovery has revealed that See, e.g., Exh. C ; Exh. D . In addition, . See, e.g., Exh. E ; Exh. F . Id. It is our understanding that the negotiations involved the entire hierarchy of the USAO for the SDFL, all of whom signed off on the NPA. Discovery indicates that . Further, the investigation leading up to the NPA was not limited to the SDFL: A privilege log produced by the government in civil litigation indicates that the USAO-SDFL involved the USAO for this District in its investigation of Epstein, and that attorneys from the USAO-SDFL traveled to New York and interviewed and/or subpoenaed New York-based witnesses. Privilege Log, Doe v. United States, Case No. 9:08-CV-80736 (S.D. Fla.), Dkt. No. 212-1 (filed July 19, 2013) (“SDFL Privilege Log”), at 4, 5, 7. Moreover,", "position": "middle" }, { "type": "printed", "content": "11", "position": "footer" }, { "type": "printed", "content": "DOJ-OGR-00002588", "position": "footer" } ], "entities": { "people": [], "organizations": [ "USAOs", "USAO", "SDFL", "USAO-SDFL" ], "locations": [ "New York" ], "dates": [ "January 2007", "July 19, 2013", "02/04/21" ], "reference_numbers": [ "1:20-cr-00330-AJN", "142", "955 F.3d 1196", "967 F.3d 1285", "9:08-CV-80736", "212-1" ] }, "additional_notes": "The document appears to be a court filing with redactions. The redactions are likely due to sensitive information being withheld." }