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496 KB
Extraction Summary
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People
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Organizations
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Locations
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Events
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Relationships
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Quotes
Document Information
Type:
Legal document
File Size:
496 KB
Summary
This legal document argues that all remaining counts in a case must be dismissed because they fall within the scope of a Non-Prosecution Agreement (NPA) that binds the USAO-SDNY. The author contends the NPA's co-conspirator immunity is not limited to specific timeframes or offenses, citing a provision that allows the U.S. to prosecute Epstein for any federal offense upon a breach of the agreement as evidence of its broad scope. At a minimum, it is argued that Counts Three and Six must be dismissed as they fall within the NPA's scope as construed by the District Court.
People (1)
| Name | Role | Context |
|---|---|---|
| Epstein |
Mentioned as the subject of an agreement that allows the United States to investigate and prosecute him for any and a...
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| USAO-SDNY | Government agency |
The U.S. Attorney's Office for the Southern District of New York, which the document argues is bound by the Non-Prose...
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| SDFL | Judicial district |
The Southern District of Florida, mentioned in the context of a prosecution timeframe that does not limit the scope o...
|
| United States | Government |
Party to the agreement, which is allowed to terminate the agreement and prosecute Epstein upon a breach.
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| District Court | Judicial body |
Mentioned as having construed the scope of the NPA, with the argument that certain counts must be dismissed even unde...
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Timeline (2 events)
Relationships (1)
The document describes a Non-Prosecution Agreement between the United States and Epstein, outlining the conditions under which the U.S. could prosecute him.
Key Quotes (1)
"allows the United States to elect to terminate the agreement and to investigate and prosecute Epstein and any other individual or entity for any and all federal offenses."Source
— The agreement (NPA)
(Quoted from a provision of the Non-Prosecution Agreement to support the argument that the immunity provision is not limited in scope.)
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Quote #1
Full Extracted Text
Complete text extracted from the document (1,072 characters)
Case 22-1426, Document 59, 02/28/2023, 3475902, Page55 of 113
have total immunity from federal prosecution for matters that were the subject of the investigation.
D. All counts fall within the scope of the NPA and must be dismissed.
Given that the NPA binds the USAO-SDNY, all three remaining counts must be dismissed because the plain text of the co-conspirator provision is not limited to any particular offense or any time period. A172.
That the co-conspirator immunity provision is not limited to the 2006-2007 investigation or the 2001-2007 timeframe or to prosecution in the SDFL is reinforced by another provision of the agreement which reads, in pertinent part, that a breach of the agreement, “allows the United States to elect to terminate the agreement and to investigate and prosecute Epstein and any other individual or entity for any and all federal offenses. A172.
In any, event, at minimum, Counts Three and Six must be dismissed because they indisputably fall within the scope of the NPA even as construed by the District Court.
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DOJ-OGR-00021102
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