{
  "document_metadata": {
    "page_number": "4",
    "document_number": "317",
    "date": "08/13/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 317 Filed 08/13/21 Page 4 of 14\n\nCourt in Commonwealth v. Cosby, No. 39 MAP 2020, 2021 WL 2674380 (Pa. June 30, 2021), requires dismissal. Neither argument is persuasive.\n\nAnnabi contains no exception for out-of-district prosecutions for charges that are \"identical to the dismissed charges.\" In the language Maxwell cites from Annabi, the Second Circuit discussed (and rejected) a claim based on the Double Jeopardy Clause, not a claim based on the plea agreement in that case. See Annabi, 771 F.2d at 672. In that section of the opinion, the Second Circuit held that even if the charges had been identical to the dismissed charges, the defendants' double jeopardy claims would fail because they were never in jeopardy on the charges that were dismissed under the plea agreement. Nothing in Annabi suggests that the presumption in favor of single-district plea agreements does not apply if later charges in another district are sufficiently \"identical\" to the dismissed ones, and no subsequent Second Circuit case applying Annabi has so held. Annabi applies squarely to the facts of this case and binds this Court.\n\nThe Court also disagrees that Cosby mandates a different result. To begin with, this Court must follow the precedential opinions of the Second Circuit on questions of federal law, not those of a state court. Thus, nothing in Cosby could change this Court's view that Second Circuit precedent in Annabi forecloses Maxwell's arguments related to the NPA. In any event, the state court in Cosby did not purport to decide the same federal question at issue here. In Cosby, the court held that it was unfair for a district attorney to proceed with charges against Bill Cosby after the district attorney's office had, in that court's view of the facts, unequivocally promised that it would not charge him. Cosby, 2021 WL 2674380, at *34. That case did not involve a question of whether one office's promise bound another, much less whether a plea agreement in one federal district should be construed to apply in another district. Instead, the",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 317 Filed 08/13/21 Page 4 of 14",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Court in Commonwealth v. Cosby, No. 39 MAP 2020, 2021 WL 2674380 (Pa. June 30, 2021), requires dismissal. Neither argument is persuasive.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Annabi contains no exception for out-of-district prosecutions for charges that are \"identical to the dismissed charges.\" In the language Maxwell cites from Annabi, the Second Circuit discussed (and rejected) a claim based on the Double Jeopardy Clause, not a claim based on the plea agreement in that case. See Annabi, 771 F.2d at 672. In that section of the opinion, the Second Circuit held that even if the charges had been identical to the dismissed charges, the defendants' double jeopardy claims would fail because they were never in jeopardy on the charges that were dismissed under the plea agreement. Nothing in Annabi suggests that the presumption in favor of single-district plea agreements does not apply if later charges in another district are sufficiently \"identical\" to the dismissed ones, and no subsequent Second Circuit case applying Annabi has so held. Annabi applies squarely to the facts of this case and binds this Court.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The Court also disagrees that Cosby mandates a different result. To begin with, this Court must follow the precedential opinions of the Second Circuit on questions of federal law, not those of a state court. Thus, nothing in Cosby could change this Court's view that Second Circuit precedent in Annabi forecloses Maxwell's arguments related to the NPA. In any event, the state court in Cosby did not purport to decide the same federal question at issue here. In Cosby, the court held that it was unfair for a district attorney to proceed with charges against Bill Cosby after the district attorney's office had, in that court's view of the facts, unequivocally promised that it would not charge him. Cosby, 2021 WL 2674380, at *34. That case did not involve a question of whether one office's promise bound another, much less whether a plea agreement in one federal district should be construed to apply in another district. Instead, the",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "4",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004978",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell",
      "Bill Cosby"
    ],
    "organizations": [
      "Second Circuit"
    ],
    "locations": [
      "Pennsylvania"
    ],
    "dates": [
      "08/13/21",
      "June 30, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 317",
      "No. 39 MAP 2020",
      "2021 WL 2674380",
      "771 F.2d at 672"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Maxwell, with references to other legal cases and precedents. The text is printed and there are no visible stamps or handwritten notes."
}