3
Shared Docs
2
Same-Page
3 / 6
Mentions
squarely refutes the government's position. The co-conspirator immunity provision does not prohibit merely prosecutions by the USAO for the SDFL ("USAO-SDFL"), but by "the United States." This broad prohibition was intentional, as demonstrated by the express references elsewhere in the NPA to the United
ew York, 404 U.S. 257 (1971) 12 Subaru Distribs. Corp. v. Subaru of Am., Inc., 425 F.3d 119 (2d Cir. 2005) 15 EFTA00065991 United States v. Aleman, 286 F.3d 86 (2d Cir. 2002) United States v. Annabi, 771 F.2d 670 (2d Cir. 1985) United States v. Ashy*: 29 passim 320 F. App'x 26 (2d Cir. 20
agreement or non-prosecution agreement is in genuine dispute. See, e.g., id. at 270 (noting testimony from defendant's attorney); United States v. Aleman, 286 F.3d 86, 91 (2d Cir. 2002) (remanding where "the district court failed to make a record that allows us to determine the existence, scope and ef
squarely refutes the government's position. The co-conspirator immunity provision does not prohibit merely prosecutions by the USAO for the SDFL ("USAO-SDFL"), but by "the United States." This broad prohibition was intentional, as demonstrated by the express references elsewhere in the NPA to the United
ew York, 404 U.S. 257 (1971) 12 Subaru Distribs. Corp. v. Subaru of Am., Inc., 425 F.3d 119 (2d Cir. 2005) 15 EFTA00099354 United States v. Aleman, 286 F.3d 86 (2d Cir. 2002) United States v. Annabi, 771 F.2d 670 (2d Cir. 1985) United States v. Ashy*: 29 passim 320 F. App'x 26 (2d Cir. 20
agreement or non-prosecution agreement is in genuine dispute. See, e.g., id. at 270 (noting testimony from defendant's attorney); United States v. Aleman, 286 F.3d 86, 91 (2d Cir. 2002) (remanding where "the district court failed to make I record that allows us to determine the existence, scope and ef
DU Lac, 929 F.3d 830 (7th Cir. 2019) 8, 9 Penncro Assocs., Inc. v. Sprint Spectrum, L.P., 499 F.3d 1151 (10th Cir. 2007) 8, 9 United States v. Aleman, 286 F.3d 86 (2d Cir. 2002) 17 United States v. Annabi, 771 F.2d 670 (2d Cir. 1985) passim United States v. CFW Const. Co., 583 F. Supp. 197 (
Page: EFTA00028882 →ision in the NPA is intended to refer only to the USAO-SDFL, it does so explicitly. See Mem. at 8-9 (citing examples of NPA's explicit references to USAO-SDFL). While the government is correct that the use of the term "the United States" in a plea agreement, without snore, is insufficient under Annabi and
Page: EFTA00028892 →ch, on its face, bars her prosecution. See Feldman, 939 F.3d at 184, 190 (hearing based on oral representations made to defendant); United States v. Aleman, 286 F.3d 86, 91 (2d Cir. 2002) (granting hearing where defendant submitted attorney affidavits alleging oral agreement); United States v. Sattar,
Page: EFTA00028900 →Entities connected to both USAO-SDFL and Aleman

Jeffrey Epstein
PERSON
United States
LOCATIONthe Southern District
LOCATIONFBI
ORGANIZATION
Ghislaine Maxwell
PERSONSantobello
PERSONEmmy Taylor
PERSON
Southern District of New York
ORGANIZATION
Scarlett Johansson
PERSONWalker
PERSONThompson
PERSON
Department of Justice
ORGANIZATIONJane Doe
PERSONSalameh
PERSON
Giglio
PERSONCollins
PERSONAnnabi
PERSON
Brady
PERSON
Reid Weingarten
PERSONRusso
PERSON