{
  "document_metadata": {
    "page_number": "124",
    "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 124 of 348\n\nthe defense \"[f]irst and foremost\" reaffirmed the NPA and that Epstein \"has no intention of unwinding the agreement.\"\n\nOn December 7, 2007—the deadline set by Acosta in his December 4, 2007 letter to Starr—the defense transmitted to the USAO a one-sentence \"Affirmation\" of the NPA and its addendum, signed by Epstein.154\n\nF. Despite Affirming the NPA, Defense Counsel Intensify Their Challenges to It and Accuse Villafaña of Improper Conduct\n\n1. December 7 and 11, 2007: Starr and Lefkowitz Send to Acosta Letters and \"Ethics Opinions\" Complaining about the Federal Investigation and Villafaña\n\nOn the same day that the defense team sent Epstein's \"Affirmation\" to the USAO, Starr and Lefkowitz sent to Acosta two \"independent ethics opinions\"—one authored by prominent criminal defense attorney and former U.S. Attorney Joe Whitley, which assessed purported improprieties in the federal investigation of Epstein, and the other, by a prominent retired federal judge and former U.S. Attorney, arguing against the NPA's use of the civil damages recovery provision under 18 U.S.C. § 2255 \"as a proxy for traditional criminal restitution.\"\n\nDays later, on December 11, 2007, Starr sent a letter to Acosta transmitting two lengthy submissions authored by Lefkowitz presenting substantive challenges to the NPA and to the \"background and conduct of the investigation.\" These submissions repeated arguments previously raised by the defense but also asserted new issues. In one submission, 20 pages long, Lefkowitz addressed the \"improper involvement\" of federal authorities in the investigation and criticized Villafaña for a number of alleged improprieties, including having engaged in \"unprecedented federal overreaching\" by seeking to prosecute Epstein federally, \"insist[ing]\" that the State Attorney's Office \"charge Mr. Epstein with violations of law and recommend a sentence that are significantly harsher than what the State deemed appropriate,\" and requiring that Epstein plead guilty to a registrable offense, a \"harsh\" condition that was \"unwarranted.\"155\n\nLefkowitz also argued that the federal investigation relied upon a state investigation that was \"tainted\" by the lead PBPD Detective's misrepresentation of key facts in affidavits and interview summaries, leading the USAO to make its charging decision based on flawed information that \"compromised the federal investigation.\" Finally, Lefkowitz criticized federal involvement in the state plea process as a violation of \"the tenets of the Petite Policy.\" In a second, 13-page submission, Lefkowitz reiterated Epstein's complaints about the § 2255 component of the NPA, arguing, among other things, that federal prosecutors \"should not be in the business of helping alleged victims of state crimes secure civil financial settlements.\"\n\n154 The Affirmation read: \"I, Jeffrey E. Epstein do hereby re-affirm the Non-Prosecution Agreement and Addendum to same dated October 30, 2007.\"\n155 Villafaña sent Lefkowitz a five-page letter responding to the accusations made against her personally.\n\n98\nDOJ-OGR-00003300",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 124 of 348",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "the defense \"[f]irst and foremost\" reaffirmed the NPA and that Epstein \"has no intention of unwinding the agreement.\"",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "On December 7, 2007—the deadline set by Acosta in his December 4, 2007 letter to Starr—the defense transmitted to the USAO a one-sentence \"Affirmation\" of the NPA and its addendum, signed by Epstein.154",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "F. Despite Affirming the NPA, Defense Counsel Intensify Their Challenges to It and Accuse Villafaña of Improper Conduct",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "1. December 7 and 11, 2007: Starr and Lefkowitz Send to Acosta Letters and \"Ethics Opinions\" Complaining about the Federal Investigation and Villafaña",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "On the same day that the defense team sent Epstein's \"Affirmation\" to the USAO, Starr and Lefkowitz sent to Acosta two \"independent ethics opinions\"—one authored by prominent criminal defense attorney and former U.S. Attorney Joe Whitley, which assessed purported improprieties in the federal investigation of Epstein, and the other, by a prominent retired federal judge and former U.S. Attorney, arguing against the NPA's use of the civil damages recovery provision under 18 U.S.C. § 2255 \"as a proxy for traditional criminal restitution.\"",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Days later, on December 11, 2007, Starr sent a letter to Acosta transmitting two lengthy submissions authored by Lefkowitz presenting substantive challenges to the NPA and to the \"background and conduct of the investigation.\" These submissions repeated arguments previously raised by the defense but also asserted new issues. In one submission, 20 pages long, Lefkowitz addressed the \"improper involvement\" of federal authorities in the investigation and criticized Villafaña for a number of alleged improprieties, including having engaged in \"unprecedented federal overreaching\" by seeking to prosecute Epstein federally, \"insist[ing]\" that the State Attorney's Office \"charge Mr. Epstein with violations of law and recommend a sentence that are significantly harsher than what the State deemed appropriate,\" and requiring that Epstein plead guilty to a registrable offense, a \"harsh\" condition that was \"unwarranted.\"155",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Lefkowitz also argued that the federal investigation relied upon a state investigation that was \"tainted\" by the lead PBPD Detective's misrepresentation of key facts in affidavits and interview summaries, leading the USAO to make its charging decision based on flawed information that \"compromised the federal investigation.\" Finally, Lefkowitz criticized federal involvement in the state plea process as a violation of \"the tenets of the Petite Policy.\" In a second, 13-page submission, Lefkowitz reiterated Epstein's complaints about the § 2255 component of the NPA, arguing, among other things, that federal prosecutors \"should not be in the business of helping alleged victims of state crimes secure civil financial settlements.\"",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "154 The Affirmation read: \"I, Jeffrey E. Epstein do hereby re-affirm the Non-Prosecution Agreement and Addendum to same dated October 30, 2007.\"",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "155 Villafaña sent Lefkowitz a five-page letter responding to the accusations made against her personally.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "98",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003300",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein",
      "Acosta",
      "Starr",
      "Lefkowitz",
      "Villafaña",
      "Joe Whitley",
      "Jeffrey E. Epstein"
    ],
    "organizations": [
      "USAO",
      "State Attorney's Office",
      "PBPD"
    ],
    "locations": [],
    "dates": [
      "December 7, 2007",
      "December 4, 2007",
      "December 11, 2007",
      "October 30, 2007",
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "204-3",
      "DOJ-OGR-00003300"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Jeffrey Epstein. It includes references to various legal documents and correspondence between lawyers. The text is mostly printed, with no visible handwriting or stamps."
}