DOJ-OGR-00021086.jpg

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Extraction Summary

1
People
4
Organizations
2
Locations
2
Events
1
Relationships
3
Quotes

Document Information

Type: Legal brief / appellate filing
File Size: 666 KB
Summary

This document is a page from an appellate legal brief (Case 22-1426) arguing that the District Court erred in applying the 'Annabi' legal precedent to the Appellant's case. The text argues that the Non-Prosecution Agreement (NPA) originated outside the Second Circuit and should not be subject to its specific legal canons, and further argues that the conduct charged in Count Six falls within the time period covered by the original NPA. The document specifically challenges the USAO-SDNY's charges relative to the 2001-2007 offense period.

People (1)

Name Role Context
Appellant Defendant/Appellant
Refers to the defendant in Case 22-1426 (likely Ghislaine Maxwell based on case number and context of NPA arguments).

Organizations (4)

Name Type Context
District Court
The lower court whose decision is being appealed.
Second Circuit
The appellate court jurisdiction mentioned regarding legal precedents.
USAO-SDNY
United States Attorney's Office for the Southern District of New York, which charged the Appellant.
DOJ-OGR
Department of Justice - Office of Government Relations (indicated in Bates stamp).

Timeline (2 events)

2001-2004
Period of conduct charged under Count Six
Not specified
2001-2007
Offense period contemplated by the NPA
Not specified

Locations (2)

Location Context
Jurisdiction whose laws are being discussed.
Location where the NPA originated (implied to be Southern District of Florida).

Relationships (1)

Appellant Legal Adversary USAO-SDNY
USAO-SDNY charged Appellant under Count Six

Key Quotes (3)

"the District Court did not just purport to follow Annabi, but expanded its questionable doctrine into new and inapplicable territory."
Source
DOJ-OGR-00021086.jpg
Quote #1
"it would be unreasonable to graft a unique, pro-prosecution canon of construction... onto a plea agreement negotiated with prosecutors elsewhere."
Source
DOJ-OGR-00021086.jpg
Quote #2
"the USAO-SDNY charged Appellant under Count Six with conduct from 2001 through 2004 that falls entirely within the 2001-2007 offense period contemplated by the NPA."
Source
DOJ-OGR-00021086.jpg
Quote #3

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