Eleventh Circuit

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DOJ-OGR-00021091.jpg

This page from a legal filing (dated Feb 28, 2023) argues against allowing the Government to bypass the terms of a Non-Prosecution Agreement (NPA) by moving jurisdictions ('parachuting into a new circuit'). It cites various legal precedents to argue that the court should apply the law of the circuit where the violation or agreement occurred (referencing the 11th Circuit) to protect the defendant's Fifth Amendment rights in the plea-bargaining process.

Legal filing / court brief (page 44 of 113)
2025-11-20

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This legal document argues for limiting the application of the 'Annabi' doctrine. It contends that this doctrine, from the Second Circuit, should not apply to a plea agreement originating in the Eleventh Circuit, where precedent dictates that ambiguities are resolved against the government. The document also asserts that the Annabi doctrine should only be applied when new charges are 'sufficiently distinct' from the original ones.

Legal document
2025-11-20

DOJ-OGR-00021835.jpg

This is page 11 of a legal filing from November 2024 (Case 22-1426) arguing against a Second Circuit Court decision (U.S. v. Maxwell). The text contends that the court unfairly applied the 'Annabi' precedent to allow the SDNY to prosecute Ghislaine Maxwell despite a Non-Prosecution Agreement (NPA) negotiated in the Eleventh Circuit. The document highlights that witnesses told the OPR the agreement was intended to provide 'transactional immunity' to co-conspirators, yet Maxwell was denied discovery or a hearing on this matter.

Legal filing / court document (appellate brief or petition)
2025-11-20

DOJ-OGR-00021831.jpg

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.

Legal brief / appellate filing
2025-11-20

DOJ-OGR-00021685.jpg

This document is page 38 of a legal filing (Case 22-1426) dated June 29, 2023. It contains legal arguments rejecting Ghislaine Maxwell's claim that a U.S. Attorney's Office in one district is bound by a plea agreement made in another, citing Eleventh Circuit precedent (San Pedro v. United States) and 28 U.S.C. ยง 547 regarding the limitation of a U.S. Attorney's authority to their own district. A footnote discusses and dismisses Maxwell's argument regarding an 'inter-circuit exclusionary rule.'

Legal brief / court filing (appellate)
2025-11-20
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