DOJ-OGR-00021831.jpg
535 KB
Extraction Summary
3
People
4
Organizations
2
Locations
1
Events
1
Relationships
3
Quotes
Document Information
Type:
Legal brief / appellate filing
File Size:
535 KB
Summary
This document is page 2 of a legal brief filed on November 1, 2024 (Case 22-1426). It argues that the legal precedent set in 'Annabi' should be overruled or limited because it creates unfairness in plea negotiations. The text specifically argues that a plea agreement negotiated in the Eleventh Circuit (likely referencing the Jeffrey Epstein 2008 Florida non-prosecution agreement) should bind the 'United States' globally, preventing prosecution in other districts for the same conduct.
People (3)
| Name | Role | Context |
|---|---|---|
| Annabi | Legal Precedent Subject |
Refers to United States v. Annabi, a case precedent regarding plea agreements.
|
| Santobello | Legal Precedent Subject |
Refers to Santobello v. New York (1971).
|
| Defendant | Litigant |
Generic reference to the accused party in the current case, arguing about the scope of a plea agreement.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| The Court |
The appellate court being addressed in the brief.
|
|
| United States |
Referenced as the party that agreed not to prosecute in the plea agreement.
|
|
| Eleventh Circuit |
The jurisdiction where the plea agreement in question was negotiated and executed.
|
|
| DOJ-OGR |
Department of Justice - Office of Government Information Services (indicated by Bates stamp).
|
Timeline (1 events)
Locations (2)
| Location | Context |
|---|---|
|
Region covering Florida, Georgia, and Alabama; location of the plea negotiation.
|
|
|
Mentioned in case citation Santobello v. New York.
|
Relationships (1)
Dispute over the binding nature of a plea agreement/non-prosecution agreement.
Key Quotes (3)
"The Court should overrule Annabi because it is an outlier and incompatible with 'fairness in securing agreement between an accused and a prosecutor.'"Source
DOJ-OGR-00021831.jpg
Quote #1
"Annabi should not apply (1) to plea agreements from other circuits that do not have such a rule"Source
DOJ-OGR-00021831.jpg
Quote #2
"Here, Annabi was applied to a plea that was negotiated and executed in the Eleventh Circuit... to an offense based on the same conduct that the 'United States' had agreed not to prosecute"Source
DOJ-OGR-00021831.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,184 characters)
Case 22-1426, Document 117, 11/01/2024, 3636586, Page7 of 51
provisions against the government, which drafted the agreement and enjoys
unequal bargaining power in the sentencing process.”).
unequal bargaining power in the sentencing process.”).
The Court should overrule Annabi because it is an outlier and incompatible
with “fairness in securing agreement between an accused and a prosecutor.” See
Santobello v. New York, 404 U.S. 257, 261 (1971). Alternatively, the Court should
limit Annabi as follows: Annabi should not apply (1) to plea agreements from other
circuits that do not have such a rule; (2) to offenses based on the same conduct that
was the subject of a non-prosecution or plea agreement; (3) where there are
“affirmative indications” that the defendant reasonably understood the agreement
to bind other districts; and (4) without discovery and an evidentiary hearing. Here,
Annabi was applied to a plea that was negotiated and executed in the Eleventh
Circuit (a circuit that does not follow Annabi); to an offense based on the same
conduct that the “United States” had agreed not to prosecute; despite affirmative
appearances of intent to bind other districts; and without discovery and a hearing.
with “fairness in securing agreement between an accused and a prosecutor.” See
Santobello v. New York, 404 U.S. 257, 261 (1971). Alternatively, the Court should
limit Annabi as follows: Annabi should not apply (1) to plea agreements from other
circuits that do not have such a rule; (2) to offenses based on the same conduct that
was the subject of a non-prosecution or plea agreement; (3) where there are
“affirmative indications” that the defendant reasonably understood the agreement
to bind other districts; and (4) without discovery and an evidentiary hearing. Here,
Annabi was applied to a plea that was negotiated and executed in the Eleventh
Circuit (a circuit that does not follow Annabi); to an offense based on the same
conduct that the “United States” had agreed not to prosecute; despite affirmative
appearances of intent to bind other districts; and without discovery and a hearing.
2
DOJ-OGR-00021831
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document