Annabi

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location United States
Legal representative
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person Appellant
Legal representative
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organization Second Circuit
Judicial precedent
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person MAXWELL
Legal representative
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Date Event Type Description Location Actions
1985-01-01 Court decision Court decision in the case United States v. Annabi. 2d Cir. View
1985-01-01 Legal decision Decision in the case United States v. Annabi, 771 F.2d 670 (2d Cir. 1985). 2d Cir. View

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This document is an excerpt from a legal filing, discussing the interpretation of a Non-Prosecution Agreement (NPA) and plea agreements. It argues that ambiguities in such agreements should be resolved against the government, citing several court cases. The document specifically contends that the NPA in question was intended to bind the Southern District of New York, contrary to a Second Circuit conclusion that suggested it only bound the Southern District of Florida.

Legal document / court filing excerpt
2025-11-20

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This document discusses legal principles of contract interpretation in the context of plea agreements, citing several court cases. It argues that ordinary contract principles should apply to plea agreements, with a strong emphasis on fairness to the defendant and construing ambiguity against the government, and suggests that the cases of Annabi and Maxwell should be reversed based on these principles.

Legal document/court filing
2025-11-20

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This legal document, dated July 27, 2020, is a filing in the criminal case of Ms. Maxwell, addressed to Judge Alison J. Nathan. It discusses the legal standard for a protective order over discovery materials, arguing that restrictions should apply not only to the defense but also to the government's potential witnesses and their counsel. The filing expresses concern that these witnesses, who are also involved in civil litigation against Ms. Maxwell, might use the discovery materials to support their civil cases or in public statements.

Legal document
2025-11-20

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This legal document, filed on July 13, 2020, is a portion of the prosecution's argument against a defendant's motion. The prosecution contends that a Non-Prosecution Agreement (NPA) between Jeffrey Epstein and the U.S. Attorney's Office in the Southern District of Florida does not protect the defendant from prosecution in the Southern District of New York, as she was not a party to the agreement and it does not bind other districts. A footnote reveals that since the charges were made public, the FBI has been contacted by new individuals willing to provide more evidence against the defendant.

Legal document
2025-11-20

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This legal document, part of a court filing, argues against a defendant's motion for bail by refuting her claim of protection under a Non-Prosecution Agreement (NPA). The prosecution asserts the NPA between Jeffrey Epstein and the U.S. Attorney's Office in the Southern District of Florida is irrelevant because the defendant was not a party to it and it does not bind the current prosecuting office in the Southern District of New York. A footnote adds that new witnesses have recently come forward to the FBI and U.S. Attorney's Office to provide more information against the defendant.

Legal document
2025-11-20

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This page from a legal filing (likely an appellate opinion) rejects Ghislaine Maxwell's argument that Jeffrey Epstein's Non-Prosecution Agreement (NPA) prevents her prosecution in the Southern District of New York (SDNY). The court cites *United States v. Annabi* to conclude that the NPA was expressly limited to the Southern District of Florida and did not bind other districts like SDNY. Footnotes discuss legal precedents regarding plea agreements and double jeopardy.

Legal document (appellate court opinion/ruling)
2025-11-20

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This legal document argues that a charge (Count Six) should be dismissed because the U.S. Attorney's Office for the Southern District of New York (USAO-SDNY) is bound by a Non-Prosecution Agreement (NPA). The author contends that the NPA shows an "affirmative appearance" of a broad restriction on prosecution for co-conspirators, contrasting it with the specifically limited non-prosecution provision for Epstein, which was restricted to "in this District."

Legal document
2025-11-20

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This legal document argues that the government is precluded from charging the Appellant under Count Six due to a prior Non-Prosecution Agreement (NPA). The argument is based on legal precedent against prosecuting the same crime in a new district and asserts that the charge, involving the trafficking of a witness named Carolyn, falls within the time period covered by the NPA. The document also references a court's finding that the NPA covers Maxwell's involvement in offenses committed by Epstein.

Legal document
2025-11-20

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This page from a legal brief (Case 22-1426) argues points regarding the scope of plea agreements and Double Jeopardy. It analyzes the 'Abbamonte-Alessi rule' and the 'Annabi' precedent to determine if a plea agreement binding 'the Government' applies to other United States Attorney Offices (USAOs). The text argues that for charges to be distinct enough to bypass the rule, they must cover a new time period, noting that in the Annabi case, the conspiracy period was two years longer.

Legal brief / appellate filing
2025-11-20

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This document is page 45 of a legal brief filed on February 28, 2023 (Case 22-1426). It argues that the government must adhere to plea bargains and immunity agreements, specifically referencing a Non-Prosecution Agreement (NPA) and arguing that 'Count Six' falls within the timeframe of that NPA. It cites case law (Harvey, Annabi) to support the argument that the government is held to a high standard regarding nationwide immunity promises and that new charges must be 'sufficiently distinct' from those covered by a plea.

Legal brief / court filing (appellate)
2025-11-20

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This legal document is a page from a defendant's brief arguing that the court made an error. The defendant contends the court improperly applied the 'Annabi' rule from the Second Circuit to a Non-Prosecution Agreement (NPA) that was negotiated in Florida, which falls under the Eleventh Circuit. The argument is that since the NPA was negotiated with Florida prosecutors in exchange for Epstein's guilty plea in a Florida state court, Eleventh Circuit law should apply instead.

Legal document
2025-11-20

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This document is page 38 of a legal brief (Case 22-1426, dated Feb 28, 2023) filed in the Second Circuit Court of Appeals. It contains legal arguments attempting to distance the current case from the precedent set in *U.S. v. Annabi*, arguing that *Annabi* is an outlier regarding whether a plea agreement in one district binds another. The text consists primarily of extensive footnotes citing various Second Circuit decisions (*Prisco*, *Ashraf*, *Salameh*, etc.) that limited plea agreements to specific US Attorney's Offices, supporting the government's position against the Appellant (identified by case number as Ghislaine Maxwell).

