{
  "document_metadata": {
    "page_number": "38",
    "document_number": "204",
    "date": "04/16/21",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 38 of 239\n\nwould not, without more, establish that the USAO-SDFL intended to bind other districts, much less that the USAO-SDFL communicated a promise to Epstein that the NPA would extend beyond the USAO-SDFL. The defendant's failure to offer any evidence is fatal to her claim.\n\nAlthough it is not the Government's burden to address and rebut every innuendo or conclusory statement in the defendant's motion, it is significant here that the circumstances of the NPA have been extensively litigated in a civil lawsuit, and have also been investigated by the Department of Justice's Office of Professional Responsibility (\"OPR\"), resulting in a report of OPR's findings (the \"OPR Report\").6 The records of both matters provide no support for the defendant's claims.\n\nThe OPR Report notes that the USAO-SDFL periodically consulted with the Chief of the Department of Justice Child Exploitation and Obscenity Section (\"CEOS\"), Andrew Oosterbaan, during the investigation and plea discussions, and that the CEOS Chief attended a meeting with defense counsel, during which defense counsel made a pitch that Epstein should not be prosecuted.\n\nNovember 2020 Report, United States Department of Justice, Office of Professional Responsibility, at 61-62. However, although the line prosecutor, Maria Villafaña, subsequently sent the CEOS Chief a draft of the NPA, the OPR Report reflects that the CEOS Chief reported to\n\n6 The defendant's motion cites to the executive summary of the OPR Report. However, the entire report is publicly available, is attached as Exhibit 3 hereto, and has been widely reported on and published by the media. See, e.g., \"Read the report: Investigation into the U.S. Attorney's Office for the Southern District of Florida's Resolution of Its 2006-2008 Federal Criminal Investigation of Jeffrey Epstein and Its Interactions with Victims during the Investigation,\" Wash. Post (Nov. 12, 2020), https://www.washingtonpost.com/context/read-the-report-investigation-into-the-u-s-attorney-s-office-for-the-southern-district-of-florida-s-resolution-of-its-2006-2008-federal-criminal-investigation-of-jeffrey-epstein-and-its-interactions-with-victims-during-the-investigation/db9373e8-22f8-4712-b4a7-be844d162de0/.\n\n11\nDOJ-OGR-00002972",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204 Filed 04/16/21 Page 38 of 239",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "would not, without more, establish that the USAO-SDFL intended to bind other districts, much less that the USAO-SDFL communicated a promise to Epstein that the NPA would extend beyond the USAO-SDFL. The defendant's failure to offer any evidence is fatal to her claim.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Although it is not the Government's burden to address and rebut every innuendo or conclusory statement in the defendant's motion, it is significant here that the circumstances of the NPA have been extensively litigated in a civil lawsuit, and have also been investigated by the Department of Justice's Office of Professional Responsibility (\"OPR\"), resulting in a report of OPR's findings (the \"OPR Report\").6 The records of both matters provide no support for the defendant's claims.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The OPR Report notes that the USAO-SDFL periodically consulted with the Chief of the Department of Justice Child Exploitation and Obscenity Section (\"CEOS\"), Andrew Oosterbaan, during the investigation and plea discussions, and that the CEOS Chief attended a meeting with defense counsel, during which defense counsel made a pitch that Epstein should not be prosecuted.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "November 2020 Report, United States Department of Justice, Office of Professional Responsibility, at 61-62. However, although the line prosecutor, Maria Villafaña, subsequently sent the CEOS Chief a draft of the NPA, the OPR Report reflects that the CEOS Chief reported to",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "6 The defendant's motion cites to the executive summary of the OPR Report. However, the entire report is publicly available, is attached as Exhibit 3 hereto, and has been widely reported on and published by the media. See, e.g., \"Read the report: Investigation into the U.S. Attorney's Office for the Southern District of Florida's Resolution of Its 2006-2008 Federal Criminal Investigation of Jeffrey Epstein and Its Interactions with Victims during the Investigation,\" Wash. Post (Nov. 12, 2020), https://www.washingtonpost.com/context/read-the-report-investigation-into-the-u-s-attorney-s-office-for-the-southern-district-of-florida-s-resolution-of-its-2006-2008-federal-criminal-investigation-of-jeffrey-epstein-and-its-interactions-with-victims-during-the-investigation/db9373e8-22f8-4712-b4a7-be844d162de0/.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "11",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00002972",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein",
      "Andrew Oosterbaan",
      "Maria Villafaña",
      "Jeffrey Epstein"
    ],
    "organizations": [
      "USAO-SDFL",
      "Department of Justice",
      "Office of Professional Responsibility",
      "Child Exploitation and Obscenity Section",
      "Wash. Post"
    ],
    "locations": [
      "Southern District of Florida"
    ],
    "dates": [
      "04/16/21",
      "November 2020",
      "Nov. 12, 2020"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204",
      "DOJ-OGR-00002972"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Jeffrey Epstein. The text is printed and there are no visible stamps or handwritten notes. The document is page 38 of 239."
}