{
  "document_metadata": {
    "page_number": "99",
    "document_number": "204-3",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 99 of 348\n\ntwelve months, with six served in home confinement, to run consecutively.\n\nI just received an e-mail asking if Mr. Epstein could just do 12 months imprisonment instead.\n\nAs you can see, Mr. Epstein is having second thoughts about doing jail time. I would like to send Jay Lefkowitz an e-mail stating that if we do not have a signed agreement by tomorrow at 5:00, negotiations will end. I have selected tomorrow at 5:00 because it gives them enough time to really negotiate an agreement if they are serious about it, and if not, it gives me one day before the Jewish holiday to get [prepared] for Tuesday . . . [September 25], when I plan to [file charges], and it gives the office sufficient time to review the indictment package.\n\nDo you concur?\n\nA few minutes later, the incoming West Palm Beach manager emailed Lourie, suggesting that Lourie \"talk to Epstein and close the deal.\"118\n\nWithin moments, Lourie replied to the manager, with a copy to Villafaña, reporting that he had just spoken with Lefkowitz and agreed \"to two fed[eral] obstruction[] charges (24 month cap) with nonbinding recommendation for 18 months. When [Epstein] gets out, he has to plead to state offenses, including against minor, registrable, and then take one year house arrest/community confinement.\" By reply email, Villafaña asked Lourie to call her, but there is no record of whether they spoke.\n\nF. Defense Counsel Offers New Proposals Substantially Changing the Terms of the Federal Plea Agreement, which the USAO Rejects\n\nApproximately an hour after Lourie's email reporting the deal he had reached with Lefkowitz, Lefkowitz sent Villafaña a revised draft plea agreement. Despite the agreement Lourie believed he and Lefkowitz had reached that morning, Lefkowitz's proposal would have resulted in a 16-month federal sentence followed by 8 months of supervised release served in the form of home detention. Lefkowitz also inserted a statement in his proposal explicitly prohibiting the USAO from requesting, initiating, or encouraging immigration authorities to institute immigration proceedings against two of Epstein's female assistants.\n\nVillafaña circulated the defense's proposed plea agreement to Lourie and two other supervisors, and expressed frustration that the new defense version incorporated terms that were \"completely different from what Jay just told Andy they would agree to.\" Villafaña also pointed out that the defense \"wants us to recommend an improper calculation\" of the sentencing guidelines\n\n118 The manager told OPR that he probably meant this as a joke because in his view the continued back-and-forth communications with defense counsel \"was ridiculous,\" and the only way to \"get this deal done\" might be to have a direct conversation with Epstein.\n\n73",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 99 of 348",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "twelve months, with six served in home confinement, to run consecutively.\n\nI just received an e-mail asking if Mr. Epstein could just do 12 months imprisonment instead.\n\nAs you can see, Mr. Epstein is having second thoughts about doing jail time. I would like to send Jay Lefkowitz an e-mail stating that if we do not have a signed agreement by tomorrow at 5:00, negotiations will end. I have selected tomorrow at 5:00 because it gives them enough time to really negotiate an agreement if they are serious about it, and if not, it gives me one day before the Jewish holiday to get [prepared] for Tuesday . . . [September 25], when I plan to [file charges], and it gives the office sufficient time to review the indictment package.\n\nDo you concur?",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "A few minutes later, the incoming West Palm Beach manager emailed Lourie, suggesting that Lourie \"talk to Epstein and close the deal.\"118",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Within moments, Lourie replied to the manager, with a copy to Villafaña, reporting that he had just spoken with Lefkowitz and agreed \"to two fed[eral] obstruction[] charges (24 month cap) with nonbinding recommendation for 18 months. When [Epstein] gets out, he has to plead to state offenses, including against minor, registrable, and then take one year house arrest/community confinement.\" By reply email, Villafaña asked Lourie to call her, but there is no record of whether they spoke.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "F. Defense Counsel Offers New Proposals Substantially Changing the Terms of the Federal Plea Agreement, which the USAO Rejects",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Approximately an hour after Lourie's email reporting the deal he had reached with Lefkowitz, Lefkowitz sent Villafaña a revised draft plea agreement. Despite the agreement Lourie believed he and Lefkowitz had reached that morning, Lefkowitz's proposal would have resulted in a 16-month federal sentence followed by 8 months of supervised release served in the form of home detention. Lefkowitz also inserted a statement in his proposal explicitly prohibiting the USAO from requesting, initiating, or encouraging immigration authorities to institute immigration proceedings against two of Epstein's female assistants.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Villafaña circulated the defense's proposed plea agreement to Lourie and two other supervisors, and expressed frustration that the new defense version incorporated terms that were \"completely different from what Jay just told Andy they would agree to.\" Villafaña also pointed out that the defense \"wants us to recommend an improper calculation\" of the sentencing guidelines",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "118 The manager told OPR that he probably meant this as a joke because in his view the continued back-and-forth communications with defense counsel \"was ridiculous,\" and the only way to \"get this deal done\" might be to have a direct conversation with Epstein.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "73",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein",
      "Jay Lefkowitz",
      "Lourie",
      "Villafaña",
      "Andy"
    ],
    "organizations": [
      "USAO",
      "OPR"
    ],
    "locations": [
      "West Palm Beach"
    ],
    "dates": [
      "04/16/21",
      "September 25"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "204-3"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Jeffrey Epstein. The text discusses plea negotiations and the terms of a potential agreement. The document is well-formatted and mostly free of errors or damage."
}