{
  "document_metadata": {
    "page_number": "292",
    "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 292 of 348\n\nstrongly objected to the government's plan to notify victims of the state proceedings, which he described as \"highly inappropriate\" and an \"intrusion into state affairs, when the identified individuals are not even victims of the crime for which Mr. Epstein is being sentenced.\"\n\nThereafter—at a time when the USAO believed Epstein's plea to be imminent—Villafaña drafted, and Sloman signed, the December 6, 2007 letter to Lefkowitz rejecting the defense arguments regarding notification and reiterating the USAO's position that the victims identified in the federal investigation be invited to appear at the state plea hearing. The letter took an expansive view of the applicable statutes by contending that both the CVRA and the VRRA required the USAO to notify the victims of the state proceedings:\n\n[T]hese sections are not limited to proceedings in a federal district court. Our Non-Prosecution Agreement resolves the federal investigation by allowing Mr. Epstein to plead to a state offense. The victims identified through the federal investigation should be appropriately informed, and our Non-Prosecution Agreement does not require the U.S. Attorney's Office to forego [sic] its legal obligations.416\n\nThe letter also asserted that the VRRA obligated the USAO to provide the victims with information concerning restitution to which they may be entitled and \"the earliest possible\" notice of the status of the investigation, the filing of charges, and the acceptance of a plea. Along with the letter, Sloman forwarded a revised draft victim notification letter to Lefkowitz for his comments. This draft victim notification letter stated that the federal investigation had been completed, Epstein would plead guilty in state court, the parties would recommend 18 months of imprisonment at sentencing, and Epstein would compensate victims for monetary damages claims brought under 18 U.S.C. § 2255. The draft victim notification letter provided specific information concerning the upcoming change of plea hearing and invited the victims to attend or provide a written statement to the State Attorney's Office. When Lefkowitz asked Sloman to delay sending victim notifications until after a discussion of their contents, Sloman instructed Villafaña, who was preparing letters for transmittal to 30 victims, to \"Hold the letter.\" During his OPR interview, Sloman recalled that he had \"wanted to push the letter out,\" but he \"must have had a conversation with somebody\" about whether the CVRA applied, and based on that conversation he directed Villafaña to hold the letter.\n\nIn his response letter to Acosta, Lefkowitz contended that the government had misinterpreted both the CVRA and VRRA because neither applied to the \"public proceeding in this matter [which] will be in state court for the purpose of the entry of a plea on state charges.\"\n\n416 Sloman told Lefkowitz the USAO did not seek to \"federalize\" a state plea, but \"is simply informing the victims of their rights.\" Sloman also addressed the defense attorneys' objection to advising the victims that they could contact Villafaña or the FBI case agent with questions or concerns by referencing the CVRA, noting, \"Again, federal law requires that victims have the 'reasonable right to confer with the attorney for the Government in this case.'\"\n\n266\n\nDOJ-OGR-00003468",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 292 of 348",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "strongly objected to the government's plan to notify victims of the state proceedings, which he described as \"highly inappropriate\" and an \"intrusion into state affairs, when the identified individuals are not even victims of the crime for which Mr. Epstein is being sentenced.\"",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Thereafter—at a time when the USAO believed Epstein's plea to be imminent—Villafaña drafted, and Sloman signed, the December 6, 2007 letter to Lefkowitz rejecting the defense arguments regarding notification and reiterating the USAO's position that the victims identified in the federal investigation be invited to appear at the state plea hearing. The letter took an expansive view of the applicable statutes by contending that both the CVRA and the VRRA required the USAO to notify the victims of the state proceedings:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "[T]hese sections are not limited to proceedings in a federal district court. Our Non-Prosecution Agreement resolves the federal investigation by allowing Mr. Epstein to plead to a state offense. The victims identified through the federal investigation should be appropriately informed, and our Non-Prosecution Agreement does not require the U.S. Attorney's Office to forego [sic] its legal obligations.416",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The letter also asserted that the VRRA obligated the USAO to provide the victims with information concerning restitution to which they may be entitled and \"the earliest possible\" notice of the status of the investigation, the filing of charges, and the acceptance of a plea. Along with the letter, Sloman forwarded a revised draft victim notification letter to Lefkowitz for his comments. This draft victim notification letter stated that the federal investigation had been completed, Epstein would plead guilty in state court, the parties would recommend 18 months of imprisonment at sentencing, and Epstein would compensate victims for monetary damages claims brought under 18 U.S.C. § 2255. The draft victim notification letter provided specific information concerning the upcoming change of plea hearing and invited the victims to attend or provide a written statement to the State Attorney's Office. When Lefkowitz asked Sloman to delay sending victim notifications until after a discussion of their contents, Sloman instructed Villafaña, who was preparing letters for transmittal to 30 victims, to \"Hold the letter.\" During his OPR interview, Sloman recalled that he had \"wanted to push the letter out,\" but he \"must have had a conversation with somebody\" about whether the CVRA applied, and based on that conversation he directed Villafaña to hold the letter.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In his response letter to Acosta, Lefkowitz contended that the government had misinterpreted both the CVRA and VRRA because neither applied to the \"public proceeding in this matter [which] will be in state court for the purpose of the entry of a plea on state charges.\"",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "416 Sloman told Lefkowitz the USAO did not seek to \"federalize\" a state plea, but \"is simply informing the victims of their rights.\" Sloman also addressed the defense attorneys' objection to advising the victims that they could contact Villafaña or the FBI case agent with questions or concerns by referencing the CVRA, noting, \"Again, federal law requires that victims have the 'reasonable right to confer with the attorney for the Government in this case.'\"",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "266",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003468",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein",
      "Villafaña",
      "Sloman",
      "Lefkowitz",
      "Acosta"
    ],
    "organizations": [
      "USAO",
      "FBI",
      "U.S. Attorney's Office",
      "State Attorney's Office"
    ],
    "locations": [
      "federal district court",
      "state court"
    ],
    "dates": [
      "December 6, 2007",
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204-3",
      "DOJ-OGR-00003468",
      "18 U.S.C. § 2255"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Jeffrey Epstein. It discusses the government's plan to notify victims of state proceedings and the objections raised by the defense. The document includes references to specific statutes and laws, such as the CVRA and VRRA."
}