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DOJ-OGR-00021758.jpg
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Extraction Summary
5
People
4
Organizations
3
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal brief / court filing (page 16 of 35)
File Size:
672 KB
Summary
This legal document argues that the Non-Prosecution Agreement (NPA) was intentionally drafted to provide immunity beyond the Southern District of Florida, evidenced by the removal of limiting language and its replacement with 'United States.' It also refutes the Government's claim that 'Main Justice' was not involved, citing OPR records showing Andrew C. Lourie (Deputy Assistant Attorney General) actively participated in negotiations from Washington, D.C. in September 2007.
People (5)
| Name | Role | Context |
|---|---|---|
| Jeffrey Epstein | Defendant / Subject |
Referenced regarding the NPA and his desire to reach a global agreement on State and Federal criminal liabilities.
|
| Andrew C. Lourie | Deputy Assistant Attorney General / Chief of Staff |
Official in the Department's Criminal Division who actively participated in plea negotiations from Washington DC.
|
| Alice Fisher | Assistant Attorney General |
Andrew C. Lourie served as her Chief of Staff.
|
| U.S. Attorney | Prosecutor (Lead) |
Instructed the line prosecutor to restore specific language to the NPA regarding global agreement.
|
| Line Prosecutor | Prosecutor |
Received instructions from the U.S. Attorney regarding the drafting of the NPA.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Main Justice |
DOJ Headquarters; document argues they were involved in plea negotiations despite Government denial.
|
|
| Department's Criminal Division |
Division of the DOJ where Andrew Lourie worked.
|
|
| OPR |
Office of Professional Responsibility; cited as demonstrating Lourie's involvement.
|
|
| Southern District of Florida |
Jurisdiction mentioned regarding the limitation of immunity language that was removed.
|
Timeline (2 events)
2007-09-24
Andrew C. Lourie, stationed in Washington D.C., was involved in plea negotiations.
Washington, DC
Unknown (Drafting Phase)
Removal of language limiting co-conspirator immunity to the Southern District of Florida from the NPA.
N/A
Locations (3)
| Location | Context |
|---|---|
|
Geographic limitation originally in the draft NPA but removed.
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|
|
Location where Andrew C. Lourie was stationed at Main Justice.
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Term used in the final NPA to replace the limited geographic scope of the Southern District of Florida.
|
Relationships (2)
Lourie was Chief of Staff to Assistant Attorney General Alice Fisher.
U.S. Attorney... instructed the line prosecutor to restore the reference.
Key Quotes (4)
"However, that language, limiting co-conspirator immunity to the Southern District of Florida, was removed from the final signed NPA."Source
DOJ-OGR-00021758.jpg
Quote #1
"The intentional excision of this limiting language from the draft version of the co-conspirator clause establishes that that limitation was not intended to apply to the co-conspirator clause."Source
DOJ-OGR-00021758.jpg
Quote #2
"The Government denies that Main Justice was involved in the plea negotiations."Source
DOJ-OGR-00021758.jpg
Quote #3
"Andrew C. Lourie... was actively participating in a critical phase of plea negotiations in September 'from his new post at the Department in Washington, DC.'"Source
DOJ-OGR-00021758.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (1,603 characters)
Case 22-1426, Document 87, 07/27/2023, 3548202, Page16 of 35
agreement. SA100, SA105 fn.122. However, that language, limiting co-conspirator
immunity to the Southern District of Florida, was removed from the final signed
NPA. SA166-167fn.237, fn.239, & fn.240. The intentional excision of this limiting
language from the draft version of the co-conspirator clause establishes that that
limitation was not intended to apply to the co-conspirator clause. Indeed, it is
difficult to imagine any clearer evidence than the purposeful removal of that limiting
language, especially as it is replaced by the term “United States.” And to punctuate
this point, the U.S. Attorney himself as part of a final review and edit of the NPA,
instructed the line prosecutor to restore the reference to Epstein’s desire to reach a
global agreement of his State and Federal criminal liabilities. SA110.
immunity to the Southern District of Florida, was removed from the final signed
NPA. SA166-167fn.237, fn.239, & fn.240. The intentional excision of this limiting
language from the draft version of the co-conspirator clause establishes that that
limitation was not intended to apply to the co-conspirator clause. Indeed, it is
difficult to imagine any clearer evidence than the purposeful removal of that limiting
language, especially as it is replaced by the term “United States.” And to punctuate
this point, the U.S. Attorney himself as part of a final review and edit of the NPA,
instructed the line prosecutor to restore the reference to Epstein’s desire to reach a
global agreement of his State and Federal criminal liabilities. SA110.
The Government denies that Main Justice was involved in the plea
negotiations. Br. 22. But the OPR demonstrates that Andrew C. Lourie, Deputy
Assistant Attorney General for the Department’s Criminal Division and Chief of
Staff to Assistant Attorney General Alice Fisher, was actively participating in a
critical phase of plea negotiations in September “from his new post at the
Department in Washington, DC.” SA101. After his transfer, he continued to be
consulted on the negotiations and apprised of their status. He repeatedly rendered
opinions, trying to close the deal involving a plea agreement and the NPA (SA106,
110). On September 24, 2007, Lourie, now stationed in Washington D.C. at Main
negotiations. Br. 22. But the OPR demonstrates that Andrew C. Lourie, Deputy
Assistant Attorney General for the Department’s Criminal Division and Chief of
Staff to Assistant Attorney General Alice Fisher, was actively participating in a
critical phase of plea negotiations in September “from his new post at the
Department in Washington, DC.” SA101. After his transfer, he continued to be
consulted on the negotiations and apprised of their status. He repeatedly rendered
opinions, trying to close the deal involving a plea agreement and the NPA (SA106,
110). On September 24, 2007, Lourie, now stationed in Washington D.C. at Main
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DOJ-OGR-00021758
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