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.
| 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.
|
| 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).
|
| Location | Context |
|---|---|
|
Jurisdiction where the NPA was signed and where prosecution was agreed to be withheld.
|
"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
"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
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