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e's the only one who takes the blame for what happened").3 The government further asserts that Ms. Maxwell's position is not supported by subsequent Second Circuit cases that apply Annabi. (Opp. 5-6). But this argument simply begs the question. Although courts in this Circuit have applied Annabi to evaluate whe
79) 13, 14 United States v. Carter, 454 F.2d 426 (4th Cir. 1972) 10 United States v. Dionisio, 503 F.3d 78 (2d Cir. 2007) 12 United States v. Gebbie, 294 F.3d 540 (3d Cir. 2002) 6, 7, 10 United States v. Gonzalez, 93 F. App'x 268 (2d Cir. 2004) 7 United States v. Korfant, 771 F.2d 660 (2d C
t because Annabi did not address the circumstances of this case; it is also consistent with fundamental fairness. As the Third Circuit cautioned in Gebbie, individual U.S. Attorney's Offices should not view themselves as "sovereigns of autonomous fiefdoms" with the ability to charge a defendant with t
t in this District as barred by what they claimed was an earlier "plea agreement" in the Eastern District, and the court denied the motion. Id. The Second Circuit, in affirming the denial, stated simply that "[a] plea agreement binds only the office of the United States Attorney for the district in which the p
82 (2d Cir. 2019) 13, 26, 29, 30 United States v. Florida West Intl Airways, Inc., 853 F. Supp. 2d 1209 (S.D. Fla. 2012) 16, 17 United States v. Gebbie, 294 F.3d 540 (3d Cir. 2002) 24, 25 United States v. Gonzalez, 93 F. App'x 268 (2d Cir. 2004) 14, 22, 27, 29 United States v. Harvey, 791 F.2d
t in this District as barred by what they claimed was an earlier "plea agreement" in the Eastern District, and the court denied the motion. Id. The Second Circuit, in affirming the denial, stated simply that "[I] plea agreement binds only the office of the United States Attorney for the district in which the p
82 (2d Cir. 2019) 13, 26, 29, 30 United States v. Florida West Intl Airways, Inc., 853 F. Supp. 2d 1209 (S.D. Fla. 2012) 16, 17 United States v. Gebbie, 294 F.3d 540 (3d Cir. 2002) 24, 25 United States v. Gonzalez, 93 F. App'x 268 (2d Cir. 2004) 14, 22, 27, 29 United States v. Harvey, 791 F.2d
182 (2d Cir. 2019) 5, 6, 10, 17 United States v. Florida West Intl Airways, Inc., 853 F. Supp. 2d 1209 (S.D. Fla. 2012) 3, 4, 6 United States v. Gebbie, 294 F.3d 540 (3d Cir. 2002) 12 United States v. Gonzalez, 93 F. App'x 268 (2d Cir. 2004) 8 United States v. Harvey, 791 F.2d 294 (4th Cir. 19
Page: EFTA00028882 →an, 939 F.3d 182 (2d Cir. 2019), for the proposition that "plea agreements differ from commercial contracts" (Opp. 18), the "differ[ence]" to which the Second Circuit was referring was that in construing a plea agreement, 3 Accuser-2 is identified in the Indictment as Minor Victim-2. 5 EFTA00028888 --- PAGE BR
Page: EFTA00028889 →ns omitted), and the government is held "responsible for imprecisions or ambiguities in the agreement." United States v. Padilla, 186 F.3d 136, 142 (2d Cir. 1999). While the government argues that Annabi relieves it of this responsibility where the "imprecisions or ambiguities" relate to the geographic
Page: EFTA00028893 →Entities connected to both Second Circuit and Gebbie

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONthe Southern District
LOCATION
Department of Justice
ORGANIZATION
Julie K. Brown
PERSON
Michael Cohen
PERSON
Southern District of New York
ORGANIZATIONJeffrey Pagliuca
PERSON
New York
LOCATION
Virginia Giuffre
PERSON
Denver
LOCATION
Colorado
LOCATIONFBI
ORGANIZATIONCohen & Gresser LLP
ORGANIZATION
Harvey Weinstein
PERSONBobbi C. Sternheim
PERSONAnnabi
PERSON
Brady
PERSON
Alexander Acosta
PERSON