mirror-epstein-docs/results/IMAGES008/DOJ-OGR-00021094.json

{
  "document_metadata": {
    "page_number": "47",
    "document_number": "59",
    "date": "02/28/2023",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "them \"sufficiently distinct.\" A contrary rule—allowing the Government to gainsay a non-prosecution promise in plea agreement by hopping to a new district and prosecuting the same crime, covering the same time period—would upend federal plea bargaining nationally, disrupt expectations beyond this case, and turn the Second Circuit into a forum of convenience for the Government to reprosecute pled-out offenses that touch multiple federal districts. As the Fourth Circuit noted, prosecuting a defendant for the same charges resolved by plea agreement in a different district puts at stake “the honor of the government[,] public confidence in the fair administration of justice, and the efficient administration of justice in a federal scheme of government.” Carter, 454 F.2d at 427-28. Here, under the “sufficiently-distinct” qualification to Annabi, the Government was precluded, at minimum, from charging Appellant under Count Six. This count arose out of the 2006-08 SDFL investigation and is based on a trafficking statute, § 1591(a), that is explicitly mentioned in the NPA. A175. The only accuser on whom Count Six is based, Carolyn, was also a witness in the SDFL investigation. [T: 1604-5, 1614, 1679]. But unlike the SDNY charges in Annabi, Count Six falls wholly within the time period contemplated by the NPA as well. Compare 771 F.2d at 672. Count Six alleged that Defendant trafficked Carolyn from 2001 to 2004. The court held that the NPA “cover[s] any involvement of Maxwell in offenses committed by Epstein from 2001 to 2007,",
  "text_blocks": [
    {
      "type": "printed",
      "content": "them \"sufficiently distinct.\" A contrary rule—allowing the Government to gainsay a non-prosecution promise in plea agreement by hopping to a new district and prosecuting the same crime, covering the same time period—would upend federal plea bargaining nationally, disrupt expectations beyond this case, and turn the Second Circuit into a forum of convenience for the Government to reprosecute pled-out offenses that touch multiple federal districts. As the Fourth Circuit noted, prosecuting a defendant for the same charges resolved by plea agreement in a different district puts at stake “the honor of the government[,] public confidence in the fair administration of justice, and the efficient administration of justice in a federal scheme of government.” Carter, 454 F.2d at 427-28. Here, under the “sufficiently-distinct” qualification to Annabi, the Government was precluded, at minimum, from charging Appellant under Count Six. This count arose out of the 2006-08 SDFL investigation and is based on a trafficking statute, § 1591(a), that is explicitly mentioned in the NPA. A175. The only accuser on whom Count Six is based, Carolyn, was also a witness in the SDFL investigation. [T: 1604-5, 1614, 1679]. But unlike the SDNY charges in Annabi, Count Six falls wholly within the time period contemplated by the NPA as well. Compare 771 F.2d at 672. Count Six alleged that Defendant trafficked Carolyn from 2001 to 2004. The court held that the NPA “cover[s] any involvement of Maxwell in offenses committed by Epstein from 2001 to 2007,",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "32",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00021094",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Carolyn",
      "Maxwell",
      "Epstein"
    ],
    "organizations": [
      "Government",
      "Second Circuit",
      "Fourth Circuit"
    ],
    "locations": [
      "SDFL",
      "SDNY"
    ],
    "dates": [
      "2001",
      "2004",
      "2006",
      "2007",
      "02/28/2023"
    ],
    "reference_numbers": [
      "22-1426",
      "Document 59",
      "3475902",
      "Page47 of 113",
      "454 F.2d",
      "771 F.2d",
      "§ 1591(a)",
      "A175",
      "T: 1604-5, 1614, 1679",
      "DOJ-OGR-00021094"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a case involving Maxwell and Epstein. The text discusses the implications of a non-prosecution agreement and its relation to the charges brought against the defendant."
}