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ests that the United States Attorney for the Southern District of Florida defer such prosecution"). Thus, the 8 EFTA00066001 NPA's references to the "United States" demonstrate a definitional intent not to limit such provisions to the USAO-SDFL. The NPA begins with several factual recitals. After noting certai
e government's position. The co-conspirator immunity provision does not prohibit merely prosecutions by the USAO for the SDFL ("USAO-SDFL"), but by "the United States." This broad prohibition was intentional, as demonstrated by the express references elsewhere in the NPA to the United States Attorney and/or the US
cuted, when such language is included as to Epstein, must be presumed under contract interpretation principles to have been intentional. See, e.g., LaSalle Bank, 424 F.3d at 206; Port Consot, 826 F. App'x at 827-28. At minimum, the silence as to time period and covered conduct is an ambiguity and therefore s
ests that the United States Attorney for the Southern District of Florida defer such prosecution"). Thus, the 8 EFTA00099364 NPA's references to the "United States" demonstrate I definitional intent not to limit such provisions to the USAO-SDFL. The NPA begins with several factual recitals. After noting certai
e government's position. The co-conspirator immunity provision does not prohibit merely prosecutions by the USAO for the SDFL ("USAO-SDFL"), but by "the United States." This broad prohibition was intentional, as demonstrated by the express references elsewhere in the NPA to the United States Attorney and/or the US
cuted, when such language is included as to Epstein, must be presumed under contract interpretation principles to have been intentional. See, e.g., LaSalle Bank, 424 F.3d at 206; Port Consol., 826 F. App'x at 827-28. At minimum, the silence as to time period and covered conduct is an ambiguity and therefore
ing juror sympathy."). Any attempt to encourage such sympathy is therefore an attempt at nullification, which is itself plainly improper. See, e.g., United States v. Thomas, 116 F.3d 606, 615 (2d Cir. 1997) (Jury nullification is "by no means a right or 3 Evidence of the defendant's motive may be relevant evid
ts to substitute the expert's judgment for the jury's."). Nor may an expert opine as to a party's state of mind, credibility, intent, or motive. See LaSalle Bank Nat'l Ass 'n v. CIBC Inc., No. 08 Civ. 8426 (WHP) (HBP), 2012 WL 466785, at *7 (S.D.N.Y. Feb. 14, 2012) (collecting cases); see, e.g., Highland Cap
Entities connected to both United States and LaSalle Bank

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
Prince Andrew
PERSON
Alexander Acosta
PERSONFBI
ORGANIZATION
New York
LOCATION
Julie K. Brown
PERSON
Virginia Giuffre
PERSON
Samantha Power
PERSON
Southern District of New York
ORGANIZATION
Jay Lefkowitz
PERSON
Michael Cohen
PERSON
A. Marie Villafana
PERSONCourtney Wild
PERSON
Harvey Weinstein
PERSONSecond Circuit
ORGANIZATION
Alberto Gonzales
PERSON
Santa Fe
LOCATION