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. 1985) 22 United States v. Prisco, 391 F. App'x 920 (2d Cir. 2010) 22 United States v. Ready, 82 F.3d 551 (2d Cir. 1996) 12 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 20, 21, 23 United States v. Salameh, 152 F.3d 88 (2d Cir. 1998) 22 United States v. Sattar, No. 02 Cr. 395 (JGK),
n another district, which the court held irrelevant; they cited no "affirmative appearance" in support of their position, as Ms. Maxwell has. And in Russo, the court found it unnecessary to reach Annabi, but acknowledged that an "affirmative appearance" of an intent to bind other USAOs can be found ev
him to benefit third- parties," and therefore the defendant was a third-party beneficiary with standing to enforce the agreement. Id. at 609. Both Florida West and EI-Sadig illustrate how the government's argument that Ms. Maxwell lacks standing to enforce the NPA is contrary to bedrock principles of contra
. 1985) 22 United States v. Prisco, 391 F. App'x 920 (2d Cir. 2010) 22 United States v. Ready, 82 F.3d 551 (2d Cir. 1996) 12 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 20, 21, 23 United States v. Salameh, 152 F.3d 88 (2d Cir. 1998) 22 United States v. Sattar, No. 02 Cr. 395 (JGK),
n another district, which the court held irrelevant; they cited no "affirmative appearance" in support of their position, as Ms. Maxwell has. And in Russo, the court found it unnecessary to reach Annabi, but acknowledged that an "affirmative appearance" of an intent to bind other USAOs can be found ev
him to benefit third- parties," and therefore the defendant was I third-party beneficiary with standing to enforce the agreement. Id. at 609. Both Florida West and EI-Sadig illustrate how the government's argument that Ms. Maxwell lacks standing to enforce the NPA is contrary to bedrock principles of contra
nited States v. Ruiz, 702 F. Supp. 1066 (S.D.N.Y. 1989) 214 United States v. Ruiz, 894 F.2d 501 (2d Cir. 1990) 207,213,214,217 United States v. Russo, 483 F. Supp. 2d 301 (S.D.N.Y. 2007) 274, 282 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 5, 1 I United States v. Rutkoske, 506 F.3d 1
cts Although a defendant may offer evidence that the negotiations between the prosecutor and defendant contained a promise to bind other districts, Russo, 801 F.2d at 626, the defendant has failed to do so here. The defendant's motion is replete with bare assertions and conclusoiy allegations, but it
ne of which analyzed the threshold question of whether third party standing concepts from contract law apply to plea agreements. In United States v. Florida West Intl Airways, Inc., 853 F. Supp. 2d 1209, 1228 (S.D. Fla. 2012), the district court applied the third party beneficiary doctrine to a former airlin
ed States v. Ruiz, 702 F. Supp. 1066 (S.D.N.Y. 1989) 214 United States v. Ruiz, 894 F.2d 501 (2d Cir. 1990) 207, 213, 214, 217 United States v. Russo, 483 F. Supp. 2d 301 (S.D.N.Y. 2007) 274, 282 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 5, 11 United States v. Rutkoske, 506 F.3d 17
cts Although a defendant may offer evidence that the negotiations between the prosecutor and defendant contained a promise to bind other districts, Russo, 801 F.2d at 626, the defendant has failed to do so here. The defendant's motion is replete with bare assertions and conclusory allegations, but it
ne of which analyzed the threshold question of whether third party standing concepts from contract law apply to plea agreements. In United States v. Florida West Int 'I Airways, Inc., 853 F. Supp. 2d 1209, 1228 (S.D. Fla. 2012), the district court applied the third party beneficiary doctrine to a former airlin
ed States v. Ruiz, 702 F. Supp. 1066 (S.D.N.Y. 1989) 214 United States v. Ruiz, 894 F.2d 501 (2d Cir. 1990) 207, 213, 214, 217 United States v. Russo, 483 F. Supp. 2d 301 (S.D.N.Y. 2007) 274, 282 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 5, 11 United States v. Rutkoske, 506 F.3d 17
cts Although a defendant may offer evidence that the negotiations between the prosecutor and defendant contained a promise to bind other districts, Russo, 801 F.2d at 626, the defendant has failed to do so here. The defendant's motion is replete with bare assertions and conclusory allegations, but it
ne of which analyzed the threshold question of whether third party standing concepts from contract law apply to plea agreements. In United States v. Florida West Int 'I Airways, Inc., 853 F. Supp. 2d 1209, 1228 (S.D. Fla. 2012), the district court applied the third party beneficiary doctrine to a former airlin
ed States v. Ruiz, 702 F. Supp. 1066 (S.D.N.Y. 1989) 143 United States v. Ruiz, 894 F.2d 501 (2d Cir. 1990) 139, 142, 143, 145 United States v. Russo, 483 F. Supp. 2d 301 (S.D.N.Y. 2007) 182, 190 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 4, 9 United States v. Rutkoske, 506 F.3d 170
cts Although a defendant may offer evidence that the negotiations between the prosecutor and defendant contained a promise to bind other districts, Russo, 801 F.2d at 626, the defendant has failed to do so here. The defendant's motion is replete with bare assertions and conclusory allegations, but it
ne of which analyzed the threshold question of whether third party standing concepts from contract law apply to plea agreements. In United States v. Florida West Int 'I Airways, Inc., 853 F. Supp. 2d 1209, 1228 (S.D. Fla. 2012), the district court applied the third party beneficiary doctrine to a former airlin
ed States v. Ruiz, 702 F. Supp. 1066 (S.D.N.Y. 1989) 214 United States v. Ruiz, 894 F.2d 501 (2d Cir. 1990) 207, 213, 214, 217 United States v. Russo, 483 F. Supp. 2d 301 (S.D.N.Y. 2007) 274, 282 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 5, 11 United States v. Rutkoske, 506 F.3d 17
cts Although a defendant may offer evidence that the negotiations between the prosecutor and defendant contained a promise to bind other districts, Russo, 801 F.2d at 626, the defendant has failed to do so here. The defendant's motion is replete with bare assertions and conclusory allegations, but it
ne of which analyzed the threshold question of whether third party standing concepts from contract law apply to plea agreements. In United States v. Florida West Int 'I Airways, Inc., 853 F. Supp. 2d 1209, 1228 (S.D. Fla. 2012), the district court applied the third party beneficiary doctrine to a former airlin
Entities connected to both Russo and Florida West

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSONEmmy Taylor
PERSONAnnabi
PERSON
Scarlett Johansson
PERSONCollins
PERSONThompson
PERSONWalker
PERSON
Southern District of New York
ORGANIZATIONthe Southern District
LOCATIONFBI
ORGANIZATION
Alberto Gonzales
PERSONTracy
PERSONBortnovsky
PERSONSantobello
PERSONAleman
PERSON
Giglio
PERSON
Supreme Court
ORGANIZATIONSalameh
PERSON