mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00002968.json

{
  "document_metadata": {
    "page_number": "34",
    "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 34 of 239\n\nnot parties to the agreement. This position is at odds with the law in this Circuit, which presumes\na narrow reading of the boundaries of a plea agreement unless a defendant can affirmatively\nestablish that a more expansive interpretation was contemplated.) (citing Annabi, 771 F.2d at\n672). To hold otherwise would turn Annabi on its head.\n\nThe defendant next argues that the following provision of the NPA evinces an intent to\nbind the entire federal government:\n\nIn consideration of Epstein's agreement to plead guilty and to\nprovide compensation in the manner described above, if Epstein\nsuccessfully fulfills all of the terms and conditions of this\nagreement, the United States also agrees that it will not institute any\ncriminal charges against any potential co-conspirators of Epstein,\nincluding but not limited to Sarah Kellen, Adriana Ross, Lesley\nGroff, or Nadia Marcinkova.\n\nNPA at 5; Def. Mot. 1 at 20-21. Aside from the reference to \"United States\" which, as noted\nabove, is insufficient, the defendant does not point to any language in this provision that\npurportedly binds other districts. Instead, she argues that the absence of language specifically\nlimiting this provision to the USAO-SDFL demonstrates an intent to bind the entire federal\ngovernment. This argument fails, for at least three reasons. First, the defendant's argument inverts\nthe holding of Annabi: in this Circuit, the presumption is that plea agreements bind only the district\nin which they are entered, absent affirmative indications otherwise. Put differently, the absence\nof express limiting language in this provision is not an affirmative indication of a broader\napplication. Accordingly, under Second Circuit law, the absence of limiting language in this\nspecific provision provides no support for the defendant's motion.\n\nSecond, the defendant's argument acknowledges that the plain terms of the NPA\nimmunized Epstein from prosecution in \"this District,\" that is, the Southern District of Florida.\nSee NPA at 2 (\"After timely fulfilling all the terms and conditions of the Agreement, no\n7\nDOJ-OGR-00002968",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 34 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "not parties to the agreement. This position is at odds with the law in this Circuit, which presumes\na narrow reading of the boundaries of a plea agreement unless a defendant can affirmatively\nestablish that a more expansive interpretation was contemplated.) (citing Annabi, 771 F.2d at\n672). To hold otherwise would turn Annabi on its head.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The defendant next argues that the following provision of the NPA evinces an intent to\nbind the entire federal government:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In consideration of Epstein's agreement to plead guilty and to\nprovide compensation in the manner described above, if Epstein\nsuccessfully fulfills all of the terms and conditions of this\nagreement, the United States also agrees that it will not institute any\ncriminal charges against any potential co-conspirators of Epstein,\nincluding but not limited to Sarah Kellen, Adriana Ross, Lesley\nGroff, or Nadia Marcinkova.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "NPA at 5; Def. Mot. 1 at 20-21. Aside from the reference to \"United States\" which, as noted\nabove, is insufficient, the defendant does not point to any language in this provision that\npurportedly binds other districts. Instead, she argues that the absence of language specifically\nlimiting this provision to the USAO-SDFL demonstrates an intent to bind the entire federal\ngovernment. This argument fails, for at least three reasons. First, the defendant's argument inverts\nthe holding of Annabi: in this Circuit, the presumption is that plea agreements bind only the district\nin which they are entered, absent affirmative indications otherwise. Put differently, the absence\nof express limiting language in this provision is not an affirmative indication of a broader\napplication. Accordingly, under Second Circuit law, the absence of limiting language in this\nspecific provision provides no support for the defendant's motion.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Second, the defendant's argument acknowledges that the plain terms of the NPA\nimmunized Epstein from prosecution in \"this District,\" that is, the Southern District of Florida.\nSee NPA at 2 (\"After timely fulfilling all the terms and conditions of the Agreement, no",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "7",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002968",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein",
      "Sarah Kellen",
      "Adriana Ross",
      "Lesley Groff",
      "Nadia Marcinkova",
      "Annabi"
    ],
    "organizations": [
      "United States",
      "USAO-SDFL"
    ],
    "locations": [
      "Southern District of Florida"
    ],
    "dates": [
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "DOJ-OGR-00002968"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Epstein. The text discusses the interpretation of a plea agreement and its implications for the federal government. The document is well-formatted and free of significant damage or redactions."
}