USAOs
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This document is a table of contents for an argument or legal brief, outlining sections like 'Table of Cited Authorities,' 'Interest of Amici,' 'Introduction and Summary of Argument,' and a detailed 'Argument' section. The argument points discuss the reliability of government promises, the Department of Justice's ability to draft plea agreements, and the practice of USAOs regarding plea agreement scope in contrast to a Non-Prosecution Agreement (NPA).
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This document is a legal conclusion affirming the District Court's judgment of conviction for Ms. Maxwell on June 29, 2022. It details five key holdings, including that Epstein's Non-Prosecution Agreement with USAO-SDFL did not prevent Maxwell's prosecution by USAOSDNY, and that the District Court's sentence for Maxwell was procedurally reasonable. The document emphasizes the gravity of Maxwell's offense and the significant harm she inflicted.
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This document is a page from a legal brief filed on February 28, 2023. It argues that the Non-Prosecution Agreement (NPA) was intended to have a broad scope, providing global immunity to Epstein and his co-conspirators beyond a specific district. It cites a 2007 email from prosecutor Villafana to defense attorney Lefkowitz, explicitly stating a preference not to highlight other crimes and other chargeable persons to the judge.
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This page from a legal brief (Case 22-1426) argues points regarding the scope of plea agreements and Double Jeopardy. It analyzes the 'Abbamonte-Alessi rule' and the 'Annabi' precedent to determine if a plea agreement binding 'the Government' applies to other United States Attorney Offices (USAOs). The text argues that for charges to be distinct enough to bypass the rule, they must cover a new time period, noting that in the Annabi case, the conspiracy period was two years longer.
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This page is from a legal filing (Case 22-1426, dated Feb 28, 2023) arguing that the Non-Prosecution Agreement (NPA) signed by Jeffrey Epstein should be interpreted under Eleventh Circuit law rather than Second Circuit law. The text asserts that under Eleventh Circuit precedent, the NPA's promise by 'the United States' not to prosecute Epstein's potential co-conspirators (specifically including the Defendant) is binding on all U.S. Attorneys' Offices and any ambiguity must be resolved against the government.
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This legal document is a page from a defendant's brief arguing that the court made an error. The defendant contends the court improperly applied the 'Annabi' rule from the Second Circuit to a Non-Prosecution Agreement (NPA) that was negotiated in Florida, which falls under the Eleventh Circuit. The argument is that since the NPA was negotiated with Florida prosecutors in exchange for Epstein's guilty plea in a Florida state court, Eleventh Circuit law should apply instead.
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This legal document argues that the Appellant, identified as Maxwell, is a third-party beneficiary of a Non-Prosecution Agreement (NPA) related to Epstein and therefore has standing to enforce it. The brief contends that a District Court erred in its ruling that the NPA's immunity for co-conspirators only applied to the U.S. Attorney's Office in the Southern District of Florida (USAO-SDFL), arguing the agreement's plain text referring to "the United States" should bind all U.S. Attorney's Offices, including the one in the Southern District of New York (USAO-SDNY).
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This document is page 15 (labeled 20 of 51 in the header) of a legal appellate brief filed on November 1, 2024. It argues that the Non-Prosecution Agreement (NPA) covering the 2001-2007 period should have prevented the USAO-SDNY from charging the Appellant (contextually Ghislaine Maxwell) for conduct between 2001-2004. The text cites legal precedents (*Annabi*, *Alessi*, *Papa*) regarding whether plea agreements bind other US Attorney Offices and argues the Appellant was improperly denied an evidentiary hearing.
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This legal document, dated November 1, 2024, presents an argument for an en banc review to potentially overrule or limit the 'Annabi' canon of construction for plea agreements. The text discusses the jurisdictional authority of U.S. Attorneys' offices, citing the U.S. Attorneys' Manual and the Judiciary Act of 1789 to argue about the scope of immunity and the government's obligation to be explicit about its limitations. The argument is framed in the context of a past case involving interviews with Epstein's lawyers.
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This legal document outlines the recollections of an individual identified as 'AK' regarding discussions about the Epstein case. AK recalls a meeting with attorneys where she sought to clarify their proposal to have the SDNY re-investigate conduct previously handled in Florida, and she disputes an account of the meeting from Brad Edwards's book. The document also notes AK's vague memory of being told about depositions and the possibility of perjury charges against Maxwell, though no investigation was opened, and her decision to take no further action on the Epstein matter after calling Sean Watson.
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