{
  "document_metadata": {
    "page_number": "36",
    "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 36 of 239\nprosecutions by those two offices, and only those two offices.4 The defendant therefore cannot argue that the word \"global\" in this provision means that the NPA binds the entire federal government.\n\nIn sum, the defendant points to nothing in the text of the NPA that could possibly be construed to bind other districts. To the contrary, there are affirmative indications in the text that the NPA applies only to the USAO-SDFL. Accordingly, under Annabi, the NPA is only binding on the USAO-SDFL, and the defendant's motion fails as a matter of law.\n\n2. The Defendant Has Offered No Evidence That the NPA Binds Other Districts\n\nAlthough a defendant may offer evidence that the negotiations between the prosecutor and defendant contained a promise to bind other districts, Russo, 801 F.2d at 626, the defendant has failed to do so here. The defendant's motion is replete with bare assertions and conclusory allegations, but it fails to point to any evidence that the NPA binds the USAO-SDNY.\n\nThe lone document the defendant offers in support of her motion is a privilege log filed by the USAO-SDFL in connection with a lawsuit filed by Epstein's victims. (Def. Mot. 1 at 22). The log reflects that the FBI agents working with the USAO-SDFL interviewed witnesses in other states—including New York—during their investigation. That is entirely unremarkable, since federal investigations frequently involve gathering evidence in other states. This does not in any way establish the substantive involvement of any other districts in the prior investigation, let alone that the USAO-SDFL promised Epstein that the U.S. Attorney's offices in those states would be bound by the NPA.\n\n4 Interpreting the term \"federal liability\" in this provision could not be read to encompass all U.S. Attorney's offices without also interpreting its neighboring term, \"state . . . liability,\" to refer to every state prosecutor's office in all fifty states. The USAO-SDFL clearly did not—and could not—make such a broad promise.\n\n9\nDOJ-OGR-00002970",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 36 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "prosecutions by those two offices, and only those two offices.4 The defendant therefore cannot argue that the word \"global\" in this provision means that the NPA binds the entire federal government.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "In sum, the defendant points to nothing in the text of the NPA that could possibly be construed to bind other districts. To the contrary, there are affirmative indications in the text that the NPA applies only to the USAO-SDFL. Accordingly, under Annabi, the NPA is only binding on the USAO-SDFL, and the defendant's motion fails as a matter of law.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "2. The Defendant Has Offered No Evidence That the NPA Binds Other Districts",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Although a defendant may offer evidence that the negotiations between the prosecutor and defendant contained a promise to bind other districts, Russo, 801 F.2d at 626, the defendant has failed to do so here. The defendant's motion is replete with bare assertions and conclusory allegations, but it fails to point to any evidence that the NPA binds the USAO-SDNY.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The lone document the defendant offers in support of her motion is a privilege log filed by the USAO-SDFL in connection with a lawsuit filed by Epstein's victims. (Def. Mot. 1 at 22). The log reflects that the FBI agents working with the USAO-SDFL interviewed witnesses in other states—including New York—during their investigation. That is entirely unremarkable, since federal investigations frequently involve gathering evidence in other states. This does not in any way establish the substantive involvement of any other districts in the prior investigation, let alone that the USAO-SDFL promised Epstein that the U.S. Attorney's offices in those states would be bound by the NPA.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "4 Interpreting the term \"federal liability\" in this provision could not be read to encompass all U.S. Attorney's offices without also interpreting its neighboring term, \"state . . . liability,\" to refer to every state prosecutor's office in all fifty states. The USAO-SDFL clearly did not—and could not—make such a broad promise.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "9",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002970",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein"
    ],
    "organizations": [
      "USAO-SDFL",
      "USAO-SDNY",
      "FBI",
      "DOJ"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "DOJ-OGR-00002970"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a case involving Epstein. The text is printed and there are no visible stamps or handwritten notes. The document is page 36 of 239."
}