{
  "document_metadata": {
    "page_number": "60",
    "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 60 of 348\n\nOn that same day, Villafaña emailed Lourie, Menchel, Sloman, and her immediate supervisor complaining that she had received no reply to her query about making changes to the proposed indictment and asking again for feedback. During his OPR interview, Lourie observed that Villafaña's request for feedback reflected her desire to \"charge this case sooner than . . . everybody else,\" but Acosta was still considering what strategy to pursue. Sloman told OPR that he did not know whether Villafaña received any response to her request, but he believed that at that point in time, Menchel and Lourie were evaluating the case to make a decision about how to proceed.\n\nThe day before the June 26 meeting, defense counsel Lefcourt transmitted to the USAO a 19-page letter intended to provide \"an overview of our position and the materials we plan to present in order to demonstrate that none of the statutes identified by you can rightly be applied to the conduct at issue here.\" Reiterating their prior arguments and themes, defense counsel strongly contested the appropriateness of federal involvement in the matter. Among other issues, Lefcourt's letter argued:\n\n- Voluntary sexual activity involving \"young adults–16 or 17 years of age\"–was \"strictly a state concern.\"\n- Federal statutes were not meant to apply to circumstances in which the defendant reasonably believed that the person with whom he engaged in sexual activity was 18 years of age.\n- One of the chief statutes the USAO had focused upon, 18 U.S.C. § 2422(b), was intended to address use of the internet to prey upon child victims through \"internet trolling,\" but Epstein did not use the internet to lure victims.\n- The \"travel\" statute, 18 U.S.C. § 2423(b), prohibits travel \"for the purpose of\" engaging in illicit sexual conduct, but Epstein traveled to Florida to visit family, oversee his Florida-based flight operations, and \"engage in the routine activities of daily living.\"\n\nLefcourt also argued that \"irregularities\" had tainted the state's case and would \"have a significant impact on any federal prosecution.\"52\n\nLourie sent to Menchel, with a copy to Villafaña, an email dividing the defense arguments into \"weaker\" and \"stronger\" points. Lourie disagreed with the argument that 18 U.S.C. § 2422(b) was limited to \"internet trolling,\" and described this as \"our best charge and the most defensible for federal interest.\" On the other hand, Lourie believed the defense argument that Epstein did not travel to Florida \"'with the purpose'\" of engaging in illicit sex with a minor was more persuasive.\n\nLefcourt, he told OPR that he \"wouldn't take issue\" with Villafaña's claim that he had done so. Menchel also told OPR that he did not recall Villafaña objecting at that point to providing the information to the defense.\n\n52 Lefcourt claimed there were deficiencies in the PBPD search warrant and \"material misstatements and omissions\" in the PBPD probable cause affidavit. As an example, he contended that the police had lacked probable cause to search for videotapes, \"since all the women who were asked whether they had been videotaped denied knowledge of any videotaping.\" (Emphasis in original).\n\n34\n\nDOJ-OGR-00003236",
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      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 60 of 348",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "On that same day, Villafaña emailed Lourie, Menchel, Sloman, and her immediate supervisor complaining that she had received no reply to her query about making changes to the proposed indictment and asking again for feedback. During his OPR interview, Lourie observed that Villafaña's request for feedback reflected her desire to \"charge this case sooner than . . . everybody else,\" but Acosta was still considering what strategy to pursue. Sloman told OPR that he did not know whether Villafaña received any response to her request, but he believed that at that point in time, Menchel and Lourie were evaluating the case to make a decision about how to proceed.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The day before the June 26 meeting, defense counsel Lefcourt transmitted to the USAO a 19-page letter intended to provide \"an overview of our position and the materials we plan to present in order to demonstrate that none of the statutes identified by you can rightly be applied to the conduct at issue here.\" Reiterating their prior arguments and themes, defense counsel strongly contested the appropriateness of federal involvement in the matter. Among other issues, Lefcourt's letter argued:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "- Voluntary sexual activity involving \"young adults–16 or 17 years of age\"–was \"strictly a state concern.\"\n- Federal statutes were not meant to apply to circumstances in which the defendant reasonably believed that the person with whom he engaged in sexual activity was 18 years of age.\n- One of the chief statutes the USAO had focused upon, 18 U.S.C. § 2422(b), was intended to address use of the internet to prey upon child victims through \"internet trolling,\" but Epstein did not use the internet to lure victims.\n- The \"travel\" statute, 18 U.S.C. § 2423(b), prohibits travel \"for the purpose of\" engaging in illicit sexual conduct, but Epstein traveled to Florida to visit family, oversee his Florida-based flight operations, and \"engage in the routine activities of daily living.\"",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Lefcourt also argued that \"irregularities\" had tainted the state's case and would \"have a significant impact on any federal prosecution.\"52",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Lourie sent to Menchel, with a copy to Villafaña, an email dividing the defense arguments into \"weaker\" and \"stronger\" points. Lourie disagreed with the argument that 18 U.S.C. § 2422(b) was limited to \"internet trolling,\" and described this as \"our best charge and the most defensible for federal interest.\" On the other hand, Lourie believed the defense argument that Epstein did not travel to Florida \"'with the purpose'\" of engaging in illicit sex with a minor was more persuasive.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Lefcourt, he told OPR that he \"wouldn't take issue\" with Villafaña's claim that he had done so. Menchel also told OPR that he did not recall Villafaña objecting at that point to providing the information to the defense.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "52 Lefcourt claimed there were deficiencies in the PBPD search warrant and \"material misstatements and omissions\" in the PBPD probable cause affidavit. As an example, he contended that the police had lacked probable cause to search for videotapes, \"since all the women who were asked whether they had been videotaped denied knowledge of any videotaping.\" (Emphasis in original).",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "34",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003236",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Villafaña",
      "Lourie",
      "Menchel",
      "Sloman",
      "Acosta",
      "Lefcourt",
      "Epstein"
    ],
    "organizations": [
      "USAO",
      "PBPD",
      "OPR"
    ],
    "locations": [
      "Florida"
    ],
    "dates": [
      "04/16/21",
      "June 26"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204-3",
      "DOJ-OGR-00003236"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case against Jeffrey Epstein. It discusses the arguments made by the defense and the prosecution, as well as the evaluation of the case by various individuals involved. The document is well-formatted and mostly free of errors or damage."
}