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801 KB

Extraction Summary

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

Document Information

Type: Legal document
File Size: 801 KB
Summary

This legal document, filed on July 13, 2020, is a portion of the prosecution's argument against a defendant's motion. The prosecution contends that a Non-Prosecution Agreement (NPA) between Jeffrey Epstein and the U.S. Attorney's Office in the Southern District of Florida does not protect the defendant from prosecution in the Southern District of New York, as she was not a party to the agreement and it does not bind other districts. A footnote reveals that since the charges were made public, the FBI has been contacted by new individuals willing to provide more evidence 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...
Annabi
Named in the case citation 'United States v. Annabi, 771 F.2d 670'.
Prisco
Named in the case citation 'United States v. Prisco, 391 F. App’x 920'.

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.
Federal Bureau of Investigation government agency
Mentioned in a footnote as having been in touch with additional individuals willing to provide information about the ...
U.S. Attorney’s Office government agency
Mentioned generally in the context of plea agreements and in a footnote as being in touch with individuals regarding ...

Timeline (2 events)

2020-07-13
Filing of a document arguing against the defendant's motion for bail, specifically refuting the claim that a prior NPA protects her from the current prosecution.
Southern District of New York
The Government (prosecution) The defendant
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

Locations (2)

Location Context
The location of the U.S. Attorney's Office that entered into the Non-Prosecution Agreement with Jeffrey Epstein.
The location of the current prosecution, which the document argues is not bound by the Florida NPA.

Relationships (1)

defendant criminal association Jeffrey Epstein
The document alleges that evidence and testimony will establish that "the defendant groomed the victims for sexual abuse by Jeffrey Epstein."

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 bind the prosecution in the Southern District of New York.)
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Quote #1

Full Extracted Text

Complete text extracted from the document (2,421 characters)

Case 1:20-cr-00330-AJN Document 22 Filed 07/13/20 Page 6 of 19
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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