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Case 22-1426, Document 59, 02/28/2023, 3475902, Page36 of 113 (“promises made by an [AUSA]” in a plea agreement “bind all agents of the United States government”); Thomas v. I.N.S., 35 F.3d 1332 (9th Cir. 1994) (enforcing against the INS a cooperation agreement between defendant and an AUSA promising that “the government” would not oppose defendant’s application for relief from deportation); U.S. v. Levasseur, 846 F.2d 786, 799 (1st Cir. 1988) (expressly declining to apply Annabi in the estoppel context, instead holding that “the representation of any [AUSA] may, in appropriate circumstances, be invoked to estop the United States...”); U.S. v. Harvey, 791 F.2d 294, 303 (4th Cir. 1986) (“Whenever a United States Attorney negotiates and enters a plea agreement, it is the Government that ‘agrees’ to whatever is agreed to.”); U.S. v. Carter, 454 F.2d 426 (4th Cir. 1972) (en banc) (vacating conviction where a plea “bargain was allegedly breached in a neighboring district,” adding that “[t]he United States government is the United States government throughout all of the states and districts”); Young v. U.S., 953 F.Supp.2d 1049, 1069 n.4 (D.S.D. 2013) (plea agreement between defendant and “the United States” in West Virginia would bind federal prosecutors in South Dakota); Little v. U.S., Nos. 1:08-cr-59, 1:09-cv-822, 2010 WL 3942749, at *3 (S.D. Ohio Oct. 7, 2010) (plea agreement between defendant “‘and the United States of America,” which was “silent as to the effect it may have with respect to other United States Attorneys,” would be interpreted to “bind[] the United States Attorneys in all other districts’). 21 DOJ-OGR-00021083