{
  "document_metadata": {
    "page_number": "104",
    "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 104 of 348\n\nI. The Defense Rejects the Federal Plea Agreement, Returns to the NPA \"State-Only\" Resolution, and Begins Opposing the Sexual Offender Registration Requirement\n\nAfter having spent days negotiating the federal charges to be included in a plea agreement, by the afternoon of September 20, 2007, the defense rejected the federal plea option, and the parties resumed negotiations over the details of an NPA calling for Epstein to plead to only state charges. Through multiple emails and attempts (some successful) to speak directly with Acosta and other supervisors, defense attorneys vigorously fought the USAO's insistence that Epstein plead to a state charge requiring sexual offender registration.\n\nAfter receiving the federal plea agreement, Lefkowitz spoke with Villafaña. She reported to Acosta and Lourie that Lefkowitz told her the defense was \"back to doing the state-charges-only agreement\" and wanted until the middle of the following week to work out the details, but that she had told defense counsel that \"we need a signed agreement by tomorrow [Friday] or we are [filing charges] on Tuesday.\"\n\nLefkowitz emailed Villafaña about the draft NPA that she had sent to him, pointing out that it called for a 20-month jail sentence followed by 10 months of community control, rather than 18 months in jail and 12 under community control, and to ask if the USAO had \"any flexibility\" on the § 2255 procedure. Villafaña responded:\n\nThe 18 and 12 has already been agreed to by our office, so that is not a problem. On the issue about 18 [U.S.C. §] 2255, we seem to be miles apart. Your most recent version not only had me binding the girls to a trust fund administered by the state court, but also promising that they will give up their [§] 2255 rights.\n\nI reviewed the e-mail that I sent you on Sunday with the comments on some of your other changes. In the context of a non-prosecution agreement, the office may be more willing to be specific about not pursuing charges against others. However, as I stated on Sunday, the Office cannot and will not bind Immigration.\n\nAlso, your timetable will need to move up significantly. As [State Attorney] Barry [Krischer] said in our meeting last week, his office can put together a plea agreement, [and an] information, and get you all before the [state] judge on a change of plea within a day.\n\nVillafaña alerted Krischer that evening that negotiations were \"not going very well\" and that defense counsel \"changed their minds again, and they only want to plead to state charges, not concurrent state and federal.\" She added, \"If we cannot reach . . . an agreement, then I need to [charge] the case on Tuesday [September 25] and I will not budge from that date.\"\n\nIn response to Villafaña's report of her conversation with Lefkowitz about the defense preference for a \"state-charges-only agreement,\" Lourie alerted her that, \"He wants to get out of [sexual offender] registration which we should not agree to.\" Lourie emailed Acosta:\n\n78\n\nDOJ-OGR-00003280",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 104 of 348",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "I. The Defense Rejects the Federal Plea Agreement, Returns to the NPA \"State-Only\" Resolution, and Begins Opposing the Sexual Offender Registration Requirement",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "After having spent days negotiating the federal charges to be included in a plea agreement, by the afternoon of September 20, 2007, the defense rejected the federal plea option, and the parties resumed negotiations over the details of an NPA calling for Epstein to plead to only state charges. Through multiple emails and attempts (some successful) to speak directly with Acosta and other supervisors, defense attorneys vigorously fought the USAO's insistence that Epstein plead to a state charge requiring sexual offender registration.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "After receiving the federal plea agreement, Lefkowitz spoke with Villafaña. She reported to Acosta and Lourie that Lefkowitz told her the defense was \"back to doing the state-charges-only agreement\" and wanted until the middle of the following week to work out the details, but that she had told defense counsel that \"we need a signed agreement by tomorrow [Friday] or we are [filing charges] on Tuesday.\"",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Lefkowitz emailed Villafaña about the draft NPA that she had sent to him, pointing out that it called for a 20-month jail sentence followed by 10 months of community control, rather than 18 months in jail and 12 under community control, and to ask if the USAO had \"any flexibility\" on the § 2255 procedure. Villafaña responded:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The 18 and 12 has already been agreed to by our office, so that is not a problem. On the issue about 18 [U.S.C. §] 2255, we seem to be miles apart. Your most recent version not only had me binding the girls to a trust fund administered by the state court, but also promising that they will give up their [§] 2255 rights.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "I reviewed the e-mail that I sent you on Sunday with the comments on some of your other changes. In the context of a non-prosecution agreement, the office may be more willing to be specific about not pursuing charges against others. However, as I stated on Sunday, the Office cannot and will not bind Immigration.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Also, your timetable will need to move up significantly. As [State Attorney] Barry [Krischer] said in our meeting last week, his office can put together a plea agreement, [and an] information, and get you all before the [state] judge on a change of plea within a day.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Villafaña alerted Krischer that evening that negotiations were \"not going very well\" and that defense counsel \"changed their minds again, and they only want to plead to state charges, not concurrent state and federal.\" She added, \"If we cannot reach . . . an agreement, then I need to [charge] the case on Tuesday [September 25] and I will not budge from that date.\"",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In response to Villafaña's report of her conversation with Lefkowitz about the defense preference for a \"state-charges-only agreement,\" Lourie alerted her that, \"He wants to get out of [sexual offender] registration which we should not agree to.\" Lourie emailed Acosta:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "78",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003280",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Acosta",
      "Lefkowitz",
      "Villafaña",
      "Lourie",
      "Epstein",
      "Krischer",
      "Barry"
    ],
    "organizations": [
      "USAO",
      "Office",
      "Immigration"
    ],
    "locations": [],
    "dates": [
      "September 20, 2007",
      "Sunday",
      "Friday",
      "Tuesday",
      "September 25"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "204-3",
      "DOJ-OGR-00003280"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Jeffrey Epstein. It discusses negotiations between the defense and prosecution regarding a plea agreement and the details of a non-prosecution agreement (NPA). The document is well-formatted and mostly free of errors or damage."
}