Legal brief / court filing (appellate brief)
2025-11-20

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This legal document argues that the 'Annabi' court decision is an outlier and inconsistent with the Circuit's established law regarding the interpretation of plea agreements. The author contends that contrary to the District Court's opinion, the Circuit has been reluctant to rely on Annabi's reasoning, which construes ambiguities against the defendant, and has instead consistently held that such ambiguities should be resolved against the Government.

Legal document
2025-11-20

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This legal document, a page from a court filing dated February 28, 2023, presents a series of case law citations to support the legal argument that a plea agreement made by an Assistant U.S. Attorney (AUSA) binds the entire United States government. The cited cases establish that the U.S. government is considered a single entity across all districts, and therefore, an agreement made by one of its attorneys in one location (e.g., West Virginia) is enforceable against federal prosecutors in another (e.g., South Dakota).

Legal document
2025-11-20

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This legal document excerpt critiques the Second Circuit's interpretation of plea agreements, arguing it misread its own precedent in the 'Papa' case to create an "illogical" rule. This rule is contrasted with United States Supreme Court precedent from cases like 'Santobello' and 'Giglio', which establish that promises made by one prosecutor are binding on other prosecutors within the same office and must be disclosed.

Legal document
2025-11-20

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This document is a page from a legal filing that discusses the legal precedent set in the Annabi case concerning the scope of plea agreements. It explains the "Annabi rule," which holds that a plea agreement only binds the U.S. Attorney's office in the district where it was made, unless explicitly stated otherwise. The document also highlights that this rule has been sharply criticized by other courts, such as in U.S. v. Gebbie, for lacking a sound analytical basis.

Legal document
2025-11-20

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This legal document argues that the Appellant, identified as Maxwell, is a third-party beneficiary of a Non-Prosecution Agreement (NPA) related to Epstein and therefore has standing to enforce it. The brief contends that a District Court erred in its ruling that the NPA's immunity for co-conspirators only applied to the U.S. Attorney's Office in the Southern District of Florida (USAO-SDFL), arguing the agreement's plain text referring to "the United States" should bind all U.S. Attorney's Offices, including the one in the Southern District of New York (USAO-SDNY).

Legal document
2025-11-20

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This document is the Table of Contents (page i) for an appellate brief filed on February 28, 2023, in Case 22-1426. It outlines legal arguments asserting that the 'Appellant' (contextually Ghislaine Maxwell) should have all counts dismissed based on the Epstein Non-Prosecution Agreement (NPA), claiming status as a third-party beneficiary and arguing that the USAO-SDNY is bound by the 'potential co-conspirators' provision.

Legal court filing (appellate brief table of contents)
2025-11-20

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This document is page 4 of a legal opinion (Case 22-1426) dated February 28, 2023. The court rejects Ghislaine Maxwell's arguments that the *Commonwealth v. Cosby* decision or the *Annabi* precedent should prevent her prosecution. The court rules that the Non-Prosecution Agreement (NPA) from one district does not bind another district in this context, distinguishing her situation from Bill Cosby's case where a specific promise not to prosecute was made by a district attorney.

Legal opinion / court filing
2025-11-20

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This legal document, filed on April 16, 2021, argues that a non-prosecution agreement (NPA) does not bind the U.S. Attorney's Office for the Southern District of New York. Citing Second Circuit precedent, particularly United States v. Annabi, the filing asserts that such agreements are limited to the district in which they are made unless they explicitly state a broader scope. The document refutes an opposing argument from an individual named Maxwell, stating the NPA lacks the necessary language to apply to other districts.

Legal document
2025-11-20

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This document is page 10 of a legal filing (dated December 2, 2024) related to the appeal of Ghislaine Maxwell (Case 22-1426). The text argues that the Non-Prosecution Agreement (NPA) signed by Jeffrey Epstein was geographically limited to the Southern District of Florida and does not bind the Southern District of New York (USAO-SDNY) or prevent them from prosecuting Maxwell. It cites the legal precedent 'United States v. Annabi' to support the claim that plea agreements do not automatically bind other districts unless affirmatively stated.

Court filing (appellate brief/opinion)
2025-11-20

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This legal document argues for limiting the application of the 'Annabi' doctrine. It contends that this doctrine, from the Second Circuit, should not apply to a plea agreement originating in the Eleventh Circuit, where precedent dictates that ambiguities are resolved against the government. The document also asserts that the Annabi doctrine should only be applied when new charges are 'sufficiently distinct' from the original ones.

Legal document
2025-11-20

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This document is a page from a legal filing that critiques the reasoning of a prior court decision, 'Annabi'. The author argues that 'Annabi' departed from the established legal doctrine that a plea agreement with a specific U.S. Attorney's Office (USAO) only binds that office, not the entire U.S. government, unless explicitly stated otherwise. The text cites numerous other cases in its footnotes to support this traditional, more limited interpretation of such agreements.

Legal document
2025-11-20

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This page from a legal filing argues that plea agreements made by any U.S. Attorney are binding on the entire U.S. government across all federal districts. It cites several court cases establishing this principle and the related rule that any ambiguities in such agreements must be interpreted against the government. The document concludes by stating that a case named Annabi contradicts this established legal precedent.

Legal document
2025-11-20

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This legal document, a page from a court filing, argues that a plea agreement made by a United States Attorney's Office (USAO) in one district is generally binding on other USAOs and the federal government as a whole. It cites several court cases, such as Gebbie and Van Thournout, to support this majority view, while also acknowledging contrary or more limited rulings from circuits like the Seventh and Sixth in a footnote.

Legal document
2025-11-20
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