mirror-epstein-docs/results/IMAGES008/DOJ-OGR-00021679.json

{
  "document_metadata": {
    "page_number": "32",
    "document_number": "79",
    "date": "06/29/2023",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 22-1426, Document 79, 06/29/2023, 3536060, Page32 of 93\n\n19\nby officials of the USAO-SDFL and by no other components of the Department of Justice. Accordingly, the plain terms of the NPA make clear that the agreement only binds the USAO-SDFL.\n\nMaxwell's argument that the NPA binds the USAO-SDNY relies on a separate provision of the agreement, which says that \"the United States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to\" a list of four individuals that does not include the defendant (A.178). (Br.15, 33). But her argument that the term \"United States\" means the entire federal government requires the term to be read in isolation. As Judge Nathan explained, terms like \"the United States\" or \"the government\" are \"common shorthand\" for a single U.S. Attorney's Office, and \"a plea agreement need not painstakingly spell out 'the Office of the United States Attorney for Such-and-Such District' in every instance to make clear that it applies only in the district where signed\" (A.141). See Salameh, 152 F.3d at 120 (\"The mere use of the term 'government' in the plea agreement does not create an affirmative appearance that the agreement contemplated barring districts other than the particular district entering into the agreement.\"); United States v. Gonzalez, 93 F. App'x 268, 270 (2d Cir. 2004) (\"Although paragraph 12(b) uses the term 'United States' rather than the term 'government,' this is a distinction from our prior caselaw without a difference.\").\n\nReading the NPA as a whole confirms that conclusion. The very next sentence of the agreement states\n\nDOJ-OGR-00021679",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 22-1426, Document 79, 06/29/2023, 3536060, Page32 of 93",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "19\nby officials of the USAO-SDFL and by no other components of the Department of Justice. Accordingly, the plain terms of the NPA make clear that the agreement only binds the USAO-SDFL.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Maxwell's argument that the NPA binds the USAO-SDNY relies on a separate provision of the agreement, which says that \"the United States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to\" a list of four individuals that does not include the defendant (A.178). (Br.15, 33). But her argument that the term \"United States\" means the entire federal government requires the term to be read in isolation. As Judge Nathan explained, terms like \"the United States\" or \"the government\" are \"common shorthand\" for a single U.S. Attorney's Office, and \"a plea agreement need not painstakingly spell out 'the Office of the United States Attorney for Such-and-Such District' in every instance to make clear that it applies only in the district where signed\" (A.141). See Salameh, 152 F.3d at 120 (\"The mere use of the term 'government' in the plea agreement does not create an affirmative appearance that the agreement contemplated barring districts other than the particular district entering into the agreement.\"); United States v. Gonzalez, 93 F. App'x 268, 270 (2d Cir. 2004) (\"Although paragraph 12(b) uses the term 'United States' rather than the term 'government,' this is a distinction from our prior caselaw without a difference.\").",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Reading the NPA as a whole confirms that conclusion. The very next sentence of the agreement states",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00021679",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Maxwell",
      "Epstein",
      "Nathan"
    ],
    "organizations": [
      "USAO-SDFL",
      "USAO-SDNY",
      "Department of Justice"
    ],
    "locations": [],
    "dates": [
      "06/29/2023",
      "2004"
    ],
    "reference_numbers": [
      "22-1426",
      "79",
      "3536060",
      "DOJ-OGR-00021679"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Maxwell. The text discusses the interpretation of a Non-Prosecution Agreement (NPA) and its implications for the case."
}