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3 The government seeks to minimize the split as of “limited importance” because “the scope of a plea or similar agreement is under the control of the parties to the agreement.” Opp.14. This turns a blind eye to the problem. The very premise of Petitioner’s argument is that the parties to the NPA did seek to control the scope of the relevant clauses by narrowing the scope of immunity for Epstein through the use of narrow language specifying enforceability only in the Southern District of Florida, and then expanding the scope of it as to his co-conspirators by using the broad term “the United States.” (App. 30-31). While doing so, Epstein’s lawyers were no doubt informed by how that language was interpreted in the jurisdiction in which they were practicing. Yet by definition, the issue presented in this case and every other like it only arises when the language in question is being interpreted in a different jurisdiction than the one where the agreement was negotiated. Accordingly, uniformity in interpretation of such a provision is unusually and particularly compelling. The very nature of a clause of this nature (unlike most other clauses in an agreement, which are not cross-jurisdictional in nature) cries out for nationwide symmetry. The government also contends, rather bizarrely, that “this is not itself a case that turns on any default rule.” Opp.14. To the contrary, it is precisely the Second Circuit’s default rule, adopted in United States v. Annabi, 771 F.2d 670 (2d Cir. 1985), that doomed Petitioner to stand trial on a case that would have been dismissed outright in at least half the country. The primary reason this Court should grant certiorari is to create one single default rule across the country as to DOJ-OGR-00000247