{
  "document_metadata": {
    "page_number": "18 of 38",
    "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 18 of 38\n\nagreement is not simply a party to a contract. The Government is required to observe high standards of integrity and honorable conduct, and the supervisory power of the court is designed to insure that such standards are observed.\") Thus, plea agreements are construed \"strictly against the government.\" United States v. Feldman, 939 F.3d 182, 189 (2d Cir. 2019) (quoting United States v. Vaval, 404 F.3d 144, 152 (2d Cir. 2005)). \"Because such agreements involve waivers of fundamental constitutional rights, \"prosecutors are held to meticulous standards of performance.\" Feldman, 939 F.3d at 189 (quoting Vaval, 404 F.3d at 153). Finally, \"[t]he prosecutor's office is an entity and as such it is the spokesman for the Government. A promise made by one attorney must be attributed . . . to the Government.\" Feldman, 939 F.3d at 190 (quoting Giglio v. United States, 405 U.S. 150, 154 (1972)).\n\nThe government's attempt to evade the NPA flies in the face of these time-honored, and honorable, principles. Rather than stand behind the promises it made in the NPA, the government tries to escape them by arguing that Ms. Maxwell has no standing to enforce them—a position that is contradicted by the unambiguous text of the NPA as well as by clear precedent.\n\nThe government also tries to pretend that the NPA contains geographical and temporal limitations that simply do not exist. In doing so, the government essentially turns the principles underlying the interpretation and enforcement of such agreements on their head. Confronted with an NPA that, in hindsight, the government wishes had been negotiated and drafted differently, the government cannot now manufacture ambiguity where none exists and cannot now demand that the court construe such purported ambiguity in the government's favor, when it is a well-established principle that it must be construed in the defendant's favor.\n\nHere, it is wholly unnecessary for the Court to look beyond the four corners of the NPA to determine that it bars Ms. Maxwell's prosecution. However, the Court can be comfortable\n\n13\n\nDOJ-OGR-00002590",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-AJN Document 142 Filed 02/04/21 Page 18 of 38",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "agreement is not simply a party to a contract. The Government is required to observe high standards of integrity and honorable conduct, and the supervisory power of the court is designed to insure that such standards are observed.\") Thus, plea agreements are construed \"strictly against the government.\" United States v. Feldman, 939 F.3d 182, 189 (2d Cir. 2019) (quoting United States v. Vaval, 404 F.3d 144, 152 (2d Cir. 2005)). \"Because such agreements involve waivers of fundamental constitutional rights, \"prosecutors are held to meticulous standards of performance.\" Feldman, 939 F.3d at 189 (quoting Vaval, 404 F.3d at 153). Finally, \"[t]he prosecutor's office is an entity and as such it is the spokesman for the Government. A promise made by one attorney must be attributed . . . to the Government.\" Feldman, 939 F.3d at 190 (quoting Giglio v. United States, 405 U.S. 150, 154 (1972)).",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The government's attempt to evade the NPA flies in the face of these time-honored, and honorable, principles. Rather than stand behind the promises it made in the NPA, the government tries to escape them by arguing that Ms. Maxwell has no standing to enforce them—a position that is contradicted by the unambiguous text of the NPA as well as by clear precedent.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The government also tries to pretend that the NPA contains geographical and temporal limitations that simply do not exist. In doing so, the government essentially turns the principles underlying the interpretation and enforcement of such agreements on their head. Confronted with an NPA that, in hindsight, the government wishes had been negotiated and drafted differently, the government cannot now manufacture ambiguity where none exists and cannot now demand that the court construe such purported ambiguity in the government's favor, when it is a well-established principle that it must be construed in the defendant's favor.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Here, it is wholly unnecessary for the Court to look beyond the four corners of the NPA to determine that it bars Ms. Maxwell's prosecution. However, the Court can be comfortable",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "13",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002590",
      "position": "footer"
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  ],
  "entities": {
    "people": [
      "Maxwell"
    ],
    "organizations": [
      "Government",
      "Court",
      "prosecutor's office"
    ],
    "locations": [],
    "dates": [
      "02/04/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-AJN",
      "Document 142",
      "DOJ-OGR-00002590"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is page 18 of 38."
}