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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:
773 KB
Summary
This legal document is an argument by the prosecution against a defendant's motion to dismiss an indictment. The prosecution contends that a 2007 non-prosecution agreement (NPA) between Jeffrey Epstein and the U.S. Attorney's Office for the Southern District of Florida is irrelevant to the current case. The key reasons are that the defendant was not a party to the NPA, the agreement is not binding on the U.S. Attorney's Office for the Southern District of New York (where the case is being tried), and the NPA does not provide immunity for the specific crimes with which the defendant is charged.
People (1)
| Name | Role | Context |
|---|---|---|
| Jeffrey Epstein |
Party to a 2007 non-prosecution agreement (NPA) with the U.S. Attorney's Office for the Southern District of Florida....
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Organizations (4)
| Name | Type | Context |
|---|---|---|
| U.S. Attorney’s Office for the Southern District of Florida | government agency |
Referred to as "USAO-SDFL," it is the entity that entered into a 2007 non-prosecution agreement with Jeffrey Epstein.
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| U.S. Attorney’s Office for the Southern District of New York | government agency |
Referred to as "USAO-SDNY," it is the prosecuting office in the current case against the defendant and is argued to n...
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| The Government | government agency |
Refers to the prosecution in the case. The footnote mentions the Government's ongoing investigation into Jeffrey Epst...
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| The Court | government agency |
The judicial body that the document argues should reject the defendant's arguments.
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Timeline (3 events)
2007
A non-prosecution agreement ("NPA") was made between Jeffrey Epstein and the U.S. Attorney’s Office for the Southern District of Florida.
Southern District of Florida
2020-08-21
The Government indicated that the investigation into Jeffrey Epstein’s co-conspirators remains ongoing.
The defendant seeks to dismiss the Indictment against her based on Jeffrey Epstein's 2007 NPA.
Southern District of New York
The defendant
Locations (3)
| Location | Context |
|---|---|
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The jurisdiction of the U.S. Attorney's Office that made the non-prosecution agreement with Jeffrey Epstein.
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The defendant claims immunity from prosecution for any federal crime 'anywhere, in the United States'.
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The jurisdiction where the current case is being prosecuted and where the NPA is argued to be unenforceable.
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Relationships (2)
They entered into a 2007 non-prosecution agreement (NPA).
The defendant is attempting to use Jeffrey Epstein's NPA for her own defense. A footnote mentions an ongoing investigation into Epstein's 'co-conspirators' and the possibility of 'additional charges against the defendant' stemming from it.
Full Extracted Text
Complete text extracted from the document (2,299 characters)
Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 30 of 239
illegal sex acts, and aiding and abetting the same, in violation of 18 U.S.C. §§ 2423 and 2. Counts Five and Six charge the defendant with perjury, in violation of 18 U.S.C. § 1623.¹
ARGUMENT
I. Jeffrey Epstein’s Non-Prosecution Agreement Is Irrelevant to This Case
The defendant seeks to dismiss the Indictment based on a 2007 non-prosecution agreement (“NPA”) between Jeffrey Epstein and the U.S. Attorney’s Office for the Southern District of Florida (the “USAO-SDFL”). (Def. Mot. 1). She does so despite the fact that: (1) she did not negotiate the NPA, was not a party to the NPA, and her name is not contained anywhere in the document; and (2) her crimes are not identified or named in any way in the NPA. Essentially, the defendant claims she is immune from prosecution for any federal crime, during any time period, anywhere, in the United States, based on the language of a document that does not name her and which she did not sign. Moreover, she seeks to enforce the NPA against a U.S. Attorney’s Office that did not negotiate the NPA and is not bound by it.
The defendant’s arguments are meritless, and the Court should reject them. As a threshold matter, under the well-settled law of this Circuit, the NPA is not enforceable in this District, because the USAO-SDFL’s agreement with Jeffrey Epstein is not binding on the U.S. Attorney’s Office for the Southern District of New York (the “USAO-SDNY”). Moreover, even if the NPA applied to this District—which it does not—the NPA does not immunize the defendant from prosecution for the crimes charged in the Indictment. Finally, because the defendant has failed to
¹ As the Government has repeatedly indicated, the investigation into Jeffrey Epstein’s co-conspirators remains ongoing. (See, e.g., Gov’t Letter dated Aug. 21, 2020, Dkt. No. 46; Gov’t Letter dated Oct. 6, 2020, Dkt. No. 60; Gov’t Letter dated Oct. 20, 2020, Dkt. No. 65). To the extent that investigation results in additional charges against the defendant, the Government intends to seek any superseding indictment at least three months in advance of trial. The Government does not anticipate that any new charges would require the production of any additional discovery.
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