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Case 22-1426, Document 59, 02/28/2023, 3475902, PageS0 of 113 its face immunizes assistants who worked for Epstein out of his New York office. For example, Leslie Groff worked for Epstein out of the New York Office. Tr. 201; See Doe v. Indyke et al., Case No. 1:21-cv-08469-PKC, Dkt No. 1 (S.D. Fla.). Moreover, a promise to bind other districts need not be express; rather, it can be inferred from the negotiations between defendant and prosecutor, see United States v. Alessi, 544 F.2d 1139, 1153-54 (2d Cir.), cert. denied, 429 U.S. 960, 97 S.Ct. 384 (1976). United States v. Russo, 801 F.2d 624, 626 (2d Cir. 1986) (“A promise to bind other districts can be inferred from the negotiations between defendant and prosecutor.”) One relevant factor in this analysis is the extent to which the USAO negotiating the plea agreement acted on its own, as opposed to involving other USAOs or other offices within the Department of Justice. Cf., e.g., United States v. D’Amico, 734 F. Supp. 2d 321, 349 (S.D.N.Y. 2010) (finding that defendant “offers no meaningful support for his claim that he ‘reasonably understood’ the Agreement to bar subsequent prosecutions in this District... . He does not claim, for example, that the SDNY USAO was in any way consulted or involved in the plea negotiations.”); United States v. Laskow, 688 F. Supp. 851, 854 (E.D.N.Y.) (“defendants concede [] that the Central District had no knowledge of the investigation that was taking place in the Eastern District at the time the Central District plea was being negotiated. . . . The Central District, unaware of defendants' potential criminal liability in the Eastern District, could not have 35 DOJ-OGR-00021097

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Filename DOJ-OGR-00021097.jpg
File Size 698.3 KB
OCR Confidence 93.8%
Has Readable Text Yes
Text Length 1,691 characters
Indexed 2026-02-03 20:07:11.504656