{
  "document_metadata": {
    "page_number": "118",
    "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 118 of 348\n\nOn October 22, 2007, Sloman responded to the issues Lefkowitz had raised, rejecting some defense proposals but agreeing to modify certain language in the proposed addendum to \"satisfy your concern.\"146 Noting that the addendum and a revised letter to the special master were attached, Sloman ended by stating, \"[T]his needs to be concluded. Alex and I believe that this is as far as we can go. Therefore, please advise me whether we have a deal no later than COB tomorrow . . . .\"\n\nNonetheless, the next day, Lefkowitz sent Acosta a three-page letter reiterating the Epstein team's disagreements with the USAO's interpretation of the NPA. Lefkowitz noted, however, that Epstein had \"every intention of honoring the terms of [the NPA] in good faith,\" and that \"the defense letter was not intended to be \"a rescission or withdrawal from the terms of the [NPA].\" Lefkowitz added:\n\nI also want to thank you for the commitment you made to me during our October 12 meeting in which you promised genuine finality with regard to this matter, and assured me that your Office would not intervene with the State Attorney's Office regarding this matter; or contact any of the identified individuals, potential witnesses, or potential civil claimants and their respective counsel in this matter; and that neither your Office nor the [FBI] would intervene regarding the sentence Mr. Epstein receives pursuant to a plea with the State, so long as that sentence does not violate state law. Indeed, so long as Mr. Epstein's sentence does not explicitly violate the terms of the Agreement, he is entitled to any type of sentence available to him, including but not limited to gain time and work release.\n\nSloman forwarded the letter to Villafaña, commenting, \"Wait [until] you see this one.\" Villafaña replied:\n\nWelcome to my world. I love the way that they want to interpret this agreement.\n\n. . .\n\nIt also looks like they are planning to ask for and receive a sentence far lower than the one we agreed to. Has anyone talked to Barry [Krischer] about this? Maybe this is the real reason for the delay in entering the guilty plea? We also have to contact the victims to tell [them] about the outcome of the case and to advise them than an attorney will be contacting them regarding possible claims against Mr. Epstein. If we don't do that, it may be a violation of the Florida Bar Rules for the selected attorney to \"cold call\" the girls.\n\n146 The defense raised issues concerning the attorney representative, the statutory limit on damages, and inclusion of certain victims.\n\n92\n\nDOJ-OGR-00003294",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 118 of 348",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "On October 22, 2007, Sloman responded to the issues Lefkowitz had raised, rejecting some defense proposals but agreeing to modify certain language in the proposed addendum to \"satisfy your concern.\"146 Noting that the addendum and a revised letter to the special master were attached, Sloman ended by stating, \"[T]his needs to be concluded. Alex and I believe that this is as far as we can go. Therefore, please advise me whether we have a deal no later than COB tomorrow . . . .\"",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Nonetheless, the next day, Lefkowitz sent Acosta a three-page letter reiterating the Epstein team's disagreements with the USAO's interpretation of the NPA. Lefkowitz noted, however, that Epstein had \"every intention of honoring the terms of [the NPA] in good faith,\" and that \"the defense letter was not intended to be \"a rescission or withdrawal from the terms of the [NPA].\" Lefkowitz added:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "I also want to thank you for the commitment you made to me during our October 12 meeting in which you promised genuine finality with regard to this matter, and assured me that your Office would not intervene with the State Attorney's Office regarding this matter; or contact any of the identified individuals, potential witnesses, or potential civil claimants and their respective counsel in this matter; and that neither your Office nor the [FBI] would intervene regarding the sentence Mr. Epstein receives pursuant to a plea with the State, so long as that sentence does not violate state law. Indeed, so long as Mr. Epstein's sentence does not explicitly violate the terms of the Agreement, he is entitled to any type of sentence available to him, including but not limited to gain time and work release.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Sloman forwarded the letter to Villafaña, commenting, \"Wait [until] you see this one.\" Villafaña replied:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Welcome to my world. I love the way that they want to interpret this agreement.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": ". . .",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "It also looks like they are planning to ask for and receive a sentence far lower than the one we agreed to. Has anyone talked to Barry [Krischer] about this? Maybe this is the real reason for the delay in entering the guilty plea? We also have to contact the victims to tell [them] about the outcome of the case and to advise them than an attorney will be contacting them regarding possible claims against Mr. Epstein. If we don't do that, it may be a violation of the Florida Bar Rules for the selected attorney to \"cold call\" the girls.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "146 The defense raised issues concerning the attorney representative, the statutory limit on damages, and inclusion of certain victims.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "92",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003294",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Sloman",
      "Lefkowitz",
      "Acosta",
      "Epstein",
      "Alex",
      "Villafaña",
      "Barry Krischer"
    ],
    "organizations": [
      "USAO",
      "FBI",
      "State Attorney's Office"
    ],
    "locations": [
      "Florida"
    ],
    "dates": [
      "October 22, 2007",
      "October 12, 2007",
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "204-3",
      "DOJ-OGR-00003294"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Jeffrey Epstein. The text discusses the negotiations between Epstein's defense team and the USAO regarding a non-prosecution agreement (NPA). The document includes quotes from emails and letters exchanged between the parties. The tone of the document is formal and professional."
}