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ons. The Court disagrees for two independent reasons. First, under controlling Second Circuit precedent, the NPA does not bind the U.S. Attorney for the Southern District of New York. Second, it does not cover the offenses charged in the S1 superseding indictment. 3 EFTA00020263 --- PAGE BREAK --- Case 1:20-cr-00330-AJN
Page: EFTA00020263 →U.S. Attorney makes a promise as part of a plea bargain, both contract principles and due process require the federal government to fulfill it. See Santobello v. New York, 404 U.S. 257, 262 (1971); United States v. Ready, 82 F.3d 551, 558 (2d Cir. 1996). The question here is not whether the U.S. Attorney f
Page: EFTA00020264 →PAGE BREAK --- Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 4 of 34 A. The non-prosecution agreement does not bind the U.S. Attorney for the Southern District of New York United States Attorneys speak for the United States. When a U.S. Attorney makes a promise as part of a plea bargain, both contract principles and d
Page: EFTA00020264 →ons. The Court disagrees for two independent reasons. First, under controlling Second Circuit precedent, the NPA does not bind the U.S. Attorney for the Southern District of New York. Second, it does not cover the offenses charged in the S1 superseding indictment. 3 EFTA00022093 --- PAGE BREAK --- Case 1:20-cr-00330-AJN
Page: EFTA00022093 →U.S. Attorney makes a promise as part of a plea bargain, both contract principles and due process require the federal government to fulfill it. See Santobello v. New York, 404 U.S. 257, 262 (1971); United States v. Ready, 82 F.3d 551, 558 (2d Cir. 1996). The question here is not whether the U.S. Attorney f
Page: EFTA00022094 →PAGE BREAK --- Case 1:20-cr-00330-AJN Document 207 Filed 04/16/21 Page 4 of 34 A. The non-prosecution agreement does not bind the U.S. Attorney for the Southern District of New York United States Attorneys speak for the United States. When a U.S. Attorney makes a promise as part of a plea bargain, both contract principles and d
Page: EFTA00022094 →ons. The Court disagrees for two independent reasons. First, under controlling Second Circuit precedent, the NPA does not bind the U.S. Attorney for the Southern District of New York. Second, it does not cover the offenses charged in the S1 superseding indictment. 3 EFTA00029542 --- PAGE BREAK --- Case 1:20-cr-00330-AJN
Page: EFTA00029542 →U.S. Attorney makes a promise as part of a plea bargain, both contract principles and due process require the federal government to fulfill it. See Santobello v. New York, 404 U.S. 257, 262 (1971); United States v. Ready, 82 F.3d 551, 558 (2d Cir. 1996). The question here is not whether the U.S. Attorney f
Page: EFTA00029543 →PAGE BREAK --- Case 1:20-cr-00330-AJN Document 208 Filed 04/16/21 Page 4 of 34 A. The non-prosecution agreement does not bind the U.S. Attorney for the Southern District of New York United States Attorneys speak for the United States. When a U.S. Attorney makes a promise as part of a plea bargain, both contract principles and d
Page: EFTA00029543 →Entities connected to both Santobello and District Court for the Southern District of New York

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
United States
LOCATIONJane Doe
PERSON
Department of Justice
ORGANIZATION
Audrey Strauss
PERSON
Marc Rich
PERSONU.S. Attorney's Office
ORGANIZATIONFBI
ORGANIZATION
Alison J. Nathan
PERSON
Geoffrey S. Berman
PERSON
Kenneth Marra
PERSON
New Hampshire
LOCATION
Bradley Edwards
PERSONEmmy Taylor
PERSONSecond Circuit
ORGANIZATIONMartin Weinberg
PERSONthe Southern District
LOCATION
Paul Cassell
PERSON