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614 KB

Extraction Summary

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

Document Information

Type: Legal brief / court filing (page 8 of 51)
File Size: 614 KB
Summary

This document is page 8 of a legal brief filed on November 1, 2024, discussing the legal interpretation of Jeffrey Epstein's September 2007 Non-Prosecution Agreement (NPA). It outlines the background of the NPA, noting that in exchange for a guilty plea to state charges and an 18-month sentence, the USAO-SDFL agreed not to prosecute Epstein or his potential co-conspirators (referencing four specific but unnamed individuals) for federal offenses committed between 2001 and 2007. The central legal issue presented is whether the Second Circuit's precedent in *Annabi*, which favors the government in ambiguous plea agreements, should be overruled.

People (3)

Name Role Context
Jeffrey Epstein Subject of investigation/Defendant
Entered into a non-prosecution agreement in September 2007.
Annabi Legal Precedent Subject
Referenced in 'United States v. Annabi' regarding Second Circuit canons of construction.
[four named individuals] Potential Co-conspirators
Unnamed in this specific page, but referenced as receiving immunity in the NPA along with Epstein.

Organizations (3)

Name Type Context
Second Circuit
Court whose canon of construction is being challenged.
United States Attorney’s Office for the Southern District of Florida
Prosecutorial body that entered into the NPA with Epstein (USAO-SDFL).
DOJ-OGR
Department of Justice - Office of Government Relations (indicated by Bates stamp).

Timeline (2 events)

2001-2007
Period of offenses under investigation covered by the non-prosecution agreement.
Southern District of Florida
2007-09
Jeffrey Epstein entered into a non-prosecution and plea agreement (NPA).
Southern District of Florida
Jeffrey Epstein USAO-SDFL

Locations (1)

Location Context
Jurisdiction where the NPA was signed and where prosecution was agreed to be withheld.

Relationships (2)

Jeffrey Epstein Legal Adversaries/Contractual Parties USAO-SDFL
Entered into NPA in September 2007.
Jeffrey Epstein Co-conspirators Potential Co-conspirators
NPA clause specifically prohibited criminal charges against 'potential co-conspirators of Epstein'.

Key Quotes (2)

"the United States also agree[d] that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to [four named individuals]."
Source
DOJ-OGR-00021832.jpg
Quote #1
"In return for pleading guilty to state charges... the government agreed, inter alia, not to prosecute Epstein in the SDFL for the offenses from 2001-2007 then under investigation."
Source
DOJ-OGR-00021832.jpg
Quote #2

Full Extracted Text

Complete text extracted from the document (1,440 characters)

Case 22-1426, Document 117, 11/01/2024, 3636586, Page8 of 51
ISSUE PRESENTED
Whether the canon of construction adopted by the Second Circuit in Annabi,
whereby perceived ambiguities in the scope of immunity in a plea agreement are
resolved in favor of the government, should be overruled or limited.
BACKGROUND
In September 2007, following state and federal investigations of alleged
unlawful sexual activity, Jeffrey Epstein entered into a non-prosecution and plea
agreement (“NPA”) with the United States Attorney’s Office for the Southern
District of Florida (“USAO-SDFL”). A173-179.² In return for pleading guilty to
state charges, receiving an eighteen-month sentence and consenting to jurisdiction
and liability for civil suits under 18 U.S.C. Section 2255, irrespective of where
those claims arose, the government agreed, inter alia, not to prosecute Epstein in
the SDFL for the offenses from 2001-2007 then under investigation. In addition,
“the United States also agree[d] that it will not institute any criminal charges
against any potential co-conspirators of Epstein, including but not limited to [four
named individuals].” A178. The co-conspirator clause was negotiated at the same
time that the terms of Epstein’s liability for civil claims without geographic
² Numerical references preceded by “A” and “SA” are to the appendices filed with Appellant’s
Brief and the Government’s Brief, respectively.
3
DOJ-OGR-00021832

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