{
  "document_metadata": {
    "page_number": "43",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 43 of 239\noffenses enumerated in the NPA.9 While these same limitations are not repeated in the provision that purports to immunize \"co-conspirators,\" these limitations apply with equal force across the agreement, because that is the only common-sense way to read the NPA. Indeed, and as noted above in a related context, it would be exceedingly strange to interpret the \"co-conspirator\" provision to extend broader immunity than Epstein negotiated for himself.\n\nThe defendant may assert that the \"co-conspirator\" provision has absolutely no limitations, but such an argument would lead to absurd results. In particular, in arguing that the \"co-conspirator\" provision lacks any temporal or statutory limitations whatsoever, the defendant seems to claim that the NPA immunized her for future crimes including, for example, perjury offenses that she is charged with committing almost a decade after the NPA was executed. (Def. Mot. 1 at 32 (\"For the foregoing reasons, Ms. Maxwell respectfully requests that the Court dismiss the indictment.\")) Although the defendant does not highlight this point in her motion—perhaps recognizing how absurd it would be—that is the natural consequence of her illogical interpretation of the NPA. Despite advancing an argument that strains common sense, the defendant cites no case in which a court has interpreted a plea agreement to bar prosecution for crimes that pre- or post-dated the period covered by the agreement. The Government is aware of no such authority.\n\nSee United States v. Hallahan, 756 F.3d 962, 974 (7th Cir. 2014) (rejecting defense argument that plea agreement barred prosecution for subsequent bail jumping, and, in interpreting the\n9 By its plain terms, the NPA did not immunize Epstein for his \"background,\" as the defendant suggests. (Def. Mot. 1 at 27). This provision refers, instead, to a list of \"offenses\" under federal law. Indeed, it is unclear how any plea agreement could immunize a defendant's \"background.\" Similarly, the fact that the USAO-SDFL interviewed Minor Victim-2 does not mean that this case \"arose out of\" the USAO-SDFL investigation, an assertion the defendant's motion does not explain or support with evidence. As the Indictment makes clear, the events underpinning the Indictment involve multiple victims and specific legal charges that were not within the scope of the USAO-SDFL investigation. As discussed in greater detail below, Minor Victim-1 and Minor Victim-3 were never interviewed by the USAO-SDFL, and they did not agree to speak with law enforcement until 2019.\n16\nDOJ-OGR-00002977",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 43 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "offenses enumerated in the NPA.9 While these same limitations are not repeated in the provision that purports to immunize \"co-conspirators,\" these limitations apply with equal force across the agreement, because that is the only common-sense way to read the NPA. Indeed, and as noted above in a related context, it would be exceedingly strange to interpret the \"co-conspirator\" provision to extend broader immunity than Epstein negotiated for himself.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The defendant may assert that the \"co-conspirator\" provision has absolutely no limitations, but such an argument would lead to absurd results. In particular, in arguing that the \"co-conspirator\" provision lacks any temporal or statutory limitations whatsoever, the defendant seems to claim that the NPA immunized her for future crimes including, for example, perjury offenses that she is charged with committing almost a decade after the NPA was executed. (Def. Mot. 1 at 32 (\"For the foregoing reasons, Ms. Maxwell respectfully requests that the Court dismiss the indictment.\")) Although the defendant does not highlight this point in her motion—perhaps recognizing how absurd it would be—that is the natural consequence of her illogical interpretation of the NPA. Despite advancing an argument that strains common sense, the defendant cites no case in which a court has interpreted a plea agreement to bar prosecution for crimes that pre- or post-dated the period covered by the agreement. The Government is aware of no such authority.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "See United States v. Hallahan, 756 F.3d 962, 974 (7th Cir. 2014) (rejecting defense argument that plea agreement barred prosecution for subsequent bail jumping, and, in interpreting the",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "9 By its plain terms, the NPA did not immunize Epstein for his \"background,\" as the defendant suggests. (Def. Mot. 1 at 27). This provision refers, instead, to a list of \"offenses\" under federal law. Indeed, it is unclear how any plea agreement could immunize a defendant's \"background.\" Similarly, the fact that the USAO-SDFL interviewed Minor Victim-2 does not mean that this case \"arose out of\" the USAO-SDFL investigation, an assertion the defendant's motion does not explain or support with evidence. As the Indictment makes clear, the events underpinning the Indictment involve multiple victims and specific legal charges that were not within the scope of the USAO-SDFL investigation. As discussed in greater detail below, Minor Victim-1 and Minor Victim-3 were never interviewed by the USAO-SDFL, and they did not agree to speak with law enforcement until 2019.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "16",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002977",
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  ],
  "entities": {
    "people": [
      "Epstein",
      "Ms. Maxwell",
      "Minor Victim-1",
      "Minor Victim-2",
      "Minor Victim-3"
    ],
    "organizations": [
      "USAO-SDFL"
    ],
    "locations": [],
    "dates": [
      "04/16/21",
      "2019"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "DOJ-OGR-00002977"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of United States v. Maxwell. The text discusses the interpretation of a plea agreement and its implications for the defendant's immunity. The document includes citations to legal precedents and references to specific sections of the defendant's motion."
}