DOJ-OGR-00000990.jpg
569 KB
Extraction Summary
3
People
3
Organizations
2
Locations
2
Events
2
Relationships
1
Quotes
Document Information
Type:
Legal document
File Size:
569 KB
Summary
This legal document, part of a court filing, argues against a defendant's motion for bail by refuting her claim of protection under a Non-Prosecution Agreement (NPA). The prosecution asserts the NPA between Jeffrey Epstein and the U.S. Attorney's Office in the Southern District of Florida is irrelevant because the defendant was not a party to it and it does not bind the current prosecuting office in the Southern District of New York. A footnote adds that new witnesses have recently come forward to the FBI and U.S. Attorney's Office to provide more information against the defendant.
People (3)
| Name | Role | Context |
|---|---|---|
| Jeffrey Epstein |
Mentioned as the individual for whom the defendant allegedly groomed victims for sexual abuse, and as a party to a No...
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| Annabi |
Named in the case citation 'United States v. Annabi, 771 F.2d 670, 672 (2d Cir. 1985)'.
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| Prisco |
Named in the case citation 'United States v. Prisco, 391 F. App’x 920, 921 (2d Cir. 2010)'.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| U.S. Attorney’s Office in the Southern District of Florida | government agency |
Party to the Non-Prosecution Agreement (“NPA”) with Jeffrey Epstein.
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| Federal Bureau of Investigation | government agency |
Mentioned in a footnote as having been in touch with additional individuals willing to provide information regarding ...
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| U.S. Attorney’s Office | government agency |
Mentioned in a footnote as having been in touch with additional individuals. Also referred to as 'this Office' in the...
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Timeline (2 events)
A Non-Prosecution Agreement (“NPA”) was made between Jeffrey Epstein and the U.S. Attorney’s Office in the Southern District of Florida.
Southern District of Florida
within the week prior to 2019-06-28
Additional individuals contacted the FBI and the U.S. Attorney's Office expressing a willingness to provide information regarding the defendant after charges were made public.
Locations (2)
| Location | Context |
|---|---|
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The location of the U.S. Attorney's Office that entered into the Non-Prosecution Agreement with Jeffrey Epstein.
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The location where the prosecution is taking place, which the document argues is not bound by the Florida NPA.
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Relationships (2)
The document alleges that the defendant 'groomed the victims for sexual abuse by Jeffrey Epstein.'
The document describes a Non-Prosecution Agreement (“NPA”) between Jeffrey Epstein and the U.S. Attorney’s Office in the Southern District of Florida.
Key Quotes (1)
"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."Source
— United States v. Annabi, 771 F.2d 670, 672 (2d Cir. 1985) (per curiam)
(Cited as legal precedent to argue that the Non-Prosecution Agreement from the Southern District of Florida does not apply in the Southern District of New York.)
DOJ-OGR-00000990.jpg
Quote #1
Full Extracted Text
Complete text extracted from the document (2,426 characters)
Case 1:20-cr-00330-AJN Document 122-2 Filed 06/28/2019 Page 5 of 20
evidence and witness testimony, will conclusively establish that the defendant groomed the victims for sexual abuse by Jeffrey Epstein.¹
The defendant’s motion alludes to defenses in this case, all of which are legal or procedural in nature, and none of which pass muster, let alone counsel in favor of bail. To begin with, the notion that the defendant is protected from prosecution by the Non-Prosecution Agreement (“NPA”) between Jeffrey Epstein and the U.S. Attorney’s Office in the Southern District of Florida (“SDFL”) is absurd. That agreement affords her no protection in this District, for at least three reasons. First, the defendant was not a party to that agreement nor named in it as a third-party beneficiary, and the defendant offers no basis to think she would have standing to claim any rights under the NPA. Tellingly, the defendant cites no authority for the proposition that an agreement she was not a party to and that does not even identify her by name could possibly be invoked to bar her prosecution. Second, and equally important, the NPA does not bind the Southern District of New York, which was not a party to the agreement. See United States v. Annabi, 771 F.2d 670, 672 (2d Cir. 1985) (per curiam) (“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.”); United States v. Prisco, 391 F. App’x 920, 921 (2d Cir. 2010). This rule applies even when the text of the agreement refers to the signing party as the “Government.” Annabi, 771 F.2d at 672.
Third, and perhaps most important, even assuming the NPA could be read to protect this defendant and bind this Office, which are both legally unsound propositions, the Indictment
¹ Additionally, and beyond the strong evidence set forth in the Indictment, in just the past week, and in response to the charges against the defendant being made public, the Federal Bureau of Investigation (“FBI”) and the U.S. Attorney’s Office have been in touch with additional individuals who have expressed a willingness to provide information regarding the defendant. The Government is in the process of receiving and reviewing this additional evidence, which has the potential to make the Government’s case even stronger.
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DOJ-OGR-00000990
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