{
  "document_metadata": {
    "page_number": "246",
    "document_number": "293-1",
    "date": "05/25/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 246 of 349\nhave \"notified [the victims] that that was an all-encompassing plea, that that state court sentence would also mean that the federal government was not proceeding.\"\n\nSloman told OPR that he thought Acosta and Criminal Division Deputy Assistant Attorney General Sigal Mandelker had agreed that the decision whether to notify the victims of the state court proceedings should be \"left to the state.\"323 Mandelker, however, had no memory of advising Acosta to defer the decision to make notifications to the State Attorney, and she noted that the \"correspondence [OPR] provided to me from that time period\" discussing such a decision \"demonstrates that all of the referenced language came from Mr. Acosta and/or his team, and that I did not provide, suggest, or edit the language.\" Sloman told OPR that he initially believed that \"the victims were going to be notified at some level, especially because they had restitution rights under § 2255\"; but, his expectations changed after \"there was an agreement made that we were going to allow the state, since it was going to be a state case, to decide how the victims were going to be notified.\"\n\nAssistant State Attorney Belohlavek told OPR that she did not at any time receive a victim list from the USAO. She further said she did not receive any request from the USAO with regard to contacting the victims.\n\nIn response to Acosta's December 19, 2007 letter, Lefkowitz asserted that the FBI should not communicate with the victims, and that the state, not the USAO, should determine who can be heard at the sentencing hearing:\n\n[Y]our letter also suggests that our objection to your Office's proposed victims notification letter was that the women identified as victims of federal crimes should not be notified of the state proceedings. That is not true, as our previous letter clearly states. Putting aside our threshold contention that many of those to whom [CVRA] notification letters are intended are in fact not victims as defined in the Attorney General's 2000 Victim Witness Guidelines—a status requiring physical, emotional or pecuniary injury of the [victim]—it was and remains our position that these women may be notified of such proceedings but since they are neither witnesses nor victims to the state prosecution of this matter, they should not be informed of fictitious \"rights\" or invited to make sworn written or in-court testimonial statements against Mr. Epstein at such proceedings, as Ms. Villafaña repeatedly maintained they had the right to do. Additionally, it was and remains our position that any notification should be by mail and that all proactive efforts by the FBI to have communications with the witnesses after the execution of the Agreement should finally come to an end. We agree, however, with your December 19 modification of the previously drafted federal notification letter and agree that the\n323 In his June 3, 2008 letter to Deputy Attorney General Mark Filip, Sloman wrote, \"Acosta again consulted with DAAG Mandelker who advised him to make the following proposal [to defer notification to the State Attorney's Office].\" OPR found no other documentation relating to Mandelker's purported involvement in the decision.\n219\nDOJ-OGR-00004543",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 246 of 349",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "have \"notified [the victims] that that was an all-encompassing plea, that that state court sentence would also mean that the federal government was not proceeding.\"",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Sloman told OPR that he thought Acosta and Criminal Division Deputy Assistant Attorney General Sigal Mandelker had agreed that the decision whether to notify the victims of the state court proceedings should be \"left to the state.\"323 Mandelker, however, had no memory of advising Acosta to defer the decision to make notifications to the State Attorney, and she noted that the \"correspondence [OPR] provided to me from that time period\" discussing such a decision \"demonstrates that all of the referenced language came from Mr. Acosta and/or his team, and that I did not provide, suggest, or edit the language.\" Sloman told OPR that he initially believed that \"the victims were going to be notified at some level, especially because they had restitution rights under § 2255\"; but, his expectations changed after \"there was an agreement made that we were going to allow the state, since it was going to be a state case, to decide how the victims were going to be notified.\"",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Assistant State Attorney Belohlavek told OPR that she did not at any time receive a victim list from the USAO. She further said she did not receive any request from the USAO with regard to contacting the victims.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In response to Acosta's December 19, 2007 letter, Lefkowitz asserted that the FBI should not communicate with the victims, and that the state, not the USAO, should determine who can be heard at the sentencing hearing:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "[Y]our letter also suggests that our objection to your Office's proposed victims notification letter was that the women identified as victims of federal crimes should not be notified of the state proceedings. That is not true, as our previous letter clearly states. Putting aside our threshold contention that many of those to whom [CVRA] notification letters are intended are in fact not victims as defined in the Attorney General's 2000 Victim Witness Guidelines—a status requiring physical, emotional or pecuniary injury of the [victim]—it was and remains our position that these women may be notified of such proceedings but since they are neither witnesses nor victims to the state prosecution of this matter, they should not be informed of fictitious \"rights\" or invited to make sworn written or in-court testimonial statements against Mr. Epstein at such proceedings, as Ms. Villafaña repeatedly maintained they had the right to do. Additionally, it was and remains our position that any notification should be by mail and that all proactive efforts by the FBI to have communications with the witnesses after the execution of the Agreement should finally come to an end. We agree, however, with your December 19 modification of the previously drafted federal notification letter and agree that the",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "323 In his June 3, 2008 letter to Deputy Attorney General Mark Filip, Sloman wrote, \"Acosta again consulted with DAAG Mandelker who advised him to make the following proposal [to defer notification to the State Attorney's Office].\" OPR found no other documentation relating to Mandelker's purported involvement in the decision.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "219",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004543",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Sloman",
      "Acosta",
      "Sigal Mandelker",
      "Belohlavek",
      "Lefkowitz",
      "Mark Filip",
      "Mr. Epstein",
      "Ms. Villafaña"
    ],
    "organizations": [
      "OPR",
      "USAO",
      "FBI",
      "Criminal Division",
      "State Attorney's Office",
      "Department of Justice"
    ],
    "locations": [],
    "dates": [
      "December 19, 2007",
      "June 3, 2008",
      "05/25/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 293-1",
      "DOJ-OGR-00004543"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Jeffrey Epstein, with discussions about victim notification and the involvement of various government agencies and officials."
}