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Case 22-1426, Document 59, 02/28/2023, 3475902, Page35 of 113 no such promise was made. See 405 U.S. 150, 154 (1972) (“The prosecutor’s office is an entity and as such it is the spokesman for the Government. A promise made by one attorney must be attributed, for these purposes, to the Government’’) (citing Restatement (Second) of Agency § 272). These premises are inconsistent with the notion that a federal prosecutor in one district has no obligation to honor promises made by his or her counterpart in another. It is thus unsurprising that few courts outside of this Circuit have found Annabi persuasive. Indeed, Defendant is not aware of any published authority from another circuit that follows Annabi in holding that an ambiguous promise made in a plea agreement by one USAO is presumed not to bind other USAOs. To the contrary, the weight of authority holds that a representation by the United States Attorney’s Office or its agents will bind USAOs in other districts. See Gebbie, 294 F.3d at 550 (“[W]hen a United States Attorney negotiates and contracts on behalf of ‘the United States’ or ‘the Government’ in a plea agreement . that attorney speaks for and binds all of his or her fellow United States Attorneys with respect to those same crimes and those same defendants. ... United States Attorneys should not be viewed as sovereigns of autonomous fiefdoms.’’); U.S. v. Van Thournout, 100 F.3d 590, 594 (8th Cir. 1996) (“Absent an express limitation, any promises made by an [AUSA] in one district will bind an [AUSA] in another district”); Margalli-Olvera v. I.N.S., 43 F.3d 345, 353 (8th Cir. 1994) 20 DOJ-OGR-00021082