{
  "document_metadata": {
    "page_number": "31",
    "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 31 of 239\noffer any evidence to support her claim that the NPA applies to this District, to the defendant, or to the crimes in the Indictment, the Court should deny the defendant's request for discovery and an evidentiary hearing.\n\nA. The NPA Does Not Bind the Southern District of New York\n\nAs an initial matter, the NPA is not enforceable in this District. To the contrary, it is black-letter law in this Circuit that a plea agreement in one district does not apply elsewhere, in the absence of express indications not present here. Indeed, the Second Circuit has considered and rejected the exact arguments the defendant advances in her motion. The defendant's motion is without any basis in the law and should be denied.\n\nIt is well settled in the Second Circuit that \"a plea agreement in one U.S. Attorney's office does not, unless otherwise stated, bind another.\" United States v. Prisco, 391 F. App'x 920, 921 (2d Cir. 2010) (citing United States v. Annabi, 771 F.2d 670, 672 (2d Cir. 1985) (per curiam) (\"A plea agreement binds only the office of the United States Attorney for the district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.\")); United States v. Salameh, 152 F.3d 88, 120 (2d Cir. 1998). This Circuit \"presumes a narrow reading of the boundaries of a plea agreement unless a defendant can affirmatively establish that a more expansive interpretation was contemplated.\" United States v. Laskow, 688 F. Supp. 851, 854 (E.D.N.Y. 1988) (citing Annabi, 771 F.2d at 672), aff'd, 867 F.2d 1425 (2d Cir. 1988)(tbl.). To meet this burden, a defendant must establish that either the text of the agreement or the \"negotiations between defendant and prosecutor\" indicate a promise to bind other districts. United States v. Russo, 801 F.2d 624, 626 (2d Cir. 1986). For the reasons set forth below, the defendant has failed to establish that the USAO-SDFL promised Epstein that the NPA would bind other districts.\n\n4\nDOJ-OGR-00002965",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 31 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "offer any evidence to support her claim that the NPA applies to this District, to the defendant, or to the crimes in the Indictment, the Court should deny the defendant's request for discovery and an evidentiary hearing.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "A. The NPA Does Not Bind the Southern District of New York",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "As an initial matter, the NPA is not enforceable in this District. To the contrary, it is black-letter law in this Circuit that a plea agreement in one district does not apply elsewhere, in the absence of express indications not present here. Indeed, the Second Circuit has considered and rejected the exact arguments the defendant advances in her motion. The defendant's motion is without any basis in the law and should be denied.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "It is well settled in the Second Circuit that \"a plea agreement in one U.S. Attorney's office does not, unless otherwise stated, bind another.\" United States v. Prisco, 391 F. App'x 920, 921 (2d Cir. 2010) (citing United States v. Annabi, 771 F.2d 670, 672 (2d Cir. 1985) (per curiam) (\"A plea agreement binds only the office of the United States Attorney for the district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.\")); United States v. Salameh, 152 F.3d 88, 120 (2d Cir. 1998). This Circuit \"presumes a narrow reading of the boundaries of a plea agreement unless a defendant can affirmatively establish that a more expansive interpretation was contemplated.\" United States v. Laskow, 688 F. Supp. 851, 854 (E.D.N.Y. 1988) (citing Annabi, 771 F.2d at 672), aff'd, 867 F.2d 1425 (2d Cir. 1988)(tbl.). To meet this burden, a defendant must establish that either the text of the agreement or the \"negotiations between defendant and prosecutor\" indicate a promise to bind other districts. United States v. Russo, 801 F.2d 624, 626 (2d Cir. 1986). For the reasons set forth below, the defendant has failed to establish that the USAO-SDFL promised Epstein that the NPA would bind other districts.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "4",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002965",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein"
    ],
    "organizations": [
      "USAO-SDFL",
      "Second Circuit",
      "United States Attorney"
    ],
    "locations": [
      "Southern District of New York",
      "New York",
      "District"
    ],
    "dates": [
      "04/16/21",
      "2010",
      "1985",
      "1998",
      "1988",
      "1986"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "DOJ-OGR-00002965"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is page 31 of 239."
}