{
  "document_metadata": {
    "page_number": "8",
    "document_number": "18",
    "date": "07/16/19",
    "document_type": "court transcript",
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    "has_stamps": false
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  "full_text": "Case #19-cr-00490-RMB Document 18 Filed 07/16/19 Page 8 of 18 8\n1 There is evidence to support that. The investigation was\n2 begun and conducted entirely separate from any other district.\n3 It began in the Southern District of New York.\n4\n5 Certainly there is evidence that was gathered that is\n6 consistent with and even overlapping with the prior\n7 investigation. But as the Court noted, in particular an entire\n8 count of this indictment is with respect to New York victims.\n9 And that is before we even get to the fact that the\n10 nonprosecution agreement does not bind the Southern District of\n11 New York.\n12 THE COURT: I was going to ask you about that too.\n13 Now that you have mentioned the topic, explain that, would you.\n14 MR. ROSSMILLER: Yes, your Honor. I do expect that we\n15 can brief this, but the short version is that this prosecution\n16 is not precluded by the nonprosecution agreement entered into\n17 by the defendant in the Southern District of Florida. That\n18 agreement expressly referred to that federal district. It\n19 didn't purport to bind any other office or district.\n20 It is well-settled in the Second Circuit that a plea\n21 agreement in one U.S. Attorney's office does not bind another\n22 unless otherwise stated. That is even if, based on case law,\n23 the agreement refers generally to \"the government.\" Again,\n24 additionally, as set forth in the indictment returned by the\n25 grand jury, the substantive count alleges acts occurring in New\nYork and alleges New York-based victims.\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00000394",
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      "content": "Case #19-cr-00490-RMB Document 18 Filed 07/16/19 Page 8 of 18 8",
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      "content": "1 There is evidence to support that. The investigation was\n2 begun and conducted entirely separate from any other district.\n3 It began in the Southern District of New York.\n4\n5 Certainly there is evidence that was gathered that is\n6 consistent with and even overlapping with the prior\n7 investigation. But as the Court noted, in particular an entire\n8 count of this indictment is with respect to New York victims.\n9 And that is before we even get to the fact that the\n10 nonprosecution agreement does not bind the Southern District of\n11 New York.",
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    {
      "type": "printed",
      "content": "12 THE COURT: I was going to ask you about that too.\n13 Now that you have mentioned the topic, explain that, would you.",
      "position": "main"
    },
    {
      "type": "printed",
      "content": "14 MR. ROSSMILLER: Yes, your Honor. I do expect that we\n15 can brief this, but the short version is that this prosecution\n16 is not precluded by the nonprosecution agreement entered into\n17 by the defendant in the Southern District of Florida. That\n18 agreement expressly referred to that federal district. It\n19 didn't purport to bind any other office or district.",
      "position": "main"
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      "type": "printed",
      "content": "20 It is well-settled in the Second Circuit that a plea\n21 agreement in one U.S. Attorney's office does not bind another\n22 unless otherwise stated. That is even if, based on case law,\n23 the agreement refers generally to \"the government.\" Again,\n24 additionally, as set forth in the indictment returned by the\n25 grand jury, the substantive count alleges acts occurring in New\nYork and alleges New York-based victims.",
      "position": "main"
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    {
      "type": "printed",
      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00000394",
      "position": "footer"
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  "entities": {
    "people": [
      "MR. ROSSMILLER"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
    ],
    "locations": [
      "New York",
      "Southern District of New York",
      "Southern District of Florida",
      "Second Circuit",
      "Florida"
    ],
    "dates": [
      "07/16/19"
    ],
    "reference_numbers": [
      "19-cr-00490-RMB",
      "Document 18",
      "DOJ-OGR-00000394"
    ]
  },
  "additional_notes": "The document appears to be a court transcript with clear and legible text. There are no visible redactions or damage."
}