mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00002978.json

{
  "document_metadata": {
    "page_number": "44",
    "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 44 of 239\n\nGovernment's promises in the plea agreement to only cover past crimes, observing that \"not limiting the prohibition to past crimes would make it absurd and probably illegal\") (citing Aronson v. K. Arakelian, Inc., 154 F.2d 231, 233 (7th Cir. 1946) (\"[A] contract will not be presumed to have imposed an absurd or impossible condition on one of the parties, but will be interpreted as the parties must be supposed to have understood the conditions at the time.\")).\n\nFinally, the defendant claims that the NPA covers all violations of the Mann Act. (Def. Mot. 1 at 26 n.4). Not so. The NPA lists specific statutory provisions within the Mann Act, but none of the provisions contained in the Indictment. In particular, the NPA expressly covers violations of 18 U.S.C. §§ 2422(b), 2423(b), and 2423(e), but it does not include the particular provisions charged in the Indictment against Maxwell, which alleges violations of §§ 2422(a) and 2423(a). These are plainly not the same crimes, and a plea agreement cannot be read to immunize unnamed crimes in the general ballpark of the specific crimes enumerated in the agreement. The defendant cites no authority that supports her overbroad reading of this provision.\n\nAccordingly, the NPA immunizes only certain, specific offenses, none of which are contained in the Indictment. As a result, the defendant cannot invoke the NPA to seek the dismissal of the Indictment.\n\n2. The NPA Does Not Confer Enforceable Rights on Maxwell\n\nEven if this Court were to construe the NPA beyond its plain terms to preclude prosecutions for the crimes contained in the Indictment, the defendant has established neither that those protections extend to Maxwell specifically, nor that she has standing to pursue those protections.\n\nThe defendant asks this Court to interpret the NPA according to contract principles, and accord the defendant standing to enforce the NPA as a third party beneficiary. As a general matter, plea agreements are interpreted using principles from contract law, but that maxim is not without\n\n17\n\nDOJ-OGR-00002978",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 44 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Government's promises in the plea agreement to only cover past crimes, observing that \"not limiting the prohibition to past crimes would make it absurd and probably illegal\") (citing Aronson v. K. Arakelian, Inc., 154 F.2d 231, 233 (7th Cir. 1946) (\"[A] contract will not be presumed to have imposed an absurd or impossible condition on one of the parties, but will be interpreted as the parties must be supposed to have understood the conditions at the time.\")).",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Finally, the defendant claims that the NPA covers all violations of the Mann Act. (Def. Mot. 1 at 26 n.4). Not so. The NPA lists specific statutory provisions within the Mann Act, but none of the provisions contained in the Indictment. In particular, the NPA expressly covers violations of 18 U.S.C. §§ 2422(b), 2423(b), and 2423(e), but it does not include the particular provisions charged in the Indictment against Maxwell, which alleges violations of §§ 2422(a) and 2423(a). These are plainly not the same crimes, and a plea agreement cannot be read to immunize unnamed crimes in the general ballpark of the specific crimes enumerated in the agreement. The defendant cites no authority that supports her overbroad reading of this provision.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Accordingly, the NPA immunizes only certain, specific offenses, none of which are contained in the Indictment. As a result, the defendant cannot invoke the NPA to seek the dismissal of the Indictment.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "2. The NPA Does Not Confer Enforceable Rights on Maxwell",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Even if this Court were to construe the NPA beyond its plain terms to preclude prosecutions for the crimes contained in the Indictment, the defendant has established neither that those protections extend to Maxwell specifically, nor that she has standing to pursue those protections.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The defendant asks this Court to interpret the NPA according to contract principles, and accord the defendant standing to enforce the NPA as a third party beneficiary. As a general matter, plea agreements are interpreted using principles from contract law, but that maxim is not without",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "17",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002978",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "DOJ-OGR-00002978"
    ]
  },
  "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 page 44 of 239."
}