mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00004286.json

{
  "document_metadata": {
    "page_number": "21",
    "document_number": "293",
    "date": "05/25/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 293 Filed 05/25/21 Page 21 of 32\na non-prosecution agreement with another district would be a miscarriage of justice. See United States v. Carter, 454 F.2d 426, 427-28 (4th Cir. 1972) (federally prosecuting defendant a second time for the same charges previously resolved by a plea agreement with a different federal district puts at stake \"the honor of the government[,] public confidence in the fair administration of justice, and the efficient administration of justice in a federal scheme of government\"); Gebbie, 294 F.3d at 550 (\"United States Attorneys should not be viewed as sovereigns of autonomous fiefdoms. They represent the United States, and their promises on behalf of the Government must bind each other absent express contractual limitations or disavowals to the contrary.\"). For these reasons, the NPA bars the USAO-SDNY from prosecuting Ms. Maxwell for the offenses charged in Counts Five and Six of the S2 Indictment. They must therefore be dismissed.\n\nC. Counts One and Three Must Also Be Dismissed.\nBecause Counts Five and Six must be dismissed, the expanded Mann Act conspiracies charged in Counts One and Three must also be dismissed. In the S1 Indictment, the conspiracies charged in Counts One and Three were confined to a four-year period from 1994-1997, which the Court found was not covered by the NPA. (Dkt. 207 at 6-7). In the S2 Indictment, by contrast, the conspiracies charged in Counts One and Three cover a much broader timeframe from 1994-2004 because they incorporate the same conduct from 2001-2004 involving Accuser-4 charged in Counts Five and Six. As previously discussed, the NPA bars the government from prosecuting Ms. Maxwell for these offenses. Hence, as currently charged, the government could offer inadmissible evidence excluded by the NPA as proof of Counts One and Three. It would be impermissible for the jury to consider such evidence in connection with Counts One and Three and any guilty verdict based on proof related to Accuser-4, or any other conduct covered by the NPA, might require reversal. See United States v. Rooney, 37 F.3d 847, 855-56 (2d Cir.\n17\nDOJ-OGR-00004286",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 293 Filed 05/25/21 Page 21 of 32",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "a non-prosecution agreement with another district would be a miscarriage of justice. See United States v. Carter, 454 F.2d 426, 427-28 (4th Cir. 1972) (federally prosecuting defendant a second time for the same charges previously resolved by a plea agreement with a different federal district puts at stake \"the honor of the government[,] public confidence in the fair administration of justice, and the efficient administration of justice in a federal scheme of government\"); Gebbie, 294 F.3d at 550 (\"United States Attorneys should not be viewed as sovereigns of autonomous fiefdoms. They represent the United States, and their promises on behalf of the Government must bind each other absent express contractual limitations or disavowals to the contrary.\"). For these reasons, the NPA bars the USAO-SDNY from prosecuting Ms. Maxwell for the offenses charged in Counts Five and Six of the S2 Indictment. They must therefore be dismissed.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "C. Counts One and Three Must Also Be Dismissed.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Because Counts Five and Six must be dismissed, the expanded Mann Act conspiracies charged in Counts One and Three must also be dismissed. In the S1 Indictment, the conspiracies charged in Counts One and Three were confined to a four-year period from 1994-1997, which the Court found was not covered by the NPA. (Dkt. 207 at 6-7). In the S2 Indictment, by contrast, the conspiracies charged in Counts One and Three cover a much broader timeframe from 1994-2004 because they incorporate the same conduct from 2001-2004 involving Accuser-4 charged in Counts Five and Six. As previously discussed, the NPA bars the government from prosecuting Ms. Maxwell for these offenses. Hence, as currently charged, the government could offer inadmissible evidence excluded by the NPA as proof of Counts One and Three. It would be impermissible for the jury to consider such evidence in connection with Counts One and Three and any guilty verdict based on proof related to Accuser-4, or any other conduct covered by the NPA, might require reversal. See United States v. Rooney, 37 F.3d 847, 855-56 (2d Cir.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "17",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004286",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Carter",
      "Gebbie",
      "Maxwell",
      "Rooney",
      "Accuser-4"
    ],
    "organizations": [
      "United States Attorneys",
      "USAO-SDNY"
    ],
    "locations": [],
    "dates": [
      "05/25/21",
      "1994",
      "1997",
      "2001",
      "2004"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 293",
      "Dkt. 207",
      "DOJ-OGR-00004286"
    ]
  },
  "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 21 of 32."
}