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Discovery has revealed that during these negotiations, several drafts of the NPA were exchanged. See, e.g., Exh. C (9/17/07 email from Villafana to Lefkowitz attaching draft NPA); Exh. D (9/21/07 email from Villafana to Lefkowitz attaching draft NPA). In addition, the parties exchanged several drafts of
ew York, 404 U.S. 257 (1971) 12 Subaru Distribs. Corp. v. Subaru of Am., Inc., 425 F.3d 119 (2d Cir. 2005) 15 EFTA00065991 United States v. Aleman, 286 F.3d 86 (2d Cir. 2002) United States v. Annabi, 771 F.2d 670 (2d Cir. 1985) United States v. Ashy*: 29 passim 320 F. App'x 26 (2d Cir. 20
agreement or non-prosecution agreement is in genuine dispute. See, e.g., id. at 270 (noting testimony from defendant's attorney); United States v. Aleman, 286 F.3d 86, 91 (2d Cir. 2002) (remanding where "the district court failed to make a record that allows us to determine the existence, scope and ef
Discovery has revealed that during these negotiations, several drafts of the NPA were exchanged. See, e.g., Exh. C (9/17/07 email from Villafana to Lefkowitz attaching draft NPA); Exh. D (9/21/07 email from Villafana to Lefkowitz attaching draft NPA). In addition, the parties exchanged several drafts of
ew York, 404 U.S. 257 (1971) 12 Subaru Distribs. Corp. v. Subaru of Am., Inc., 425 F.3d 119 (2d Cir. 2005) 15 EFTA00099354 United States v. Aleman, 286 F.3d 86 (2d Cir. 2002) United States v. Annabi, 771 F.2d 670 (2d Cir. 1985) United States v. Ashy*: 29 passim 320 F. App'x 26 (2d Cir. 20
agreement or non-prosecution agreement is in genuine dispute. See, e.g., id. at 270 (noting testimony from defendant's attorney); United States v. Aleman, 286 F.3d 86, 91 (2d Cir. 2002) (remanding where "the district court failed to make I record that allows us to determine the existence, scope and ef
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 →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 →submitted an affidavit from Epstein's counsel, defense counsel notes that it has made several unsuccessful attempts to obtain information from Jay Lelkowitz, the attorney who was principally involved in negotiating the language of the NPA on Epstein's behalf. 17 EFTA00028900 --- PAGE BREAK --- CONCLU
Page: EFTA00028901 →Entities connected to both Jay Lefkowitz and Aleman

Jeffrey Epstein
PERSON
Alexander Acosta
PERSONLeon Black
PERSON
A. Marie Villafana
PERSON
United States
LOCATION
Department of Justice
ORGANIZATIONJane Doe
PERSON
Ken Starr
PERSONMartin Weinberg
PERSONthe Southern District
LOCATION
Bradley Edwards
PERSON
George W. Bush
PERSON
Prince Andrew
PERSONFBI
ORGANIZATION
Lesley Groff
PERSONDarren Indyke
PERSON
Scarlett Johansson
PERSONMaria Farmer
PERSON
Ghislaine Maxwell
PERSONLourie
PERSON