{
  "document_metadata": {
    "page_number": "98 of 349",
    "document_number": "293-1",
    "date": "05/25/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 98 of 349\n\nfor them to be deported.\"114 As to whether the foreign nationals would be removable by virtue of having committed crimes, Villafaña told OPR she did not consider her role as seeking removal apart from actual prosecution.\n\nVillafaña concluded her email to Lefkowitz by expressing disappointment that they were not \"closer to resolving this than it appears that we are,\" and offering to meet the next day to work on the agreement:\n\nCan I suggest that tomorrow we either meet live or via teleconference, either with your client or having him within a quick phone call, to hash out these items? I was hoping to work only a half day tomorrow to save my voice for Tuesday's hearing . . . , if necessary, but maybe we can set a time to meet. If you want to meet \"off campus\" somewhere, that is fine. I will make sure that I have all the necessary decision makers present or \"on call,\" as well.115\n\nVillafaña told OPR that she offered to meet Lefkowitz away from the USAO because conducting negotiations via email was inefficient, and Villafaña wanted \"to have a meeting where we sat down and just finalized things. And what I meant by off campus is, sometimes people feel better if you go to a neutral location\" for a face-to-face meeting.\n\nOn the morning of Monday, September 17, 2007, the USAO supervisor who was taking over Lourie's duties as manager of the West Palm Beach office asked Villafaña for an update on the plea negotiations, and she forwarded to him the email she had sent to Lefkowitz the previous afternoon. Villafaña told the manager, \"As you can see . . . there are a number of things in their last draft that were unacceptable. All of the loopholes that I sewed up they tried to open.\"\n\nShortly thereafter, Villafaña alerted the new manager, Acosta, and Lourie that she had just spoken with Lefkowitz, who advised that Epstein was leaning towards a plea to state charges under a non-prosecution agreement, and she would be forwarding to Lefkowitz \"our last version of the Non-Prosecution Agreement.\" Acosta asked that Villafaña \"make sure they know it[']s only a draft\" and reminded her that \"[t]he form and language may need polishing.\" Villafaña responded, \"Absolutely. There were a lot of problems with their last attempt. They tried to re-open all the loopholes that I had sewn shut.\" Villafaña sent to Lefkowitz the draft NPA that she had provided to Lefcourt on September 11, 2007, noting that it was the \"last version\" and would \"avoid [him] having to reinvent the wheel.\" She also updated the FBI case agents on the status of negotiations, noting that she had told her \"chain of command . . . that we are still on for the [September] 25th [to bring charges] . . . , no matter what.\"\n\nAfter receiving the draft NPA, Lefkowitz asked Villafaña to provide for his review a factual proffer for a federal obstruction of justice charge, and, with respect to the NPA option, asked, \"[I]f\n\n114 According to the case agents, the West Palm Beach FBI office had an ICE agent working with them at the beginning of the federal investigation, and the ICE agent normally would have looked into the immigration status of any foreign national, but neither case agent recalled any immigration issue regarding any of the Epstein employees.\n\n115 Lefkowitz was based in New York City but traveled to Miami in connection with the case.",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 98 of 349",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "for them to be deported.\"114 As to whether the foreign nationals would be removable by virtue of having committed crimes, Villafaña told OPR she did not consider her role as seeking removal apart from actual prosecution.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Villafaña concluded her email to Lefkowitz by expressing disappointment that they were not \"closer to resolving this than it appears that we are,\" and offering to meet the next day to work on the agreement:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Can I suggest that tomorrow we either meet live or via teleconference, either with your client or having him within a quick phone call, to hash out these items? I was hoping to work only a half day tomorrow to save my voice for Tuesday's hearing . . . , if necessary, but maybe we can set a time to meet. If you want to meet \"off campus\" somewhere, that is fine. I will make sure that I have all the necessary decision makers present or \"on call,\" as well.115",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Villafaña told OPR that she offered to meet Lefkowitz away from the USAO because conducting negotiations via email was inefficient, and Villafaña wanted \"to have a meeting where we sat down and just finalized things. And what I meant by off campus is, sometimes people feel better if you go to a neutral location\" for a face-to-face meeting.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "On the morning of Monday, September 17, 2007, the USAO supervisor who was taking over Lourie's duties as manager of the West Palm Beach office asked Villafaña for an update on the plea negotiations, and she forwarded to him the email she had sent to Lefkowitz the previous afternoon. Villafaña told the manager, \"As you can see . . . there are a number of things in their last draft that were unacceptable. All of the loopholes that I sewed up they tried to open.\"",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Shortly thereafter, Villafaña alerted the new manager, Acosta, and Lourie that she had just spoken with Lefkowitz, who advised that Epstein was leaning towards a plea to state charges under a non-prosecution agreement, and she would be forwarding to Lefkowitz \"our last version of the Non-Prosecution Agreement.\" Acosta asked that Villafaña \"make sure they know it[']s only a draft\" and reminded her that \"[t]he form and language may need polishing.\" Villafaña responded, \"Absolutely. There were a lot of problems with their last attempt. They tried to re-open all the loopholes that I had sewn shut.\" Villafaña sent to Lefkowitz the draft NPA that she had provided to Lefcourt on September 11, 2007, noting that it was the \"last version\" and would \"avoid [him] having to reinvent the wheel.\" She also updated the FBI case agents on the status of negotiations, noting that she had told her \"chain of command . . . that we are still on for the [September] 25th [to bring charges] . . . , no matter what.\"",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "After receiving the draft NPA, Lefkowitz asked Villafaña to provide for his review a factual proffer for a federal obstruction of justice charge, and, with respect to the NPA option, asked, \"[I]f",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "114 According to the case agents, the West Palm Beach FBI office had an ICE agent working with them at the beginning of the federal investigation, and the ICE agent normally would have looked into the immigration status of any foreign national, but neither case agent recalled any immigration issue regarding any of the Epstein employees.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "115 Lefkowitz was based in New York City but traveled to Miami in connection with the case.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "71",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004395",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Villafaña",
      "Lefkowitz",
      "Lourie",
      "Acosta",
      "Epstein"
    ],
    "organizations": [
      "USAO",
      "FBI",
      "ICE",
      "OPR"
    ],
    "locations": [
      "West Palm Beach",
      "New York City",
      "Miami"
    ],
    "dates": [
      "September 17, 2007",
      "September 11, 2007",
      "September 25",
      "05/25/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 293-1"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the Epstein case. The text is mostly printed, with no handwritten content or stamps visible. The document is well-formatted and legible."
}