Back to Results

DOJ-OGR-00000120.tif

Source: IMAGES  •  Size: 41.3 KB  •  OCR Confidence: 95.3%
View Original Image

Extracted Text (OCR)

57a every instance to make clear that it applies only in the district where signed. Maxwell asks this Court to draw the opposite conclusion. The provision of the NPA dealing with co-conspirators does not expressly state that it binds US. Attorneys in other districts. It does not expressly state that it applies in other districts. The relevant language, in its entirety, reads as follows: “the United States also agrees that it will not institute any crimi- nal charges against any potential co-conspirators of Epstein.” Dkt. No. 142-1 at 5. Under Annabi, Salameh, and Gonzalez, a statement that “the United States” agrees not to prosecute implies no restriction on prosecutions in other districts. Two provisions of the NPA refer specifically to prosecution in the Southern District of Florida. The first states that the U.S. Attorney for the Southern District of Florida will defer “prosecution in this District” if Epstein complies with the agreement. Dkt. No. 142-1 at 2. The second states that no prosecution “will be instituted in this District, and the charges against Epstein if any, will be dismissed” after he fulfills the agreement’s conditions. Maxwell contends that the lack of similar language in the co-conspirator provision must mean that it lacks any geographical limitation. If anything, that language reflects that the NPA’s scope was expressly limited to the Southern District of Florida. It is not plausible—let alone “affirmatively apparent”, Annabi, 771 F.2d at 672,— that the parties intended to drastically expand the agreement’s geographic scope in the single sentence on the prosecution of co-conspirators without clearly so saying. Without an affirmative statement in the NPA’s text, Maxwell turns to its negotiation history. Under Second DOJ-OGR-00000120

Document Preview

DOJ-OGR-00000120.tif

Click to view full size

Document Details

Filename DOJ-OGR-00000120.tif
File Size 41.3 KB
OCR Confidence 95.3%
Has Readable Text Yes
Text Length 1,789 characters
Indexed 2026-02-03 15:58:01.724153