{
  "document_metadata": {
    "page_number": "12",
    "document_number": "9:08-cv-80736",
    "date": "07/13/2010",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Agreement. The Non-Prosecution Agreement does not bar the United States from bringing federal criminal charges against Epstein for the offenses set forth in the Non-Prosecution Agreement in any other district in the nation.11 See, e.g., United States v. Cain, 587 F.2d 678, 680 (5th Cir. 1979) (\"Where . . . the prosecutor is not found to have made promises relating to nonprosecution of charges in another district and the [defendant] is not found to have relied on such alleged promises, this Court will affirm the trial court's denial of a motion to dismiss the subsequent prosecutions.\") Neither does the Non-Prosecution Agreement bar prosecution in any district for offenses not identified in the agreement.\n\nPetitioners contend that the CVRA gives a victim the right to confer with the attorney for the government before there is a disposition of contemplated, but-not-yet-filed federal criminal charges arising from offenses against the victim. But, although the government disputes that the CVRA creates such a right,12 the Petitioners have never been denied any such right. The Petitioners have had and still have the ability confer to with the attorney for the government about potential federal criminal charges against Epstein and about the potential disposition of any such charges, should they be filed. In fact, Petitioners are free to approach the United States Attorney's Offices in districts such as the Southern District of New York and the District of New Jersey - whose authority to institute criminal charges against Epstein in their districts has not\n\n11 Significantly, under the governing provision of the United States Attorney's Manual, the USAO-SDFL did not have the authority to unilaterally bar Epstein's prosecution in any other district in the country:\n\nNo district or division shall make any agreement, including any agreement not to prosecute, which purports to bind any other district(s) or division without the express written approval of the United States Attorney(s) in each affected district and/or the Assistant Attorney General of the Criminal Division.\n\nUSAM 9-27.641 (Multi-District (Global) Agreement Requests).\n\n12 The government acknowledges that this Court has nonetheless ruled that \"as a matter of law the CVRA can apply before formal charges are filed,\" DE 99 at 10; see also id. at 6-9, but has not yet determined \"whether the particular rights asserted here attached,\" id. at 10.\n\n11",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Agreement. The Non-Prosecution Agreement does not bar the United States from bringing federal criminal charges against Epstein for the offenses set forth in the Non-Prosecution Agreement in any other district in the nation.11 See, e.g., United States v. Cain, 587 F.2d 678, 680 (5th Cir. 1979) (\"Where . . . the prosecutor is not found to have made promises relating to nonprosecution of charges in another district and the [defendant] is not found to have relied on such alleged promises, this Court will affirm the trial court's denial of a motion to dismiss the subsequent prosecutions.\") Neither does the Non-Prosecution Agreement bar prosecution in any district for offenses not identified in the agreement.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Petitioners contend that the CVRA gives a victim the right to confer with the attorney for the government before there is a disposition of contemplated, but-not-yet-filed federal criminal charges arising from offenses against the victim. But, although the government disputes that the CVRA creates such a right,12 the Petitioners have never been denied any such right. The Petitioners have had and still have the ability confer to with the attorney for the government about potential federal criminal charges against Epstein and about the potential disposition of any such charges, should they be filed. In fact, Petitioners are free to approach the United States Attorney's Offices in districts such as the Southern District of New York and the District of New Jersey - whose authority to institute criminal charges against Epstein in their districts has not",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "11 Significantly, under the governing provision of the United States Attorney's Manual, the USAO-SDFL did not have the authority to unilaterally bar Epstein's prosecution in any other district in the country:\n\nNo district or division shall make any agreement, including any agreement not to prosecute, which purports to bind any other district(s) or division without the express written approval of the United States Attorney(s) in each affected district and/or the Assistant Attorney General of the Criminal Division.\n\nUSAM 9-27.641 (Multi-District (Global) Agreement Requests).",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "12 The government acknowledges that this Court has nonetheless ruled that \"as a matter of law the CVRA can apply before formal charges are filed,\" DE 99 at 10; see also id. at 6-9, but has not yet determined \"whether the particular rights asserted here attached,\" id. at 10.",
      "position": "bottom"
    }
  ],
  "entities": {
    "people": [
      "Epstein"
    ],
    "organizations": [
      "United States Attorney's Office",
      "Criminal Division"
    ],
    "locations": [
      "Southern District of New York",
      "District of New Jersey"
    ],
    "dates": [
      "07/13/2010"
    ],
    "reference_numbers": [
      "9:08-cv-80736",
      "DE 99",
      "USAM 9-27.641"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Epstein, with discussions around the Non-Prosecution Agreement and the Crime Victims' Rights Act (CVRA). The text is mostly printed, with no visible handwriting or stamps. The document is from page 12 of a larger filing."
}