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9 circuit split regarding an important issue of federal criminal law. A. The Third, Fourth, Eighth and Ninth Cir- cuits have faithfully applied Santobello’s instruction that promises in plea agree- ments must be binding on the government, applying basic principles of contract law to find that obligations entered into on behalf of the “United States” or the “Government” apply to the federal government through- out the nation. Third Circuit. In United States v. Gebbie, 294 F.3d 540 (8d Cir. 2002), the Third Circuit squarely addressed the question of “whether promises made on behalf of ‘the Government’ or ‘the United States’ by a United States Attorney to a defendant bind other United States Attorneys with respect to the same defendant.” Id. at 546-47. After recognizing that the Second and Fourth Circuits “employ opposite default rules” from one another, id. at 547, the Third Circuit agreed with the Fourth Circuit and held that “when a United States Attorney negotiates and contracts on behalf of ‘the United States’ or ‘the Government’ in a plea agreement for specific crimes, that attorney speaks for and binds all of his or her fellow United States Attorneys with respect to those same crimes and those same defendants.” Jd. at 550. It went on to note that “United States Attorneys should not be viewed as sovereigns of autonomous fiefdoms. They represent the United States, and their promises on behalf of the Government must bind each other absent express contractual limitations or disavowals to the contrary.” Id. Fourth Circuit. The Fourth Circuit, in United States v. Carter, 454 F.2d 426 (4th Cir. 1972), was the DOJ-OGR-00000051