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Case 22-1426, Document 117, 11/01/2024, 3636586, Page15 of 51 affirmative appearance of doing so. Papa does not explain or attempt to rationalize the rule that has evolved. 294 F.3d at 547-48 (brackets and italics in original; bold added). Annabi stands in tension with what the United States Supreme Court has written about plea and immunity agreements. In Santobello, 404 U.S. 257 (1971)— the seminal case on plea bargaining—the Supreme Court held that one prosecutor’s promise in a plea agreement would bind other prosecutors, even those who might have been unaware of the promise. As Santobello explained, “[t]he staff lawyers in a prosecutor’s office have the burden of ‘letting the left hand know what the right hand is doing’ or has done.” 404 U.S. at 262. And in Giglio v. United States, the Supreme Court held that an AUSA had a duty under Brady to disclose a promise of immunity that another AUSA had made to a testifying witness, even though the first AUSA had been falsely assured that 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. Appellant 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 10 DOJ-OGR-00021839