{ "document_metadata": { "page_number": "22", "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 22 of 38\n\nprovider], employees of [its] subsidiaries, and subsidiary corporations of [the cargo provider and a related foreign airline].\n\nId.\n\nAn even more loosely defined immunity agreement was enforced in favor of a third party in United States v. El-Sadig, 133 F. Supp. 2d 600 (N.D. Ohio 2001). In El-Sadig, the court held that the defendant, who was alleged to have purchased firearms unlawfully for two members of the Saudi royal family who had traveled with a Saudi prince to the United States, had standing to enforce an oral agreement between the government and the prince not to prosecute any of the individuals involved in the purchase. 133 F. Supp. 2d at 601. The court concluded that \"even if the non-prosecution agreement was never directly communicated to [the defendant], he can enforce the non-prosecution agreement as a third party beneficiary.\" Id. at 608. Moreover, the court reasoned, because the prince himself \"was not involved in any of the illegal activity, his efforts to obtain a commitment not to prosecute were obviously intended by him to benefit third-parties,\" and therefore the defendant was a third-party beneficiary with standing to enforce the agreement. Id. at 609.\n\nBoth Florida West and El-Sadig illustrate how the government's argument that Ms. Maxwell lacks standing to enforce the NPA is contrary to bedrock principles of contract law, as applied to immunity agreements. Like Ms. Maxwell, the defendants in Florida West and El-Sadig were not parties to the agreements at issue. Like Ms. Maxwell, the defendants were not specifically named in the agreements. Yet in both cases, the courts held that the defendants were third-party beneficiaries with standing to enforce the agreements, because the parties to the agreements obviously intended to confer on them the benefit of immunity. Ms. Maxwell similarly has standing to enforce the co-conspirator immunity provision of the NPA, as the\n\n17\n\nDOJ-OGR-00002594", "text_blocks": [ { "type": "printed", "content": "Case 1:20-cr-00330-AJN Document 142 Filed 02/04/21 Page 22 of 38", "position": "header" }, { "type": "printed", "content": "provider], employees of [its] subsidiaries, and subsidiary corporations of [the cargo provider and a related foreign airline].\n\nId.\n\nAn even more loosely defined immunity agreement was enforced in favor of a third party in United States v. El-Sadig, 133 F. Supp. 2d 600 (N.D. Ohio 2001). In El-Sadig, the court held that the defendant, who was alleged to have purchased firearms unlawfully for two members of the Saudi royal family who had traveled with a Saudi prince to the United States, had standing to enforce an oral agreement between the government and the prince not to prosecute any of the individuals involved in the purchase. 133 F. Supp. 2d at 601. The court concluded that \"even if the non-prosecution agreement was never directly communicated to [the defendant], he can enforce the non-prosecution agreement as a third party beneficiary.\" Id. at 608. Moreover, the court reasoned, because the prince himself \"was not involved in any of the illegal activity, his efforts to obtain a commitment not to prosecute were obviously intended by him to benefit third-parties,\" and therefore the defendant was a third-party beneficiary with standing to enforce the agreement. Id. at 609.\n\nBoth Florida West and El-Sadig illustrate how the government's argument that Ms. Maxwell lacks standing to enforce the NPA is contrary to bedrock principles of contract law, as applied to immunity agreements. Like Ms. Maxwell, the defendants in Florida West and El-Sadig were not parties to the agreements at issue. Like Ms. Maxwell, the defendants were not specifically named in the agreements. Yet in both cases, the courts held that the defendants were third-party beneficiaries with standing to enforce the agreements, because the parties to the agreements obviously intended to confer on them the benefit of immunity. Ms. Maxwell similarly has standing to enforce the co-conspirator immunity provision of the NPA, as the", "position": "main content" }, { "type": "printed", "content": "17", "position": "footer" }, { "type": "printed", "content": "DOJ-OGR-00002594", "position": "footer" } ], "entities": { "people": [ "Ms. Maxwell", "El-Sadig" ], "organizations": [ "Saudi royal family" ], "locations": [ "United States", "Ohio" ], "dates": [ "02/04/21", "2001" ], "reference_numbers": [ "1:20-cr-00330-AJN", "Document 142", "133 F. Supp. 2d 600", "DOJ-OGR-00002594" ] }, "additional_notes": "The document appears to be a court filing related to a case involving Ms. Maxwell. The text discusses the enforceability of immunity agreements and cites relevant case law." }