DOJ-OGR-00021075.jpg
568 KB
Extraction Summary
4
People
5
Organizations
1
Locations
2
Events
2
Relationships
3
Quotes
Document Information
Type:
Legal brief / appellate filing
File Size:
568 KB
Summary
This document is page 28 of a legal appellate brief filed on February 28, 2023, arguing that all counts against Ghislaine Maxwell should be dismissed based on the 2007 Non-Prosecution Agreement (NPA) between the Government and Jeffrey Epstein. It claims the NPA immunized Maxwell as a 'potential co-conspirator' and cites Supreme Court precedent requiring prosecutors to fulfill plea agreement promises. Additionally, the text argues jury prejudice occurred due to media interviews given by accusers named Carolyn and Kate.
People (4)
| Name | Role | Context |
|---|---|---|
| Maxwell | Defendant/Appellant |
Subject of the legal argument regarding jury prejudice and immunity via NPA.
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| Carolyn | Witness/Accuser |
Granted an interview to the Daily Mail immediately after the verdict.
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| Kate | Witness/Accuser |
Made public statements before the trial concluded.
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| Epstein | Co-conspirator (deceased) |
Entered into the Non-Prosecution Agreement (NPA) with the government in 2007.
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| Daily Mail |
Media outlet that interviewed Carolyn.
|
|
| Supreme Court |
Cited for legal precedent (Santobello v. New York).
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| The Government |
The prosecution entity that negotiated the NPA.
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| United States Attorney’s Office |
Mentioned in the factual recitals of the NPA.
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| Federal Bureau of [Investigation] |
Mentioned in the factual recitals (text cuts off).
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Locations (1)
| Location | Context |
|---|---|
|
Referenced in the case citation Santobello v. New York.
|
Relationships (2)
The NPA entered by Epstein immunized Maxwell as a 'potential co-conspirator.'
Carolyn... granted an interview with the Daily Mail.
Key Quotes (3)
"The NPA immunized Maxwell as a “potential co-conspirator.”"Source
DOJ-OGR-00021075.jpg
Quote #1
"ALL COUNTS SHOULD BE DISMISSED PURSUANT TO THE NON-PROSECUTION AGREEMENT"Source
DOJ-OGR-00021075.jpg
Quote #2
"when a plea rests in any significant degree on a promise or agreement of the prosecutor... such promise must be fulfilled."Source
DOJ-OGR-00021075.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,241 characters)
Case 22-1426, Document 59, 02/28/2023, 3475902, Page28 of 113
That this was a manipulation designed to prejudice the jury against Maxwell was eloquently proven by Carolyn who wasted no time in granting an interview with the Daily Mail after the verdict was reached. And Kate did not even wait until after the verdict as she made public statements before trial.
POINT I
ALL COUNTS SHOULD BE DISMISSED PURSUANT TO THE NON-PROSECUTION AGREEMENT
The Government negotiated an agreement with a criminal defendant and that defendant fulfilled all the conditions to the enforcement of the agreement, including a state guilty plea. As the Supreme Court held, “when a plea rests in any significant degree on a promise or agreement of the prosecutor, so that it can be said to be part of the inducement or consideration, such promise must be fulfilled. Santobello v. New York, 92 S. Ct. 495, 499 (1971).
On September 24, 2007, the Government and Epstein entered into a nonprosecution agreement. The NPA immunized Maxwell as a “potential co-conspirator.”
A. The NPA
The NPA begins with several factual recitals. The recitals state, among other things, that (i) the “United States Attorney’s Office” and the Federal Bureau of
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DOJ-OGR-00021075
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