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REASONS FOR GRANTING THE PETITION This case presents a straightforward and important question about the government’s obligation to honor its promises in plea and non-prosecution agreements. The petition asks whether a U.S. Attorney’s promise made on behalf of “the United States” binds the entire United States. The government’s Brief in Opposition only underscores the importance of this question. Most significantly, the government concedes a circuit split on this issue, effectively admitting that defendants’ rights hinge on the happenstance of geography. Opp.13. Such an acknowledged conflict among the circuits demands this Court’s intervention. Rather than grapple with the core principles of plea agreements, the government tries to distract by reciting a lurid and irrelevant account of Jeffrey Epstein’s misconduct. But this case is about what the government promised, not what Epstein did. Even more remarkably, the government advances an interpretation of its non-prosecution agreement that flips its plain meaning on its head. Promising “not to prosecute” somehow meant preserving the right to prosecute. That is not contract interpretation; it is alchemy. Plea agreements are supposed to be strictly construed against the government, yet here the government isn’t even asking for the benefit of the doubt; it is asking for a blank check to rewrite its own promise after the fact. The government’s only real argument is that the Second Circuit rule is correct on the merits while the other circuits have it wrong. We obviously disagree, but regardless, the Court should grant certiorari so that all circuits employ that same rule. DOJ-OGR-00000245