mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00002980.json

{
  "document_metadata": {
    "page_number": "46",
    "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 46 of 239\n\nrespects from those underlying contract law, the district court concluded that \"third-party beneficiaries have no contractual right to enforce plea agreements.\" Id. at *3-4. The court reasoned, \"[t]he right to enforce a plea deal does not exist for its own sake; rather, it is a means to achieve fairness in plea bargaining.\" Id. at *4. That is because a defendant has the right to enforce his plea agreement, and \"enforcement by third parties adds nothing to protecting the defendant's right.\" Id. The same holds true here.\n\nIn support of her claim that she has standing to enforce the NPA, the defendant relies upon three district court decisions, none of which analyzed the threshold question of whether third party standing concepts from contract law apply to plea agreements. In United States v. Florida West Int'l Airways, Inc., 853 F. Supp. 2d 1209, 1228 (S.D. Fla. 2012), the district court applied the third party beneficiary doctrine to a former airline employee based on a prior plea agreement with the airline that immunized, among others, current and former employees of the airline and its subsidiaries. In its analysis, however, the court applied the doctrine without analyzing the question of whether third party beneficiary standing principles apply to plea agreements. Id. For similar reasons, the defendant's reliance on United States v. El-Sadig, 133 F. Supp. 2d 600, 608-09 (N.D. Ohio 2001) is misplaced. In that case, the court permitted a third party to invoke a plea agreement, but it did not analyze or address whether third party standing rules apply to plea agreements. Id. Likewise, in United States v. CFW Const. Co., 583 F. Supp. 197, 203 (D.S.C. 1984), the court applied the third party beneficiary doctrine, but relied solely on contracts treatises for support, and did not analyze whether that doctrine should be applied to plea agreements.\n\nIn any event, even if third party beneficiaries had standing to enforce federal plea agreements, the defendant has failed to establish that she is a third party beneficiary of the NPA. In order to establish that she has enforceable rights under the NPA, the defendant must show that\n\n19\n\nDOJ-OGR-00002980",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 46 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "respects from those underlying contract law, the district court concluded that \"third-party beneficiaries have no contractual right to enforce plea agreements.\" Id. at *3-4. The court reasoned, \"[t]he right to enforce a plea deal does not exist for its own sake; rather, it is a means to achieve fairness in plea bargaining.\" Id. at *4. That is because a defendant has the right to enforce his plea agreement, and \"enforcement by third parties adds nothing to protecting the defendant's right.\" Id. The same holds true here.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "In support of her claim that she has standing to enforce the NPA, the defendant relies upon three district court decisions, none of which analyzed the threshold question of whether third party standing concepts from contract law apply to plea agreements. In United States v. Florida West Int'l Airways, Inc., 853 F. Supp. 2d 1209, 1228 (S.D. Fla. 2012), the district court applied the third party beneficiary doctrine to a former airline employee based on a prior plea agreement with the airline that immunized, among others, current and former employees of the airline and its subsidiaries. In its analysis, however, the court applied the doctrine without analyzing the question of whether third party beneficiary standing principles apply to plea agreements. Id. For similar reasons, the defendant's reliance on United States v. El-Sadig, 133 F. Supp. 2d 600, 608-09 (N.D. Ohio 2001) is misplaced. In that case, the court permitted a third party to invoke a plea agreement, but it did not analyze or address whether third party standing rules apply to plea agreements. Id. Likewise, in United States v. CFW Const. Co., 583 F. Supp. 197, 203 (D.S.C. 1984), the court applied the third party beneficiary doctrine, but relied solely on contracts treatises for support, and did not analyze whether that doctrine should be applied to plea agreements.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "In any event, even if third party beneficiaries had standing to enforce federal plea agreements, the defendant has failed to establish that she is a third party beneficiary of the NPA. In order to establish that she has enforceable rights under the NPA, the defendant must show that",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "19",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002980",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [],
    "organizations": [
      "DOJ"
    ],
    "locations": [
      "Florida",
      "Ohio",
      "South Carolina"
    ],
    "dates": [
      "04/16/21",
      "2012",
      "2001",
      "1984"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 204",
      "DOJ-OGR-00002980"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case. The text is printed and there are no visible stamps or handwritten notes. The document is likely a page from a larger filing."
}