{
  "document_metadata": {
    "page_number": "133",
    "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 133 of 349\n\nappeal an adverse determination by him within the DOJ. Ken [Starr] and I appreciate that you understand this and have no objection to our seeking appellate review within DOJ.\n\nStarr, Lefkowitz, and Martin Weinberg attended the March 12, 2008 meeting, as well as the former Principal Deputy Chief of CEOS, who had joined the Epstein defense team. Oosterbaan, Mandelker, and a current CEOS Deputy Chief represented the Department. The current CEOS Deputy Chief told OPR that it was primarily a \"listening session\" with Starr doing most of the presentation. Oosterbaan told OPR that he recalled \"some back and forth\" because the defense team was saying \"some outrageous things.\" Both Oosterbaan and his Deputy Chief were disturbed that the former CEOS Principal Deputy Chief, who had been an aggressive advocate for child exploitation prosecutions, was supporting the defense position, although according to the CEOS Deputy Chief, the former Principal Deputy Chief gave only a \"weak pitch\" that was not effective.\n\nAfter the meeting, Starr and Lefkowitz made multiple written submissions to the Criminal Division. One submission provided a lengthy list of USAO actions that \"have caused us serious concern,\" including the following:\n\n\"Federal involvement in a state criminal prosecution without any communication with state authorities\";164\n\nthe issuance of legal process and document requests for items that \"had no connection to the conduct at issue\";\n\nthe nomination \"of an individual closely associated with one of the Assistant United States Attorneys involved in this case\" to serve as the victims' attorney representative;\n\nthe \"insistence\" on a victim notification letter inviting the victims to make sworn statements at Epstein's sentencing; and\n\nthe purported existence of a \"relationship\" between Sloman and a law firm representing several of the alleged victims in civil suits against Epstein.165\n\n164 This complaint appeared to be at odds with Villafaña's understanding that the defense objected to USAO communications with the state authorities. In November 2007, Sloman noted to Lefkowitz, \"Your recent correspondence attempting to restrict our Office from communicating with the State Attorney's Office . . . raises concern.\" In a March 2008 email reporting to CEOS about the state case, Villafaña noted that she did not know whether a state \"misdemeanor deal [was] back on the table because the defense demanded that we have no contact with the State Attorney's Office, so I haven't spoken with the [Assistant State Attorney] in over 6 months.\" Villafaña later reported to Acosta and Sloman that when Krischer complained to her that the USAO had not been communicating with him, she explained to Krischer that \"it was the defense who were blocking the channels of communication.\"\n\n165 In approximately 2001, Sloman briefly left the USAO and for a few months was in private practice with a Miami attorney, whose practice specialized in plaintiffs' sexual abuse claims. During 2007-2008, the attorney",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 133 of 349",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "appeal an adverse determination by him within the DOJ. Ken [Starr] and I appreciate that you understand this and have no objection to our seeking appellate review within DOJ.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Starr, Lefkowitz, and Martin Weinberg attended the March 12, 2008 meeting, as well as the former Principal Deputy Chief of CEOS, who had joined the Epstein defense team. Oosterbaan, Mandelker, and a current CEOS Deputy Chief represented the Department. The current CEOS Deputy Chief told OPR that it was primarily a \"listening session\" with Starr doing most of the presentation. Oosterbaan told OPR that he recalled \"some back and forth\" because the defense team was saying \"some outrageous things.\" Both Oosterbaan and his Deputy Chief were disturbed that the former CEOS Principal Deputy Chief, who had been an aggressive advocate for child exploitation prosecutions, was supporting the defense position, although according to the CEOS Deputy Chief, the former Principal Deputy Chief gave only a \"weak pitch\" that was not effective.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "After the meeting, Starr and Lefkowitz made multiple written submissions to the Criminal Division. One submission provided a lengthy list of USAO actions that \"have caused us serious concern,\" including the following:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "\"Federal involvement in a state criminal prosecution without any communication with state authorities\";164",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "the issuance of legal process and document requests for items that \"had no connection to the conduct at issue\";",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "the nomination \"of an individual closely associated with one of the Assistant United States Attorneys involved in this case\" to serve as the victims' attorney representative;",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "the \"insistence\" on a victim notification letter inviting the victims to make sworn statements at Epstein's sentencing; and",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "the purported existence of a \"relationship\" between Sloman and a law firm representing several of the alleged victims in civil suits against Epstein.165",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "164 This complaint appeared to be at odds with Villafaña's understanding that the defense objected to USAO communications with the state authorities. In November 2007, Sloman noted to Lefkowitz, \"Your recent correspondence attempting to restrict our Office from communicating with the State Attorney's Office . . . raises concern.\" In a March 2008 email reporting to CEOS about the state case, Villafaña noted that she did not know whether a state \"misdemeanor deal [was] back on the table because the defense demanded that we have no contact with the State Attorney's Office, so I haven't spoken with the [Assistant State Attorney] in over 6 months.\" Villafaña later reported to Acosta and Sloman that when Krischer complained to her that the USAO had not been communicating with him, she explained to Krischer that \"it was the defense who were blocking the channels of communication.\"",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "165 In approximately 2001, Sloman briefly left the USAO and for a few months was in private practice with a Miami attorney, whose practice specialized in plaintiffs' sexual abuse claims. During 2007-2008, the attorney",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004430",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ken Starr",
      "Lefkowitz",
      "Martin Weinberg",
      "Oosterbaan",
      "Mandelker",
      "Villafaña",
      "Sloman",
      "Acosta",
      "Krischer",
      "Epstein"
    ],
    "organizations": [
      "DOJ",
      "CEOS",
      "USAO",
      "Criminal Division",
      "State Attorney's Office"
    ],
    "locations": [
      "Miami"
    ],
    "dates": [
      "March 12, 2008",
      "November 2007",
      "March 2008",
      "2001",
      "2007-2008",
      "05/25/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 293-1",
      "Page 133 of 349"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the Epstein case, discussing interactions between the USAO and the defense team, as well as concerns raised by Starr and Lefkowitz regarding USAO actions."
}