{
  "document_metadata": {
    "page_number": "35",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 35 of 239\nprosecution . . . will be instituted in this District\"). In other words, the NPA was expressly limited to the USAO-SDFL.3 Given this provision, it would be unnatural to read a broader application to other districts—based on no textual indicia—into the provision relating to co-conspirators. Moreover, the defendant’s reading of the NPA would require the Court to adopt the view that, where a plea agreement contains limiting terms, they must be repeated in every paragraph in order to have their natural and common-sense effects.\nThird, and perhaps most importantly, the defendant’s interpretation strains common sense. In order to accept the defendant’s arguments, the Court would have to reach the counterintuitive conclusion that Epstein expressly bargained for broader immunity for his co-conspirators than he did for himself. That is, under the defendant’s reading of the agreement, Epstein bargained to protect co-conspirators nationally for crimes they committed with Epstein, but Epstein only sought protection for himself in the Southern District of Florida. The text of the agreement does not support such a puzzling interpretation. Instead, the more natural reading of the NPA is that its repeated references to the U.S. Attorney’s Office and “this District” reflect a universal limitation on the NPA: it applies only to the USAO-SDFL.\nFinally, at several points in her motion, the defendant emphasizes that the NPA contains the word “global,” but she does not appear to argue that this creates an affirmative appearance that the NPA binds other districts. (Def. Mot. 1 at 9, 12). Nor could she. The phrase “Epstein seeks to resolve globally his state and federal liability,” by its terms, refers to Epstein’s liability alone. See NPA at 2. Moreover, this language appears directly after several paragraphs describing investigations conducted by the Florida State Attorney’s Office and the USAO-SDFL. See id. at 1-2. Thus, in this context, the terms “global” and “state and federal liability” plainly refer to\n3 In fact, the NPA states that it was executed “on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida.” NPA at 2.\n8\nDOJ-OGR-00002969",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 35 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "prosecution . . . will be instituted in this District\"). In other words, the NPA was expressly limited to the USAO-SDFL.3 Given this provision, it would be unnatural to read a broader application to other districts—based on no textual indicia—into the provision relating to co-conspirators. Moreover, the defendant’s reading of the NPA would require the Court to adopt the view that, where a plea agreement contains limiting terms, they must be repeated in every paragraph in order to have their natural and common-sense effects.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Third, and perhaps most importantly, the defendant’s interpretation strains common sense. In order to accept the defendant’s arguments, the Court would have to reach the counterintuitive conclusion that Epstein expressly bargained for broader immunity for his co-conspirators than he did for himself. That is, under the defendant’s reading of the agreement, Epstein bargained to protect co-conspirators nationally for crimes they committed with Epstein, but Epstein only sought protection for himself in the Southern District of Florida. The text of the agreement does not support such a puzzling interpretation. Instead, the more natural reading of the NPA is that its repeated references to the U.S. Attorney’s Office and “this District” reflect a universal limitation on the NPA: it applies only to the USAO-SDFL.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Finally, at several points in her motion, the defendant emphasizes that the NPA contains the word “global,” but she does not appear to argue that this creates an affirmative appearance that the NPA binds other districts. (Def. Mot. 1 at 9, 12). Nor could she. The phrase “Epstein seeks to resolve globally his state and federal liability,” by its terms, refers to Epstein’s liability alone. See NPA at 2. Moreover, this language appears directly after several paragraphs describing investigations conducted by the Florida State Attorney’s Office and the USAO-SDFL. See id. at 1-2. Thus, in this context, the terms “global” and “state and federal liability” plainly refer to",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "3 In fact, the NPA states that it was executed “on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida.” NPA at 2.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "8",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002969",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Epstein",
      "R. Alexander Acosta"
    ],
    "organizations": [
      "USAO-SDFL",
      "U.S. Attorney's Office",
      "Florida State Attorney's Office"
    ],
    "locations": [
      "Southern District of Florida"
    ],
    "dates": [
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "DOJ-OGR-00002969"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of United States v. [defendant]. The text discusses the interpretation of a Non-Prosecution Agreement (NPA) and its application to co-conspirators. The document is well-formatted and free of significant damage or redactions."
}