{
  "document_metadata": {
    "page_number": "142",
    "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 142 of 349\n\nfor up to 12 hours per day, six days per week, to work at the “Florida Science Foundation” office in West Palm Beach.182 In mid-November 2008, Villafaña learned that Epstein was on work release. She notified Acosta, Sloman, and the USAO Criminal Division Chief of this development in an email, and asked, “Can I indict him now?”\n\nOn November 24, 2008, Villafaña sent defense attorney Black a letter, notifying him that the USAO believed Epstein’s application to and participation in the work release program constituted a material breach of the NPA. Villafaña reminded Black that she had “more than a dozen e-mails” expressing the USAO’s “insistence” that Epstein be incarcerated for 18 months, and that her June 27, 2008 letter to counsel made clear that this meant “confinement for twenty-four hours a day.” Villafaña noted that Goldberger had not inserted the word “imprisoned” into the plea agreement, as he had agreed to do, but instead inserted the term “jail sentence.” Villafaña told counsel:\n\nThe [USAO’s] Agreement not to prosecute Mr. Epstein was based upon its determination that eighteen months’ incarceration (i.e., confinement twenty-four hours a day) was sufficient to satisfy the federal interest in Mr. Epstein’s crimes. Accordingly, the U.S. Attorney’s Office hereby gives notice that Mr. Epstein has violated the [NPA] by failing to remain incarcerated twenty-four hours a day for the eighteen-month term of imprisonment. The United States will exercise any and all rights it has under the [NPA] unless Mr. Epstein immediately ceases and desists from his breach of this agreement.\n\nAccording to Villafaña, the FBI case agent spoke with the Stockade’s work release coordinator and reported back that that the work release coordinator told her he had been led to believe the government knew Epstein had applied for the program, and that he had been threatened with legal action if he did not allow Epstein to participate in work release.\n\nOn November 26, 2008, the USAO advised the Department that Acosta was recused from all matters involving the law firm of Kirkland & Ellis, which was still heavily involved in the Epstein case, because Acosta was discussing with the firm the possibility of employment.183 As a result, Sloman became the senior USAO official responsible for making final decisions related to Epstein.\n\nAlso on November 26, 2008, Black responded to Villafaña’s letter, acknowledging that Epstein was serving his sentence in the Palm Beach County Work Release Program, but denying that Epstein was in breach of the NPA.184 Black noted that the NPA did not prohibit work release; the NPA expressly provided that Epstein was to be afforded the same benefits as any other inmate;\n\n182 Michele Dargan and David Rogers, “Palm Beach sex offender Jeffrey Epstein ‘treated differently,’” Palm Beach Daily News, Dec. 13, 2008.\n183 The recusal was formally approved by the Department on December 8, 2008.\n184 Black forwarded the email to Sloman, noting that Villafaña “is very concerned about anything Epstein does” and that the defense team would “abide by” Sloman’s decision on the issue.\n\n115\nDOJ-OGR-00004439",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 142 of 349",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "for up to 12 hours per day, six days per week, to work at the “Florida Science Foundation” office in West Palm Beach.182 In mid-November 2008, Villafaña learned that Epstein was on work release. She notified Acosta, Sloman, and the USAO Criminal Division Chief of this development in an email, and asked, “Can I indict him now?”",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "On November 24, 2008, Villafaña sent defense attorney Black a letter, notifying him that the USAO believed Epstein’s application to and participation in the work release program constituted a material breach of the NPA. Villafaña reminded Black that she had “more than a dozen e-mails” expressing the USAO’s “insistence” that Epstein be incarcerated for 18 months, and that her June 27, 2008 letter to counsel made clear that this meant “confinement for twenty-four hours a day.” Villafaña noted that Goldberger had not inserted the word “imprisoned” into the plea agreement, as he had agreed to do, but instead inserted the term “jail sentence.” Villafaña told counsel:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The [USAO’s] Agreement not to prosecute Mr. Epstein was based upon its determination that eighteen months’ incarceration (i.e., confinement twenty-four hours a day) was sufficient to satisfy the federal interest in Mr. Epstein’s crimes. Accordingly, the U.S. Attorney’s Office hereby gives notice that Mr. Epstein has violated the [NPA] by failing to remain incarcerated twenty-four hours a day for the eighteen-month term of imprisonment. The United States will exercise any and all rights it has under the [NPA] unless Mr. Epstein immediately ceases and desists from his breach of this agreement.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "According to Villafaña, the FBI case agent spoke with the Stockade’s work release coordinator and reported back that that the work release coordinator told her he had been led to believe the government knew Epstein had applied for the program, and that he had been threatened with legal action if he did not allow Epstein to participate in work release.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "On November 26, 2008, the USAO advised the Department that Acosta was recused from all matters involving the law firm of Kirkland & Ellis, which was still heavily involved in the Epstein case, because Acosta was discussing with the firm the possibility of employment.183 As a result, Sloman became the senior USAO official responsible for making final decisions related to Epstein.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Also on November 26, 2008, Black responded to Villafaña’s letter, acknowledging that Epstein was serving his sentence in the Palm Beach County Work Release Program, but denying that Epstein was in breach of the NPA.184 Black noted that the NPA did not prohibit work release; the NPA expressly provided that Epstein was to be afforded the same benefits as any other inmate;",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "182 Michele Dargan and David Rogers, “Palm Beach sex offender Jeffrey Epstein ‘treated differently,’” Palm Beach Daily News, Dec. 13, 2008.\n183 The recusal was formally approved by the Department on December 8, 2008.\n184 Black forwarded the email to Sloman, noting that Villafaña “is very concerned about anything Epstein does” and that the defense team would “abide by” Sloman’s decision on the issue.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "115",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004439",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Villafaña",
      "Epstein",
      "Acosta",
      "Sloman",
      "Black",
      "Goldberger",
      "Michele Dargan",
      "David Rogers"
    ],
    "organizations": [
      "USAO",
      "FBI",
      "Kirkland & Ellis",
      "Palm Beach Daily News",
      "Department"
    ],
    "locations": [
      "West Palm Beach",
      "Palm Beach",
      "Florida"
    ],
    "dates": [
      "November 24, 2008",
      "June 27, 2008",
      "November 26, 2008",
      "December 8, 2008",
      "December 13, 2008",
      "05/25/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 293-1",
      "DOJ-OGR-00004439"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the Jeffrey Epstein case. It includes details about Epstein's work release program and the USAO's response to it. The text is printed and there are no visible stamps or handwritten notes."
}