15 As to the first and most basic of these principles, terms within a plea agreement are to be given their ordinary meaning. See, e.g., Williams, 102 F.3d at 927; Margalli-Olvera, 43 F.3d at 352; United States v. Rubbo, 396 F.3d 13830, 13834 (11th Cir. 2005). See Antonin Scalia & Bryan A. Garner, Reading Law: The Interpretation of Legal Texts at 69 (2012) (“The ordinary meaning rule is the most fundamental semantic rule of interpretation.”) It should be beyond reasonable dispute that the ordinary meaning of the term “the United States” is the country as a whole. This leads to the presumption that if a plea agreement states that the “United States” cannot further prose- cute an individual, this means that the United States cannot do so anywhere in the United States. If that is not what is intended, and the intent is to bind only a particular district, this can easily be achieved by using the ordinary descriptors for that district. Second, the placement of language informs the in- tent of the parties. During the course of the NPA negotiations, the co-conspirator immunity clause was severed from Epstein’s immunity clause and moved geographically to the end of the NPA after the 2255 section. This is significant because the 2255 sections “were not limited to any district.” The 2255 section and the co-conspirator clause were negotiated in tandem and the 2255 language was accepted in return for the global immunity provided to the co-conspira- tors. The co-conspirator clause was subsequently severed from Epstein’s restrictive language and moved geographically below the 2255 as a consequence. The NPA was identified as a hybrid agreement where one section referred to the district-specific language and finding that the NPA precludes Maxwell’s prosecution in this case. DOJ-OGR-00000057