mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00002967.json

{
  "document_metadata": {
    "page_number": "33",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "court document",
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    "has_stamps": false
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  "full_text": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 33 of 239\ndistrict in which the dismissed charges are initially brought. However, the law has evolved to the contrary. A plea agreement binds only the office of the United States Attorney for the district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.\nAnnabi, 771 F.2d at 672 (citations omitted). Thus, under Annabi and its progeny, a plea agreement only binds the U.S. Attorney's Office that executes the agreement, even if, as here, the agreement references \"the Government\" or \"the United States\" and even if the agreement lacks a provision that \"expressly limits the scope of the agreement to the district\" in which the agreement was entered.2\nConfronted with this clear and controlling authority, the defendant's motion attempts to limit the rule of Annabi by noting that some decisions applying Annabi concerned plea agreements that also included express provisions limiting the enforceability of the agreements to the districts in which they were entered. (Def. Mot. 1 at 22). Essentially, the defendant argues that without an express provision limiting the scope of the agreement, every plea agreement should be interpreted to bind the entire federal government. But the law in this Circuit holds the opposite: the presumption is that a plea agreement in one district does not bind another, absent an affirmative appearance that the agreement extends more broadly. See Laskow, 688 F. Supp. at 854 (\"Defendant's argument, in effect, is that unless there is an explicit statement to the contrary, it is presumed that a non-prosecution agreement binds offices of the United States Attorney that are\n2 The defendant's motion emphasizes that the Second Circuit has held, as a general matter, that plea agreements are construed against the Government. (Def. Mot. 1. at 13). That does not carry the day here, as Annabi provides a specific mode of analysis for determining whether a plea agreement applies to other districts, and the defendant's motion fails under Annabi. More broadly, the authorities the defendant cites for this general principle arise from circumstances in which a defendant has sought to enforce his own a plea agreement against the Government. (See, e.g., Def. Mot. 1 at 13 (citing United States v. Feldman, 939 F.3d 182, 189 (2d Cir. 2019) (analyzing claim by defendant seeking to enforce promises he claimed prosecutors had made to him)). Notably, the defendant has cited no authority for the proposition that plea agreements are to be construed in favor of a third party who was not involved in plea negotiations.\n6",
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      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 33 of 239",
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    {
      "type": "printed",
      "content": "district in which the dismissed charges are initially brought. However, the law has evolved to the contrary. A plea agreement binds only the office of the United States Attorney for the district in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.",
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      "content": "Annabi, 771 F.2d at 672 (citations omitted). Thus, under Annabi and its progeny, a plea agreement only binds the U.S. Attorney's Office that executes the agreement, even if, as here, the agreement references \"the Government\" or \"the United States\" and even if the agreement lacks a provision that \"expressly limits the scope of the agreement to the district\" in which the agreement was entered.2",
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      "content": "Confronted with this clear and controlling authority, the defendant's motion attempts to limit the rule of Annabi by noting that some decisions applying Annabi concerned plea agreements that also included express provisions limiting the enforceability of the agreements to the districts in which they were entered. (Def. Mot. 1 at 22). Essentially, the defendant argues that without an express provision limiting the scope of the agreement, every plea agreement should be interpreted to bind the entire federal government. But the law in this Circuit holds the opposite: the presumption is that a plea agreement in one district does not bind another, absent an affirmative appearance that the agreement extends more broadly. See Laskow, 688 F. Supp. at 854 (\"Defendant's argument, in effect, is that unless there is an explicit statement to the contrary, it is presumed that a non-prosecution agreement binds offices of the United States Attorney that are",
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      "content": "2 The defendant's motion emphasizes that the Second Circuit has held, as a general matter, that plea agreements are construed against the Government. (Def. Mot. 1. at 13). That does not carry the day here, as Annabi provides a specific mode of analysis for determining whether a plea agreement applies to other districts, and the defendant's motion fails under Annabi. More broadly, the authorities the defendant cites for this general principle arise from circumstances in which a defendant has sought to enforce his own a plea agreement against the Government. (See, e.g., Def. Mot. 1 at 13 (citing United States v. Feldman, 939 F.3d 182, 189 (2d Cir. 2019) (analyzing claim by defendant seeking to enforce promises he claimed prosecutors had made to him)). Notably, the defendant has cited no authority for the proposition that plea agreements are to be construed in favor of a third party who was not involved in plea negotiations.",
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  "entities": {
    "people": [],
    "organizations": [
      "United States Attorney",
      "Second Circuit",
      "Government"
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    "locations": [],
    "dates": [
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "771 F.2d at 672",
      "688 F. Supp. at 854",
      "939 F.3d 182, 189 (2d Cir. 2019)"
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