17 determination that the NPA precludes Maxwell’s prosecution in New York. As the Second Circuit itself noted, although the co-conspirator clause at issue here is “silent” as to whether it intended to preclude co-conspirator prosecution outside the Southern District of Florida, it is not silent as to whether Epstein’s future prosecution is limited to the Southern District of Florida. Instead, “the NPA makes clear that if Epstein fulfilled his obligations, he would no longer face charges in that district.” (App.9, emphasis in original). The use of narrowing terms as to Epstein’s protections, not but not as to co-conspirator protec- tions, demonstrates that the difference was inten- tional. See Scalia & Garner, Reading Law: The Interpretation of Legal Texts at 167 (“The whole of a contract is to be taken together, so as to give effect to every part, if reasonably practicable, each clause helping to interpret the other.”); Id. at 170 ((“[A] material variation in terms suggests a variation in meaning.”). This intent should have been recognized. Second, the NPA was entered into after extensive negotiation. The language was hotly contested and subject to much revision back and forth, including specifically on the relevant language of the coconspira- tor clause. (App.95, 108-126). In one of the earlier drafts, the government proposed language that the co-conspirator protection would be limited to the Southern District of Florida. (App.117). Yet the final draft eliminated the limitation to the Southern District of Florida and referred only to the United States. (App.122-24). The OPR report found that gov- ernment witnesses (who were the only witnesses OPR spoke to) believed the co-conspirator clause was in- tended to provide transactional immunity. (App.128- 129). This understanding, supported by the NPA itself and the negotiation history contained in the one-sided DOJ-OGR-00000059