mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00004977.json

{
  "document_metadata": {
    "page_number": "3",
    "document_number": "317",
    "date": "08/13/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 317 Filed 08/13/21 Page 3 of 14\nrenewed motion for substantially the same reasons set forth in its April 16 opinion. The Court will proceed to briefly explain why neither the new charges in the S2 superseding indictment nor the supplemental authority Maxwell cites change the Court's conclusion that the NPA does not bar the charges against her.\nAs the Court explained in its April 16, 2021 Opinion & Order, the Second Circuit held in United States v. Annabi that \"[a] plea agreement binds only the office of the United States Attorney for the district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.\" 771 F.2d 670, 672 (2d Cir. 1985) (per curiam). The Second Circuit's opinion in Annabi is clear, and that court has followed it steadfastly since. See, e.g., United States v. Gonzalez, 93 F. App'x 268, 270 (2d Cir. 2004); United States v. Brown, No. 99-1230(L), 2002 WL 34244994, at *2 (2d Cir. Apr. 26, 2002); United States v. Salameh, 152 F.3d 88, 120 (2d Cir. 1998) (per curiam); United States v. Rivera, 844 F.2d 916, 923 (2d Cir. 1988). The Second Circuit has held that language nearly identical to that in Epstein's NPA is not enough to overcome the presumption in favor of single-district plea agreements. See Salameh, 152 F.3d at 120. Adhering to this binding authority, this Court thus concluded (and continues to conclude) that the NPA does not bind the U.S. Attorney's Office for the Southern District of New York. It thus provides Maxwell no defense in this case even if it would otherwise cover the conduct charged in the new counts in the S2 superseding indictment.\nMaxwell advances two new arguments for why the Court should depart from this reasoning—the first in her renewed motion and the second in a letter of supplemental authority. See Dkt. Nos. 293, 310. In her renewed motion, she contends that Annabi contains an exception for out-of-district prosecutions for charges that are \"identical to the dismissed charges.\" And in the letter of supplemental authority, she contends that the opinion of the Pennsylvania Supreme",
  "text_blocks": [
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      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 317 Filed 08/13/21 Page 3 of 14",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "renewed motion for substantially the same reasons set forth in its April 16 opinion. The Court will proceed to briefly explain why neither the new charges in the S2 superseding indictment nor the supplemental authority Maxwell cites change the Court's conclusion that the NPA does not bar the charges against her.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "As the Court explained in its April 16, 2021 Opinion & Order, the Second Circuit held in United States v. Annabi that \"[a] plea agreement binds only the office of the United States Attorney for the district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.\" 771 F.2d 670, 672 (2d Cir. 1985) (per curiam). The Second Circuit's opinion in Annabi is clear, and that court has followed it steadfastly since. See, e.g., United States v. Gonzalez, 93 F. App'x 268, 270 (2d Cir. 2004); United States v. Brown, No. 99-1230(L), 2002 WL 34244994, at *2 (2d Cir. Apr. 26, 2002); United States v. Salameh, 152 F.3d 88, 120 (2d Cir. 1998) (per curiam); United States v. Rivera, 844 F.2d 916, 923 (2d Cir. 1988). The Second Circuit has held that language nearly identical to that in Epstein's NPA is not enough to overcome the presumption in favor of single-district plea agreements. See Salameh, 152 F.3d at 120. Adhering to this binding authority, this Court thus concluded (and continues to conclude) that the NPA does not bind the U.S. Attorney's Office for the Southern District of New York. It thus provides Maxwell no defense in this case even if it would otherwise cover the conduct charged in the new counts in the S2 superseding indictment.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Maxwell advances two new arguments for why the Court should depart from this reasoning—the first in her renewed motion and the second in a letter of supplemental authority. See Dkt. Nos. 293, 310. In her renewed motion, she contends that Annabi contains an exception for out-of-district prosecutions for charges that are \"identical to the dismissed charges.\" And in the letter of supplemental authority, she contends that the opinion of the Pennsylvania Supreme",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "3",
      "position": "footer"
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    {
      "type": "printed",
      "content": "DOJ-OGR-00004977",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell",
      "Epstein",
      "Annabi",
      "Gonzalez",
      "Brown",
      "Salameh",
      "Rivera"
    ],
    "organizations": [
      "U.S. Attorney's Office",
      "Second Circuit",
      "Pennsylvania Supreme Court"
    ],
    "locations": [
      "Southern District of New York",
      "Pennsylvania"
    ],
    "dates": [
      "April 16, 2021",
      "08/13/21",
      "April 26, 2002"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 317",
      "Dkt. Nos. 293, 310",
      "771 F.2d 670",
      "93 F. App'x 268",
      "152 F.3d 88",
      "844 F.2d 916"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is mostly clear, but there may be some minor formatting issues due to the original document's layout."
}