DOJ-OGR-00002967.jpg
878 KB
Extraction Summary
3
People
6
Organizations
2
Locations
2
Events
1
Relationships
2
Quotes
Document Information
Type:
Legal document
File Size:
878 KB
Summary
This legal document, part of a court filing from April 16, 2021, presents an argument about the jurisdictional scope of plea agreements. The author refutes a defendant's motion by citing case law, primarily *Annabi*, to argue that a plea agreement only binds the specific U.S. Attorney's Office that made it, unless it explicitly states a broader scope. The document contrasts this with the defendant's argument that without an explicit limitation, an agreement should bind the entire federal government.
People (3)
| Name | Role | Context |
|---|---|---|
| Annabi |
Cited in the case law 'Annabi, 771 F.2d at 672' which establishes a rule regarding the scope of plea agreements.
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| Laskow |
Cited in the case law 'See Laskow, 688 F. Supp. at 854' regarding the presumption of a plea agreement's scope.
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| Feldman |
Cited in the case law 'United States v. Feldman, 939 F.3d 182, 189 (2d Cir. 2019)' as an example of a defendant seeki...
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Organizations (6)
| Name | Type | Context |
|---|---|---|
| United States Attorney | government agency |
Mentioned as the office that is bound by a plea agreement within a specific district.
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| U.S. Attorney’s Office | government agency |
The specific office that executes a plea agreement and is bound by its terms.
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| the Government | government agency |
Referenced in plea agreements; the document discusses whether this term binds the entire federal government.
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| the United States | government agency |
Used interchangeably with 'the Government' in reference to a party in a plea agreement.
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| Second Circuit | government agency |
A judicial circuit whose legal holdings are cited, specifically regarding the construction of plea agreements.
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| DOJ-OGR | government agency |
Appears as a document identifier in the footer (DOJ-OGR-00002967), likely referring to a Department of Justice office...
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Relationships (1)
The document discusses a plea agreement between the defendant and the Government, and analyzes the defendant's motion against the Government's position based on legal precedent.
Key Quotes (2)
"expressly limits the scope of the agreement to the district"Source
— document author (describing a hypothetical provision)
(Used to describe a type of provision that might be absent from a plea agreement, which affects its scope.)
DOJ-OGR-00002967.jpg
Quote #1
"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"Source
— document author
(A summary of the defendant's legal argument regarding the scope of plea agreements.)
DOJ-OGR-00002967.jpg
Quote #2
Full Extracted Text
Complete text extracted from the document (2,702 characters)
Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 33 of 239
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.
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
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
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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DOJ-OGR-00002967
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