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bail proceeding, that are not even foreclosed by the cases the government does cite to you. They cite to you the -- I'm going to skip this one, the Annabi case, A-N-N-A-B-I case, which says, "The plea agreement binds only the office of the U.S. Attorney for the district in which the plea is entered u
n that never shifts, has not made a showing as required, that our client is a risk of flight. When you consider the risk, as Judge Raggi put it, in Sabhnani, the actual risk of flight, not fantasy and not speculation, when you consider that the only factors they really point to are ones that the cases
bail proceeding, that are not even foreclosed by the cases the government does cite to you. They cite to you the -- I'm going to skip this one, the Annabi case, A-N-N-A-B-I case, which says, "The plea the office of the U.S. Attorney for the plea is entered unless it affirmatively agreement binds onl
n that never shifts, has not made a showing as required, that our client is a risk of flight. When you consider the risk, as Judge Raggi put it, in Sabhnani, the actual risk of flight, not fantasy and not speculation, when you consider that the only factors they really point to are ones that the cases
Supp. 3d 283, 292 (E.D.N.Y. 2014) (Bianco, J.) (collecting cases). The Second Circuit has never directly addressed this issue. See United States v. Sabhnani, 493 F.3d 63, 78 n.18 (2d Cir. 2007) ("The government has not argued and, therefore, we have no occasion to consider whether it would be `contrary
Page: EFTA00015539 →ited States v. Brown, No. 99-1230, 2002 WL 34244994, at *2 (2d Cir. Apr. 26, 2002) (in analyzing an SDFL plea agreement, reiterating the holding of Annabi and noting that it applies "even if the plea agreement purports to bind 'the Government' or the "United States") (summary order); United States v. B
Page: EFTA00015544 →trict in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.") (citing United States v. Annabi, 771 F.2d 670, 672 (2d Cir. 1985) (per curiam)). Moreover, any references in an NPA to the "Government" or the "United States" do not abrogate thes
Page: EFTA00015544 →Supp. 3d 283, 292 (E.D.N.Y. 2014) (Bianco, J.) (collecting cases). The Second Circuit has never directly addressed this issue. See United States v. Sabhnani, 493 F.3d 63, 78 n.18 (2d Cir. 2007) ("The government has not argued and, therefore, we have no occasion to consider whether it would be `contrary
Page: EFTA00028792 →trict in which the plea is entered unless it affirmatively appears that the agreement contemplates a broader restriction.") (citing United States v. Annabi, 771 F.2d 670, 672 (2d Cir. 1985) (per curiam)). Moreover, any references in an NPA to the "Government" or the "United States" do not abrogate thes
Page: EFTA00028797 →Entities connected to both Annabi and Sabhnani

Jeffrey Epstein
PERSON
United States
LOCATION
Reid Weingarten
PERSON
Ghislaine Maxwell
PERSONthe Southern District
LOCATIONEmmy Taylor
PERSONSalameh
PERSONFBI
ORGANIZATIONSecond Circuit
ORGANIZATIONLaskow
PERSON
Department of Justice
ORGANIZATION
Anderson
PERSON
Michael Jackson
PERSONMartin Weinberg
PERSON
Prince Andrew
PERSON
New York State
LOCATIONPitman
PERSON
Richard M. Berman
PERSONGleeson
PERSONCasteneda
PERSON