{
  "document_metadata": {
    "page_number": "23",
    "document_number": "142",
    "date": "02/04/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-AJN Document 142 Filed 02/04/21 Page 23 of 38\n\nparties to the NPA clearly intended to confer immunity on potential co-conspirators of Epstein, such as Ms. Maxwell.\n\nB. The NPA's Prohibition on Prosecution of Potential Co-Conspirators Is Not Limited to the SDFL.\n\nThe NPA stands in contrast to the standard non-prosecution agreement used in this District and other jurisdictions, which typically is explicitly limited to prohibit only prosecutions by the USAO for the district in which the plea is entered. The standard agreement in this District contains the following language: \"It is further understood that this Agreement does not bind any federal, state, or local prosecuting authority other than this Office.\" See, e.g., Perez v. United States, Nos. 14 Civ. 846, 04 Cr. 937-1, 2015 WL 3413596 , at *8 (S.D.N.Y. 2015). No such language is included in the NPA. Moreover, unlike the standard agreement, the NPA refers separately to \"the United States\" in some places and to the USAO-SDFL in others, in ways that make clear that any reference to \"the United States\" was intended to refer to the government as a whole, not merely the USAO-SDFL.\n\n1. The NPA is binding on the USAO in this District.\n\nThe government's contention that the NPA does not bind the USAO in this District cannot be squared with the clear language of the co-conspirator immunity provision. On its face, that provision does not limit the preclusive effect of the NPA as to potential co-conspirators to prosecutions in the SDFL. Indeed, consistent with Epstein's desire to obtain the broadest immunity possible, the NPA expressly provides that, in exchange for Epstein's compliance with the terms and conditions therein, \"the United States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein,\" with no express geographic limitation. NPA at 5 (emphasis added). In contrast, the clauses regarding the non-prosecution of Epstein expressly defer \"prosecution in this District\" and provide that no prosecution for the\n\n18\n\nDOJ-OGR-00002595",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 142 Filed 02/04/21 Page 23 of 38",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "parties to the NPA clearly intended to confer immunity on potential co-conspirators of Epstein, such as Ms. Maxwell.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "B. The NPA's Prohibition on Prosecution of Potential Co-Conspirators Is Not Limited to the SDFL.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The NPA stands in contrast to the standard non-prosecution agreement used in this District and other jurisdictions, which typically is explicitly limited to prohibit only prosecutions by the USAO for the district in which the plea is entered. The standard agreement in this District contains the following language: \"It is further understood that this Agreement does not bind any federal, state, or local prosecuting authority other than this Office.\" See, e.g., Perez v. United States, Nos. 14 Civ. 846, 04 Cr. 937-1, 2015 WL 3413596 , at *8 (S.D.N.Y. 2015). No such language is included in the NPA. Moreover, unlike the standard agreement, the NPA refers separately to \"the United States\" in some places and to the USAO-SDFL in others, in ways that make clear that any reference to \"the United States\" was intended to refer to the government as a whole, not merely the USAO-SDFL.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1. The NPA is binding on the USAO in this District.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The government's contention that the NPA does not bind the USAO in this District cannot be squared with the clear language of the co-conspirator immunity provision. On its face, that provision does not limit the preclusive effect of the NPA as to potential co-conspirators to prosecutions in the SDFL. Indeed, consistent with Epstein's desire to obtain the broadest immunity possible, the NPA expressly provides that, in exchange for Epstein's compliance with the terms and conditions therein, \"the United States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein,\" with no express geographic limitation. NPA at 5 (emphasis added). In contrast, the clauses regarding the non-prosecution of Epstein expressly defer \"prosecution in this District\" and provide that no prosecution for the",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "18",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002595",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein",
      "Maxwell"
    ],
    "organizations": [
      "USAO",
      "USAO-SDFL"
    ],
    "locations": [
      "SDFL",
      "S.D.N.Y."
    ],
    "dates": [
      "02/04/21",
      "2015"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 142",
      "14 Civ. 846",
      "04 Cr. 937-1",
      "DOJ-OGR-00002595"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Jeffrey Epstein. The text discusses the Non-Prosecution Agreement (NPA) and its implications for potential co-conspirators. The document is well-formatted and free of significant damage or redactions."
}