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754 KB
Extraction Summary
7
People
5
Organizations
1
Locations
0
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal filing / court opinion page
File Size:
754 KB
Summary
This is page 57 of a legal filing (Document 310-1) from the Ghislaine Maxwell case (1:20-cr-00330-PAE), filed on July 2, 2021. The text presents legal arguments citing various precedents (including Martinez, Carrillo, and Baird) to establish that non-prosecution agreements should be treated as binding contracts similar to plea agreements. This argument is likely being used to support the defense's claim regarding the applicability of the 2007 Epstein non-prosecution agreement.
People (7)
| Name | Role | Context |
|---|---|---|
| Martinez | Case Citation Subject |
Cited in legal precedent regarding plea bargains (Martinez, 147 A.3d at 531-32).
|
| Santobello | Case Citation Subject |
Cited as legal precedent.
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| Zuber | Case Citation Subject |
Cited as legal precedent.
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| Hainesworth | Case Citation Subject |
Cited in Commonwealth v. Hainesworth regarding plea bargains.
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| Carrillo | Case Citation Subject |
Cited in United States v. Carrillo regarding non-prosecution agreements.
|
| Baird | Case Citation Subject |
Cited in United States v. Baird regarding non-prosecution agreements.
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| Ginn | Case Citation Subject |
Cited in Commonwealth v. Ginn regarding non-prosecution agreements.
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| Pennsylvania State Police |
Mentioned in relation to SORNA obligations.
|
|
| United States Court of Appeals for the Third Circuit |
Cited for legal opinion on non-prosecution agreements.
|
|
| Pennsylvania Superior Court |
Cited as Pa. Super regarding Commonwealth v. Hainesworth and Commonwealth v. Ginn.
|
|
| 9th Circuit Court of Appeals |
Cited in reference to United States v. Carrillo.
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| DOJ-OGR |
Department of Justice Office of Government Relations (implied by Bates stamp).
|
Locations (1)
| Location | Context |
|---|---|
|
Implied jurisdiction of cited state cases (Commonwealth v. Hainesworth, etc.).
|
Relationships (1)
Non-Prosecution Agreements
→
Legal Equivalence
→
Plea Agreements
Text states 'non-prosecution agreements are akin to plea agreements, necessitating the application of contract law principles'.
Key Quotes (3)
"fundamental fairness requires a prosecutor to uphold his or her end of a non-prosecution agreement"Source
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Quote #1
"non-prosecution agreements are binding contracts that must be interpreted according to general principles of contract law, guided by 'special due process concerns.'"Source
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Quote #2
"a defendant 'is entitled to the benefit of his bargain through specific performance of terms of the plea agreement.'"Source
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Quote #3
Full Extracted Text
Complete text extracted from the document (2,147 characters)
Case 1:20-cr-00330-PAE Document 310-1 Filed 07/02/21 Page 57 of 80
Pennsylvania State Police that he or she was subject to the intervening statute and thus
had to comply with the new obligations under SORNA, even though those obligations
contradicted the terms of each of their plea deals. Id. at 522-523.
had to comply with the new obligations under SORNA, even though those obligations
contradicted the terms of each of their plea deals. Id. at 522-523.
Each of the three offenders filed an action seeking the enforcement of the terms
of his guilty plea, notwithstanding the fact that those terms conflicted with the newly-
enacted statute. Id. at 523-24. Citing Santobello, Zuber, Commonwealth v. Hainesworth,
82 A.3d 444 (Pa. Super. 2013) (en banc), and other decisions, this Court held that the
offenders were entitled to specific performance of the terms of the plea bargains to which
the prosecutors had agreed. Martinez, 147 A.3d at 531-32. We held that, once a
bargained term is enveloped within a plea agreement, a defendant “is entitled to the
benefit of his bargain through specific performance of terms of the plea agreement.” Id.
at 533.
of his guilty plea, notwithstanding the fact that those terms conflicted with the newly-
enacted statute. Id. at 523-24. Citing Santobello, Zuber, Commonwealth v. Hainesworth,
82 A.3d 444 (Pa. Super. 2013) (en banc), and other decisions, this Court held that the
offenders were entitled to specific performance of the terms of the plea bargains to which
the prosecutors had agreed. Martinez, 147 A.3d at 531-32. We held that, once a
bargained term is enveloped within a plea agreement, a defendant “is entitled to the
benefit of his bargain through specific performance of terms of the plea agreement.” Id.
at 533.
The applicability of contract law principles to criminal negotiations is not limited to
the plea bargaining process. See United States v. Carrillo, 709 F.2d 35 (9th Cir. 1983)
(holding that fundamental fairness requires a prosecutor to uphold his or her end of a
non-prosecution agreement). For instance, the United States Court of Appeals for the
Third Circuit has explained that, like plea agreements, non-prosecution agreements are
binding contracts that must be interpreted according to general principles of contract law,
guided by “special due process concerns.” United States v. Baird, 218 F.3d 221, 229 (3d
Cir. 2000) (citation omitted). And, in Commonwealth v. Ginn, 587 A.2d 314 (Pa. Super.
1991), our Superior Court similarly held that non-prosecution agreements are akin to plea
agreements, necessitating the application of contract law principles to prevent
prosecutors from violating the Commonwealth’s promises or assurances. Id. at 316-17.
the plea bargaining process. See United States v. Carrillo, 709 F.2d 35 (9th Cir. 1983)
(holding that fundamental fairness requires a prosecutor to uphold his or her end of a
non-prosecution agreement). For instance, the United States Court of Appeals for the
Third Circuit has explained that, like plea agreements, non-prosecution agreements are
binding contracts that must be interpreted according to general principles of contract law,
guided by “special due process concerns.” United States v. Baird, 218 F.3d 221, 229 (3d
Cir. 2000) (citation omitted). And, in Commonwealth v. Ginn, 587 A.2d 314 (Pa. Super.
1991), our Superior Court similarly held that non-prosecution agreements are akin to plea
agreements, necessitating the application of contract law principles to prevent
prosecutors from violating the Commonwealth’s promises or assurances. Id. at 316-17.
Under some circumstances, assurances given by prosecutors during plea
negotiations, even unconsummated ones, may be enforceable on equitable grounds
negotiations, even unconsummated ones, may be enforceable on equitable grounds
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