{
  "document_metadata": {
    "page_number": "13",
    "document_number": "87",
    "date": "07/27/2023",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 22-1426, Document 87, 07/27/2023, 3548202, Page13 of 35\n\nU.S. Attorney's Office investigation, and any offenses that arose from the related grand jury investigation.\"); cf. Florida West, 853 F.Supp.2d at 1228-29.\n\nB. The Co-Conspirators Provision of the Non-Prosecution Agreement Binds the USAO-SDNY and Annabi is not to the Contrary.\n\nEmbedded within Annabi's canon of construction that prosecutors in one district cannot bind prosecutors in another district, is a requirement that there must be a complete absence of language expressing a broader intention. Thus, if \"it affirmatively appears that the agreement contemplates a broader restriction,\" Annabi's restrictive rule does not apply. U.S. v. Russo, 801 F.2d 624, 626 (2d Cir. 1986).\n\nThe language expressing a broader intention can be found in the NPA, which (1) explicitly states that “the United States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein” (A178), (2) contains a structural separation of this clause from the more restrictive language used elsewhere, and (3) utilizes the expressed language that Epstein intended a “global” agreement. Obviously, an intent to limit the immunity afforded the co-conspirators easily could have been made explicit by the incorporation of limiting language. No such language was utilized and was, in fact, removed from the co-conspirator clause.\n\nA promise to bind other districts can be inferred from negotiations between a defendant and a prosecutor. See United States v. Alessi, 554 F2d 1139,1153-4 (2d\n\n7\n\nDOJ-OGR-00021755",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 22-1426, Document 87, 07/27/2023, 3548202, Page13 of 35",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "U.S. Attorney's Office investigation, and any offenses that arose from the related grand jury investigation.\"); cf. Florida West, 853 F.Supp.2d at 1228-29.\n\nB. The Co-Conspirators Provision of the Non-Prosecution Agreement Binds the USAO-SDNY and Annabi is not to the Contrary.\n\nEmbedded within Annabi's canon of construction that prosecutors in one district cannot bind prosecutors in another district, is a requirement that there must be a complete absence of language expressing a broader intention. Thus, if \"it affirmatively appears that the agreement contemplates a broader restriction,\" Annabi's restrictive rule does not apply. U.S. v. Russo, 801 F.2d 624, 626 (2d Cir. 1986).\n\nThe language expressing a broader intention can be found in the NPA, which (1) explicitly states that “the United States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein” (A178), (2) contains a structural separation of this clause from the more restrictive language used elsewhere, and (3) utilizes the expressed language that Epstein intended a “global” agreement. Obviously, an intent to limit the immunity afforded the co-conspirators easily could have been made explicit by the incorporation of limiting language. No such language was utilized and was, in fact, removed from the co-conspirator clause.\n\nA promise to bind other districts can be inferred from negotiations between a defendant and a prosecutor. See United States v. Alessi, 554 F2d 1139,1153-4 (2d",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "7",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00021755",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein",
      "Annabi",
      "Russo",
      "Alessi"
    ],
    "organizations": [
      "U.S. Attorney's Office",
      "USAO-SDNY",
      "DOJ"
    ],
    "locations": [
      "Florida"
    ],
    "dates": [
      "07/27/2023",
      "1986"
    ],
    "reference_numbers": [
      "22-1426",
      "87",
      "3548202",
      "A178",
      "DOJ-OGR-00021755"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a case involving Epstein and co-conspirators. The text discusses the implications of a non-prosecution agreement and its binding effects on different districts."
}