{
  "document_metadata": {
    "page_number": "100",
    "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 100 of 348\n\nand had added language waiving the preparation of a presentence investigation (PSI) \"so he can keep all of his information confidential. I have already told Jay that the PSI language . . . was unacceptable to our office.\" Of even greater significance, in a follow-up email, Villafaña noted that the defense had removed both the requirement that Epstein plead to a registrable offense and the entire provision relating to monetary damages under 18 U.S.C. § 2255.\n\nIn the afternoon, Villafaña circulated her own proposed \"hybrid\" plea agreement, first internally to the management team with a note stating that it \"contains the 18/12 split that Jay and Andy agreed to,\" and then to Lefkowitz. Regarding the prosecution of other individuals, she included the following provision: \"This agreement resolves the federal criminal liability of the defendant and any co-conspirators in the Southern District of Florida growing out of any criminal conduct by those persons known to the [USAO] as of the date of this plea agreement,\" including but not limited to the conspiracy to solicit minors to engage in prostitution.\n\nIn her email to Lefkowitz, transmitting the plea agreement, Villafaña wrote:\n\nCould you share the attached draft with your colleagues. It is in keeping with what Andy communicated to me was the operative \"deal.\" The U.S. Attorney hasn't had a chance to review all of the language, but he agrees with it in principle.\n\n[The West Palm Beach manager] and I will both be available at 2:00. One of my suggestions is going to be (again) that we all sit down together in the same room, including Barry [Krischer] and/or Lanna [Belohlavek], so we can hash out the still existing issues and get a signed document.\n\nVillafaña also emailed Acosta directly, telling him she planned to meet with Epstein's attorneys to work on the plea agreement, and asking if Acosta would be available to provide final approval. Acosta replied, \"I don't think I should be part of negotiations. I'd rather leave it to you if that's ok.\" Acosta told OPR that \"absent truly exceptional circumstances,\" he believed it was important for him \"to not get involved\" in negotiations, and added, \"You can meet, like I did in September, [to] reaffirm the position of the office, [and] back your AUSA, but ultimately, I think your trial lawyer needs discretion to do their job.\" Villafaña told OPR, however, that she did not understand Acosta to be giving her discretion to conduct the negotiations as she saw fit; rather, she believed Acosta did not want to engage in face-to-face negotiations because \"he wanted to have an appearance of having sort of an arm's length from the deal.\"119 Villafaña replied to Acosta's\n\n119 As noted throughout the Report, Villafaña's interpretation of her supervisors' motivations for their actions often differed from the supervisors' explanations for their actions. Because it involves subjective interpretations of individuals' motivations, OPR does not reach conclusions regarding the subjects' differing views but includes them as an indication of the communication issues that hindered the prosecution team. See Chapter Two, Part Three, Section V.E.\n\n74\nDOJ-OGR-00003276",
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    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 100 of 348",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "and had added language waiving the preparation of a presentence investigation (PSI) \"so he can keep all of his information confidential. I have already told Jay that the PSI language . . . was unacceptable to our office.\" Of even greater significance, in a follow-up email, Villafaña noted that the defense had removed both the requirement that Epstein plead to a registrable offense and the entire provision relating to monetary damages under 18 U.S.C. § 2255.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "In the afternoon, Villafaña circulated her own proposed \"hybrid\" plea agreement, first internally to the management team with a note stating that it \"contains the 18/12 split that Jay and Andy agreed to,\" and then to Lefkowitz. Regarding the prosecution of other individuals, she included the following provision: \"This agreement resolves the federal criminal liability of the defendant and any co-conspirators in the Southern District of Florida growing out of any criminal conduct by those persons known to the [USAO] as of the date of this plea agreement,\" including but not limited to the conspiracy to solicit minors to engage in prostitution.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In her email to Lefkowitz, transmitting the plea agreement, Villafaña wrote:\n\nCould you share the attached draft with your colleagues. It is in keeping with what Andy communicated to me was the operative \"deal.\" The U.S. Attorney hasn't had a chance to review all of the language, but he agrees with it in principle.\n\n[The West Palm Beach manager] and I will both be available at 2:00. One of my suggestions is going to be (again) that we all sit down together in the same room, including Barry [Krischer] and/or Lanna [Belohlavek], so we can hash out the still existing issues and get a signed document.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Villafaña also emailed Acosta directly, telling him she planned to meet with Epstein's attorneys to work on the plea agreement, and asking if Acosta would be available to provide final approval. Acosta replied, \"I don't think I should be part of negotiations. I'd rather leave it to you if that's ok.\" Acosta told OPR that \"absent truly exceptional circumstances,\" he believed it was important for him \"to not get involved\" in negotiations, and added, \"You can meet, like I did in September, [to] reaffirm the position of the office, [and] back your AUSA, but ultimately, I think your trial lawyer needs discretion to do their job.\" Villafaña told OPR, however, that she did not understand Acosta to be giving her discretion to conduct the negotiations as she saw fit; rather, she believed Acosta did not want to engage in face-to-face negotiations because \"he wanted to have an appearance of having sort of an arm's length from the deal.\"119 Villafaña replied to Acosta's",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "119 As noted throughout the Report, Villafaña's interpretation of her supervisors' motivations for their actions often differed from the supervisors' explanations for their actions. Because it involves subjective interpretations of individuals' motivations, OPR does not reach conclusions regarding the subjects' differing views but includes them as an indication of the communication issues that hindered the prosecution team. See Chapter Two, Part Three, Section V.E.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "74",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003276",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Villafaña",
      "Jay",
      "Andy",
      "Lefkowitz",
      "Acosta",
      "Epstein",
      "Barry Krischer",
      "Lanna Belohlavek"
    ],
    "organizations": [
      "USAO",
      "OPR",
      "DOJ"
    ],
    "locations": [
      "Southern District of Florida",
      "West Palm Beach"
    ],
    "dates": [
      "04/16/21",
      "September"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204-3",
      "DOJ-OGR-00003276"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Jeffrey Epstein. It includes details about plea agreements and communications between various individuals involved in the case. The text is mostly printed, with no handwritten content or stamps visible."
}