{
  "document_metadata": {
    "page_number": "59",
    "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 59 of 348\n\nfor meetings was to cause delay, but \"the people in my office either couldn't see that or didn't want to see that,\" perhaps because of \"their lack of experience with these types of cases\" or a misguided belief \"that [Epstein's] attorneys would not engage in this behavior.\" Villafaña told OPR that she \"could not seem to get [her supervisors] to understand the seriousness of Epstein's behavior and the fact that he was probably continuing to commit the behavior, and that there was a need to move with necessary speed.\" Nonetheless, Villafaña followed the guidance of her immediate supervisor and did not send the email.\n\nLike Lourie, Menchel told OPR that he believed meeting with defense counsel was good practice. Menchel told OPR that he saw \"no downside\" to hearing the defense point of view. Defense counsel might make a persuasive point \"that's actually going to change our mind,\" or alternatively, present arguments the defense would inevitably raise if the case went forward, and Menchel believed it would be to the USAO's advantage to learn about such arguments in advance. Menchel also told OPR that he did not recall Villafaña ever articulating a concern that Epstein was continuing to offend, and in Menchel's view, Epstein was \"already under a microscope, at least in Florida,\" and it would have been \"the height of stupidity\" for Epstein to continue to offend in those circumstances.\n\nE. June 2007: Villafaña Supplements the Prosecution Memorandum\n\nWhile Villafaña's supervisors were considering whether to go forward with the proposed charges, Villafaña took additional steps to support them. On June 14, 2007, she supplemented the prosecution memorandum with an addendum addressing \"credibility concerns\" relating to one of the victims. In the email transmitting the addendum to Lourie, Menchel, Sloman, and her immediate supervisor, Villafaña reported, \"another Jane Doe has been identified and interviewed,\" and the \"different strategies\" about how to structure the charges left Villafaña unsure whether \"to make . . . changes now or wait until we have received approval of the current charging strategy.\" The addendum itself related to a particular victim referred to as the minor who \"saw Epstein most frequently\" and who had allegedly engaged in sexual activity with both Epstein and an Epstein assistant. In the addendum, Villafaña identified documents she had found corroborating four separate statements made by this victim.\n\nVillafaña told OPR that the only victim about whom any supervisor ever articulated specific credibility issues was the victim discussed in the addendum. Lourie told OPR that he had no specific recollection of the addendum, but it was \"reasonable\" to assume that the addendum addressed one particular victim because no one had identified specific concerns relating to any other victim. Villafaña's immediate supervisor similarly told OPR that to her recollection, the discussions about credibility issues were generic rather than tied to specific victims.\n\nF. The June 26, 2007 Meeting with Defense Counsel\n\nMenchel agreed to meet with defense counsel on June 26, 2007, communicating directly with Sanchez about the arrangements. At Menchel's instruction, on June 18, 2007, Villafaña sent a letter to defense counsel identifying what she described as \"the statutes under consideration.\"51\n\n51 Villafaña sent copies of this letter to both Menchel and Sanchez. Villafaña told OPR that she objected to sending this information to the defense. Although Menchel did not recall directing Villafaña to send the letter to\n\n33\n\nDOJ-OGR-00003235",
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      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 59 of 348",
      "position": "header"
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    {
      "type": "printed",
      "content": "for meetings was to cause delay, but \"the people in my office either couldn't see that or didn't want to see that,\" perhaps because of \"their lack of experience with these types of cases\" or a misguided belief \"that [Epstein's] attorneys would not engage in this behavior.\" Villafaña told OPR that she \"could not seem to get [her supervisors] to understand the seriousness of Epstein's behavior and the fact that he was probably continuing to commit the behavior, and that there was a need to move with necessary speed.\" Nonetheless, Villafaña followed the guidance of her immediate supervisor and did not send the email.",
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    },
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      "type": "printed",
      "content": "Like Lourie, Menchel told OPR that he believed meeting with defense counsel was good practice. Menchel told OPR that he saw \"no downside\" to hearing the defense point of view. Defense counsel might make a persuasive point \"that's actually going to change our mind,\" or alternatively, present arguments the defense would inevitably raise if the case went forward, and Menchel believed it would be to the USAO's advantage to learn about such arguments in advance. Menchel also told OPR that he did not recall Villafaña ever articulating a concern that Epstein was continuing to offend, and in Menchel's view, Epstein was \"already under a microscope, at least in Florida,\" and it would have been \"the height of stupidity\" for Epstein to continue to offend in those circumstances.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "E. June 2007: Villafaña Supplements the Prosecution Memorandum",
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    },
    {
      "type": "printed",
      "content": "While Villafaña's supervisors were considering whether to go forward with the proposed charges, Villafaña took additional steps to support them. On June 14, 2007, she supplemented the prosecution memorandum with an addendum addressing \"credibility concerns\" relating to one of the victims. In the email transmitting the addendum to Lourie, Menchel, Sloman, and her immediate supervisor, Villafaña reported, \"another Jane Doe has been identified and interviewed,\" and the \"different strategies\" about how to structure the charges left Villafaña unsure whether \"to make . . . changes now or wait until we have received approval of the current charging strategy.\" The addendum itself related to a particular victim referred to as the minor who \"saw Epstein most frequently\" and who had allegedly engaged in sexual activity with both Epstein and an Epstein assistant. In the addendum, Villafaña identified documents she had found corroborating four separate statements made by this victim.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Villafaña told OPR that the only victim about whom any supervisor ever articulated specific credibility issues was the victim discussed in the addendum. Lourie told OPR that he had no specific recollection of the addendum, but it was \"reasonable\" to assume that the addendum addressed one particular victim because no one had identified specific concerns relating to any other victim. Villafaña's immediate supervisor similarly told OPR that to her recollection, the discussions about credibility issues were generic rather than tied to specific victims.",
      "position": "middle"
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    {
      "type": "printed",
      "content": "F. The June 26, 2007 Meeting with Defense Counsel",
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    },
    {
      "type": "printed",
      "content": "Menchel agreed to meet with defense counsel on June 26, 2007, communicating directly with Sanchez about the arrangements. At Menchel's instruction, on June 18, 2007, Villafaña sent a letter to defense counsel identifying what she described as \"the statutes under consideration.\"51",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "51 Villafaña sent copies of this letter to both Menchel and Sanchez. Villafaña told OPR that she objected to sending this information to the defense. Although Menchel did not recall directing Villafaña to send the letter to",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "33",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003235",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Villafaña",
      "Epstein",
      "Menchel",
      "Lourie",
      "Sloman",
      "Sanchez",
      "Jane Doe"
    ],
    "organizations": [
      "OPR",
      "USAO"
    ],
    "locations": [
      "Florida"
    ],
    "dates": [
      "June 14, 2007",
      "June 18, 2007",
      "June 26, 2007",
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204-3",
      "DOJ-OGR-00003235"
    ]
  },
  "additional_notes": "The document appears to be a court document related to the case against Jeffrey Epstein. The text is mostly printed, with some footnotes and a header/footer. There are no visible stamps or handwritten text."
}