{
  "document_metadata": {
    "page_number": "27",
    "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 27 of 38\n\nHere, we understood that senior levels of Main Justice were directly involved in the negotiation and approval of the NPA, and the NPA itself reflects the involvement of the FBI. NPA at 1. Moreover, the USAO-SDFL's involvement of the USAO for this District in its investigation of Epstein, as well as its contact with witnesses in New York, reflect a coordinated effort that transcended the USAO-SDFL. SDFL Privilege Log at 4, 5, 7. From these facts, it affirmatively appears that the government had every reason to foresee a potential prosecution of Epstein's co-conspirators in this District and, after multiple layers of review within the Department of Justice, intended to agree to preclude it.\n\nb. The Second Circuit's subsequent application of Annabi supports Ms. Maxwell's position.\n\nIn nearly all of the cases in which the Second Circuit has reiterated its statement in Annabi in the context of written plea agreements, those agreements, unlike the NPA here, contained language expressly limiting the enforceability of the NPA to the district in which it was made. See, e.g., United States v. Prisco, 391 F. App'x 920, 921 (2d Cir. 2010) (\"agreement is limited to the United States Attorney's Office for the District of New Jersey and cannot bind other federal, state, or local authorities\"); United States v. Ashraf, 320 F. App'x 26, 28 (2d Cir. 2009) (plea agreement \"by its express terms, bound only the U.S. Attorney's Office for the Eastern District of Virginia\"); Gonzalez, 93 F. App'x at 270 (\"Paragraph 13 explicitly states that the agreement binds only the United States Attorney's Office for the District of New Mexico\"); United States v. Salameh, 152 F.3d 88, 119 (2d Cir. 1998) (\"[t]his agreement is limited to the United States Attorney's Office for the Eastern District of New York and cannot bind other federal, state or local prosecuting authorities\"); United States v. Persico, 620 F. Supp. 836, 846 (S.D.N.Y.) (finding agreements \"clearly indicate that the bargains are between the defendants and the Organized Crime Strike Force for the Eastern District of New York\" and noting that one\n\n22\n\nDOJ-OGR-00002599",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 142 Filed 02/04/21 Page 27 of 38",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Here, we understood that senior levels of Main Justice were directly involved in the negotiation and approval of the NPA, and the NPA itself reflects the involvement of the FBI. NPA at 1. Moreover, the USAO-SDFL's involvement of the USAO for this District in its investigation of Epstein, as well as its contact with witnesses in New York, reflect a coordinated effort that transcended the USAO-SDFL. SDFL Privilege Log at 4, 5, 7. From these facts, it affirmatively appears that the government had every reason to foresee a potential prosecution of Epstein's co-conspirators in this District and, after multiple layers of review within the Department of Justice, intended to agree to preclude it.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "b. The Second Circuit's subsequent application of Annabi supports Ms. Maxwell's position.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "In nearly all of the cases in which the Second Circuit has reiterated its statement in Annabi in the context of written plea agreements, those agreements, unlike the NPA here, contained language expressly limiting the enforceability of the NPA to the district in which it was made. See, e.g., United States v. Prisco, 391 F. App'x 920, 921 (2d Cir. 2010) (\"agreement is limited to the United States Attorney's Office for the District of New Jersey and cannot bind other federal, state, or local authorities\"); United States v. Ashraf, 320 F. App'x 26, 28 (2d Cir. 2009) (plea agreement \"by its express terms, bound only the U.S. Attorney's Office for the Eastern District of Virginia\"); Gonzalez, 93 F. App'x at 270 (\"Paragraph 13 explicitly states that the agreement binds only the United States Attorney's Office for the District of New Mexico\"); United States v. Salameh, 152 F.3d 88, 119 (2d Cir. 1998) (\"[t]his agreement is limited to the United States Attorney's Office for the Eastern District of New York and cannot bind other federal, state or local prosecuting authorities\"); United States v. Persico, 620 F. Supp. 836, 846 (S.D.N.Y.) (finding agreements \"clearly indicate that the bargains are between the defendants and the Organized Crime Strike Force for the Eastern District of New York\" and noting that one",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "22",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002599",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein",
      "Maxwell",
      "Annabi",
      "Prisco",
      "Ashraf",
      "Gonzalez",
      "Salameh",
      "Persico"
    ],
    "organizations": [
      "FBI",
      "Department of Justice",
      "United States Attorney's Office",
      "Organized Crime Strike Force"
    ],
    "locations": [
      "New York",
      "New Jersey",
      "Virginia",
      "New Mexico",
      "Eastern District of New York",
      "Eastern District of Virginia",
      "District of New Mexico"
    ],
    "dates": [
      "02/04/21",
      "2010",
      "2009",
      "1998"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 142",
      "NPA at 1",
      "SDFL Privilege Log at 4, 5, 7",
      "391 F. App'x 920",
      "320 F. App'x 26",
      "93 F. App'x 270",
      "152 F.3d 88",
      "620 F. Supp. 836",
      "DOJ-OGR-00002599"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell, discussing the implications of a non-prosecution agreement (NPA) and referencing various legal precedents and court decisions."
}