{
  "document_metadata": {
    "page_number": "128",
    "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 128 of 348\nthat it was to establish whether, if the plea fell apart, he, as Chief, would agree \"that we can go forward with\" the charges. He did recall being concerned, after completing the review, that \"we did not have . . . a lot of victims . . . lined up and ready to testify\" and that some victims might \"not be favorable for us.\" Nevertheless, he concluded that the proposed charges were sound, and he told Acosta that he would approve proceeding with a federal case.\n6. Acosta Asks CEOS to Review the Evidence\nNotwithstanding Senior's favorable review, Acosta and Sloman told Starr and Lefkowitz that they \"appreciate[d]\" that the defense wanted a \"fresh face\" to conduct a review, and noted that the Criminal Chief had not undertaken the \"in-depth work associated with the issues raised by the defense.\" They told the defense team that Acosta had asked CEOS to \"come on board\" and that CEOS Chief Oosterbaan would designate an attorney having \"a national perspective\" to conduct a fresh review in light of the defense submissions. Oosterbaan assigned a CEOS Trial Attorney who Villafaña understood was to review the case and prepare for trial in the event Epstein did not \"consummate\" the NPA. The CEOS Trial Attorney traveled to Florida to review the case materials, and to meet with Villafaña to discuss the case and interview some of the victims. After one such meeting, Villafaña wrote to Acosta and Sloman:\nWe just finished interviewing three of the girls. I wish you could have been there to see how much this has affected them.\nOne girl broke down sobbing so that we had to stop the interview twice within a 20 minute span. She regained her composure enough to continue a short time, but she said that she was having nightmares about Epstein coming after her and she started to break down again, so we stopped the interview.\nThe second girl . . . told us that she was very upset about the 18 month deal she had read about in the paper. She said that 18 months was nothing and that she had heard that the girls could get restitution, but she would rather not get any money and have Epstein spend a significant time in jail.\n. . .\nThese girls deserve so much better than they have received so far, and I hate feeling that there is nothing I can do to help them.161\nThe CEOS Trial Attorney had substantial experience prosecuting child exploitation cases. She told OPR that in her view, the victim witnesses in this case presented a number of challenges for a prosecution: some of the victims did not want to admit they had sexual contact with Epstein; some had recruited other victims to provide Epstein massages, and thus could have been charged as accomplices; some had \"drug histories and . . . things like that\"; some could appear to have been \"complicit\"; and there was no evidence of physical violence against the victims. She did not regard\n161 Villafaña added, \"We have four more girls coming in tomorrow. Can I persuade you to attend?\"\n102\nDOJ-OGR-00003304",
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      "content": "Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 128 of 348",
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    {
      "type": "printed",
      "content": "that it was to establish whether, if the plea fell apart, he, as Chief, would agree \"that we can go forward with\" the charges. He did recall being concerned, after completing the review, that \"we did not have . . . a lot of victims . . . lined up and ready to testify\" and that some victims might \"not be favorable for us.\" Nevertheless, he concluded that the proposed charges were sound, and he told Acosta that he would approve proceeding with a federal case.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "6. Acosta Asks CEOS to Review the Evidence",
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    },
    {
      "type": "printed",
      "content": "Notwithstanding Senior's favorable review, Acosta and Sloman told Starr and Lefkowitz that they \"appreciate[d]\" that the defense wanted a \"fresh face\" to conduct a review, and noted that the Criminal Chief had not undertaken the \"in-depth work associated with the issues raised by the defense.\" They told the defense team that Acosta had asked CEOS to \"come on board\" and that CEOS Chief Oosterbaan would designate an attorney having \"a national perspective\" to conduct a fresh review in light of the defense submissions. Oosterbaan assigned a CEOS Trial Attorney who Villafaña understood was to review the case and prepare for trial in the event Epstein did not \"consummate\" the NPA. The CEOS Trial Attorney traveled to Florida to review the case materials, and to meet with Villafaña to discuss the case and interview some of the victims. After one such meeting, Villafaña wrote to Acosta and Sloman:",
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    {
      "type": "printed",
      "content": "We just finished interviewing three of the girls. I wish you could have been there to see how much this has affected them.\nOne girl broke down sobbing so that we had to stop the interview twice within a 20 minute span. She regained her composure enough to continue a short time, but she said that she was having nightmares about Epstein coming after her and she started to break down again, so we stopped the interview.\nThe second girl . . . told us that she was very upset about the 18 month deal she had read about in the paper. She said that 18 months was nothing and that she had heard that the girls could get restitution, but she would rather not get any money and have Epstein spend a significant time in jail.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "These girls deserve so much better than they have received so far, and I hate feeling that there is nothing I can do to help them.161",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The CEOS Trial Attorney had substantial experience prosecuting child exploitation cases. She told OPR that in her view, the victim witnesses in this case presented a number of challenges for a prosecution: some of the victims did not want to admit they had sexual contact with Epstein; some had recruited other victims to provide Epstein massages, and thus could have been charged as accomplices; some had \"drug histories and . . . things like that\"; some could appear to have been \"complicit\"; and there was no evidence of physical violence against the victims. She did not regard",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "161 Villafaña added, \"We have four more girls coming in tomorrow. Can I persuade you to attend?\"",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "102",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003304",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Acosta",
      "Sloman",
      "Starr",
      "Lefkowitz",
      "Oosterbaan",
      "Villafaña",
      "Epstein"
    ],
    "organizations": [
      "CEOS",
      "OPR"
    ],
    "locations": [
      "Florida"
    ],
    "dates": [
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "204-3",
      "DOJ-OGR-00003304"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case against Jeffrey Epstein. The text discusses the review of evidence and the challenges of prosecuting child exploitation cases. The document is well-formatted and legible."
}