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NN: Internal White House Debate Over Fate Of Haspel. CNN <https://www.cnn.com/2020/11/12/politics/gop-defend-haspel-trump/index.html> (11/12, Cohen, Collins, Salama, 83.I6M) reports that while some GOP lawmakers have "publicly defended" CIA Director Haspel, "outside of Capitol Hill, there are conflictin
://apnews.com/article/jeffrey-epstein-florida-e2a4431f7319afd037023d9a586aa291> (11/12, Balsamo, Tucker) says a report from the Justice Department's Office of Professional Responsibility has found Acosta "exercised 'poor judgment' in handling an investigation into wealthy financier Jeffrey Epstein when he was a top federal prosecuto
fend the health-care law in court. "The Affordable Care Act remains the law of the land, and it is the Department of Justice's duty to defend it," Collins said. 3) "Democrats are savoring the moment," Paige Winfield Cunningham reports in the Health 202. "They're spending the week bludgeoning Republic
ficking charges against Epstein on Monday — might not be investigating authorities' handling of the previous allegations. The Justice Department's Office of Professional Responsibility has been reviewing the handling of Epstein's 2008 plea deal for possible misconduct, and Barr is recused from that." -- The Miami Herald has repor
TABLE OF AUTHORITIES Page(s) Cases Bank of New York Mellon Trust Co. v. Morgan Stanley Mortg. Capital, Inc., 821 F.3d 297 (2d Cir. 2016) 8, 9 Collins v. Univ. of Notre Dame DU Lac, 929 F.3d 830 (7th Cir. 2019) 8, 9 Penncro Assocs., Inc. v. Sprint Spectrum, L.P., 499 F.3d 1151 (10th Cir. 2007)
Page: EFTA00028882 →A at 5), the government asks the Court to disregard this plain language and instead credit a passage from the report of the Department of Justice's Office of Professional Responsibility ("OPR Report"2) stating that the line prosecutor who negotiated the NPA "believed" that only the four individuals expressly named in the co-conspir
Page: EFTA00028887 →268, 270 (2d Cir. 2004) (internal citations and emphasis omitted). 8 EFTA00028891 --- PAGE BREAK --- New York Mellon Trust Co., 821 F.3d at 309; Collins, 929 F.3d at 841; Penncro Assocs., 499 F.3d at 1156-57. Here, the NPA contains only two immunity provisions: one for Epstein, which is expressly li
Page: EFTA00028892 →t also agreed not to bring criminal charges against any of his "potential co-conspirators." Id. As a recent report from the Department of Justice's Office of Professional Responsibility observed, the NPA was unusual in many respects, including its breadth, leniency, and secrecy. OPR Report, Gov. Ex. 3, Dkt. No. 204-3, at x, 80, 175
Page: EFTA00020263 →n the control of a civilian third party, not the Government, and so the Government need not (and perhaps cannot) produce them. See United States v. Collins, 409 F. Supp. 3d 228, 239 (S.D.N.Y. 2019). Finally, Maxwell's request for copies of all subpoenas the Government has issued is overly broad and lack
Page: EFTA00020290 →t also agreed not to bring criminal charges against any of his "potential co-conspirators." Id. As a recent report from the Department of Justice's Office of Professional Responsibility observed, the NPA was unusual in many respects, including its breadth, leniency, and secrecy. OPR Report, Gov. Ex. 3, Dkt. No. 204-3, at x, 80, 175
Page: EFTA00022093 →n the control of a civilian third party, not the Government, and so the Government need not (and perhaps cannot) produce them. See United States v. Collins, 409 F. Supp. 3d 228, 239 (S.D.N.Y. 2019). Finally, Maxwell's request for copies of all subpoenas the Government has issued is overly broad and lack
Page: EFTA00022120 →t also agreed not to bring criminal charges against any of his "potential co-conspirators." Id. As a recent report from the Department of Justice's Office of Professional Responsibility observed, the NPA was unusual in many respects, including its breadth, leniency, and secrecy. OPR Report, Gov. Ex. 3, Dkt. No. 204-3, at x, 80, 175
Page: EFTA00029542 →n the control of a civilian third party, not the Government, and so the Government need not (and perhaps cannot) produce them. See United States v. Collins, 409 F. Supp. 3d 228, 239 (S.D.N.Y. 2019). Finally, Maxwell's request for copies of all subpoenas the Government has issued is overly broad and lack
Page: EFTA00029569 →Entities connected to both Collins and Office of Professional Responsibility

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
Donald Trump
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Julie K. Brown
PERSONLeon Black
PERSON
George W. Bush
PERSON
Joe Biden
PERSON
Virginia Giuffre
PERSONEmmy Taylor
PERSONFBI
ORGANIZATION
Scarlett Johansson
PERSON
Bloomberg L.P.
ORGANIZATION
Stephen Hawking
PERSON
New York
LOCATION
William Barr
PERSON
Michael Jackson
PERSON
Samantha Power
PERSON