DOJ-OGR-00021754.json 5.3 KB

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  1. {
  2. "document_metadata": {
  3. "page_number": "12",
  4. "document_number": "87",
  5. "date": "07/27/2023",
  6. "document_type": "Court Document",
  7. "has_handwriting": false,
  8. "has_stamps": false
  9. },
  10. "full_text": "Case 22-1426, Document 87, 07/27/2023, 3548202, Page12 of 35\n\n& Indemn. Co., 37 N.Y.2d 211, 219 (N.Y. 1975). And, as the court stated in Florida West, a plea agreement is enforceable by a third party as long as the \"[a]greement evince[s] an intent to extend [immunity] to a definable class of third parties\" and the third party seeking enforcement \"fall[s] within this category of beneficiaries.\" 853 F.Supp.2d at 1228-29; see id. at 1214 (defendant, as a third-party beneficiary, could enforce a plea agreement between the Government and an air cargo company, which immunized unnamed \"employees\" of the company's subsidiaries); see also Stolt-Nielsen, 524 F.Supp.2d at 613, 620 (defendants, as third-party beneficiaries, could enforce an agreement between the Government and Stolt-Nielsen, which promised leniency to unnamed directors, officers, and employees).\n\nHere, the NPA grants immunity to \"any potential co-conspirators of Epstein, including but not limited to [four named individuals].\" A178. As the District Court recognized, this is a definable class that includes Ms. Maxwell. A1443 (\"[T]he co-conspirator provision...cover[s] any involvement of Maxwell in offenses committed by Epstein from 2001 to 2007, other offenses that were the subject of the FBI and\n\n3 To the extent that the Government suggests that Ms. Maxwell is not a co-conspirator within the meaning of the NPA, the trial evidence demonstrated, according to the Government's main brief, that she was a member of the conspiracies charged in the indictment from 1994- 2004 in the SDNY and elsewhere. Moreover, there was significant overlap between the investigation in Florida and the trial. Specifically, investigators in Florida had interviewed Carolyn (SA86, SA72fn.72; SA193fn.241), Virginia Roberts (SA173fn.217, SA193fn.240, fn.241), and Annie Farmer (SA193fn.239).\n\n6\nDOJ-OGR-00021754",
  11. "text_blocks": [
  12. {
  13. "type": "printed",
  14. "content": "Case 22-1426, Document 87, 07/27/2023, 3548202, Page12 of 35",
  15. "position": "header"
  16. },
  17. {
  18. "type": "printed",
  19. "content": "& Indemn. Co., 37 N.Y.2d 211, 219 (N.Y. 1975). And, as the court stated in Florida West, a plea agreement is enforceable by a third party as long as the \"[a]greement evince[s] an intent to extend [immunity] to a definable class of third parties\" and the third party seeking enforcement \"fall[s] within this category of beneficiaries.\" 853 F.Supp.2d at 1228-29; see id. at 1214 (defendant, as a third-party beneficiary, could enforce a plea agreement between the Government and an air cargo company, which immunized unnamed \"employees\" of the company's subsidiaries); see also Stolt-Nielsen, 524 F.Supp.2d at 613, 620 (defendants, as third-party beneficiaries, could enforce an agreement between the Government and Stolt-Nielsen, which promised leniency to unnamed directors, officers, and employees).",
  20. "position": "top"
  21. },
  22. {
  23. "type": "printed",
  24. "content": "Here, the NPA grants immunity to \"any potential co-conspirators of Epstein, including but not limited to [four named individuals].\" A178. As the District Court recognized, this is a definable class that includes Ms. Maxwell. A1443 (\"[T]he co-conspirator provision...cover[s] any involvement of Maxwell in offenses committed by Epstein from 2001 to 2007, other offenses that were the subject of the FBI and",
  25. "position": "middle"
  26. },
  27. {
  28. "type": "printed",
  29. "content": "3 To the extent that the Government suggests that Ms. Maxwell is not a co-conspirator within the meaning of the NPA, the trial evidence demonstrated, according to the Government's main brief, that she was a member of the conspiracies charged in the indictment from 1994- 2004 in the SDNY and elsewhere. Moreover, there was significant overlap between the investigation in Florida and the trial. Specifically, investigators in Florida had interviewed Carolyn (SA86, SA72fn.72; SA193fn.241), Virginia Roberts (SA173fn.217, SA193fn.240, fn.241), and Annie Farmer (SA193fn.239).",
  30. "position": "bottom"
  31. },
  32. {
  33. "type": "printed",
  34. "content": "6",
  35. "position": "footer"
  36. },
  37. {
  38. "type": "printed",
  39. "content": "DOJ-OGR-00021754",
  40. "position": "footer"
  41. }
  42. ],
  43. "entities": {
  44. "people": [
  45. "Epstein",
  46. "Ms. Maxwell",
  47. "Carolyn",
  48. "Virginia Roberts",
  49. "Annie Farmer"
  50. ],
  51. "organizations": [
  52. "FBI",
  53. "SDNY",
  54. "Government"
  55. ],
  56. "locations": [
  57. "Florida",
  58. "New York"
  59. ],
  60. "dates": [
  61. "2001",
  62. "2007",
  63. "1994",
  64. "2004"
  65. ],
  66. "reference_numbers": [
  67. "22-1426",
  68. "87",
  69. "3548202",
  70. "A178",
  71. "A1443",
  72. "SA86",
  73. "SA72fn.72",
  74. "SA193fn.241",
  75. "SA173fn.217",
  76. "SA193fn.240",
  77. "SA193fn.239",
  78. "DOJ-OGR-00021754"
  79. ]
  80. },
  81. "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell, discussing the enforceability of a plea agreement and the grant of immunity to potential co-conspirators of Epstein. The text is printed and there are no visible stamps or handwritten notes."
  82. }