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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) 8, 9 United States v. Aleman, 286 F.3d 86 (2d Cir. 2002) 17 United States v. Annabi, 771 F.2d 670 (2d Cir. 1985) passim United States v. CFW Const. Co., 583 F. Supp. 197 (
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 →ch, on its face, bars her prosecution. See Feldman, 939 F.3d at 184, 190 (hearing based on oral representations made to defendant); United States v. Aleman, 286 F.3d 86, 91 (2d Cir. 2002) (granting hearing where defendant submitted attorney affidavits alleging oral agreement); United States v. Sattar,
Page: EFTA00028900 →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 →greatly increases the potential for disputes such as . .. a failure to agree on the existence, let alone the terms, of the deal." United States v. Aleman, 286 F.3d 86, 90 (2d Cir. 2002). Thus, an evidentiary hearing may be necessary to determine the terms of an agreement never committed to writing. T
Page: EFTA00020268 →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 →greatly increases the potential for disputes such as . .. a failure to agree on the existence, let alone the terms, of the deal." United States v. Aleman, 286 F.3d 86, 90 (2d Cir. 2002). Thus, an evidentiary hearing may be necessary to determine the terms of an agreement never committed to writing. T
Page: EFTA00022098 →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 →greatly increases the potential for disputes such as . .. a failure to agree on the existence, let alone the terms, of the deal." United States v. Aleman, 286 F.3d 86, 90 (2d Cir. 2002). Thus, an evidentiary hearing may be necessary to determine the terms of an agreement never committed to writing. T
Page: EFTA00029547 →Entities connected to both Office of Professional Responsibility and Aleman

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
Alexander Acosta
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Bradley Edwards
PERSONthe Southern District
LOCATIONJane Doe
PERSON
Julie K. Brown
PERSONFBI
ORGANIZATION
Virginia Giuffre
PERSON
Prince Andrew
PERSONEmmy Taylor
PERSON
Supreme Court
ORGANIZATION
Ken Starr
PERSON
Southern District of New York
ORGANIZATION
Scarlett Johansson
PERSONAnnabi
PERSONCollins
PERSON
Reid Weingarten
PERSON