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first to hold that a promise on behalf of the United
States in one district not to prosecute a defendant is
binding upon U.S. Attorney’s offices in other districts.
Id. at 428. As that court noted, “[t]he United States
government is the United States government through-
out all of the states and districts. ... A contrary result
would constitute a strong deterrent to the willingness
of defendants accused of multistate crimes to cooperat-
ing in speedy disposition of their cases and in appre-
hending and processing codefendants” Jd. The Fourth
Circuit concluded, “[a]t stake is the honor of the
government|,] public confidence in the fair admin-
istration of justice, and the efficient administration of
justice in a federal scheme of government.” Id.
Eighth Circuit. The Eighth Circuit similarly found
in United States v. Van Thournout, 100 F.3d 590
(8th Cir. 1996), that “absent an express limitation,
any promises made by an Assistant United States
Attorney in one district will bind an Assistant United
States Attorney in another district.” Id. at 594. Inter-
preting a plea agreement which provided that the
“United States” would make certain recommendations
regarding the defendant’s sentence, the court held
that this provision was binding on the U.S. Attorney’s
office in another district and that the terms of the
agreement should be enforced. See also Margalli-
Olvera v. Immigration and Naturalization Service,
43 F.3d 345, 352 (8th Cir. 1994) (finding that “the term
‘United States’ is a reference to the entire United
States government and all the agencies hereof” in the
context of determining that the INS is bound by
promises made by the U.S. Attorney’s office).
Ninth Circuit. In Thomas v. Immigration and
Naturalization Service, 35 F.3d 1332 (9th Cir. 1994),
the Ninth Circuit held that a promise made by the
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