t result in the institution of criminal charges. See Memorandum from Craig S. Morford, Acting Deputy Att'y Gen., U.S. Dep't of Justice, to Heads of Department Components, U.S. Att'ys re: Selection and Use of Monitors in Deferred Prosecution Agreements and Non-Prosecution Agreements with Corporations (Mar. 7, 2008) a

ion to Epstein's counsel; instead it was the norm. See Memorandum from Craig S. Morford, Acting Deputy Att'y Gen., U.S. Dept of Justice, to Heads of Department Components, U.S. Att'ys re: Selection and Use of Monitors in Deferred Prosecution Agreements and Non— Prosecution Agreements with Corporations (Mar. 7. 2008) a