{
  "document_metadata": {
    "page_number": "126",
    "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 126 of 349\n\nNotwithstanding these voluminous submissions, Lefkowitz added that Epstein \"unconditionally re-asserts his intention to fulfill and not seek to withdraw from or unwind\" the NPA.\n\n2. As a Result of the Starr and Lefkowitz Submissions, the New USAO Criminal Chief Begins a Full Review of the Evidence, and Acosta Agrees to Meet Again with Defense Counsel\n\nAfter reviewing Starr's and Lefkowitz's letters, Sloman notified Villafaña that \"in light of the recent Kirkland & Ellis correspondence\" he had asked Robert Senior, who had succeeded Menchel as Chief of the USAO's Criminal Division, to review de novo the evidence underlying the proposed revised indictment, and Sloman asked Villafaña to provide Senior with all the state and FBI investigative materials.\n\nIn the meantime, Acosta agreed to meet with Starr and other Epstein defense attorneys to discuss the defense complaints raised in Lefkowitz's December 11, 2007 submissions.156 The meeting took place in Miami on December 14, 2007. The defense team included Starr, Dershowitz, Lefcourt, and Boston attorney Martin Weinberg. The USAO side included Acosta, Sloman, Villafaña, and another senior AUSA, with the Miami FBI Special Agent in Charge and Assistant Special Agent in Charge also present. In addition to previously raised arguments, during this meeting, Epstein's attorneys raised a new argument—that the state charge to which Epstein had agreed to plead guilty did not apply to the facts of the case.\n\n3. The Defense Notifies Acosta That It May Pursue a Department Review of the USAO's Actions\n\nShortly after the December 14, 2007 meeting, Lefkowitz notified Acosta that if the issues raised at the meeting could not be resolved promptly, the defense team may \"have no alternative but to seek review in Washington.\" Acosta notified Assistant Attorney General Fisher that the defense team might make an appeal to her, and he asked her to grant such a request for review and \"to in fact review this case in an expedited manner [in order] to preserve the January 4th plea date.\" Starr and Lefkowitz then sent to Acosta a lengthy letter, with numerous previously submitted defense submissions, reviewing issues discussed at the meeting, and advising that Epstein sought a \"prompt, independent, expedited review\" of the evidence by \"you or someone you trust.\" The letter reiterated Epstein's position that his conduct did not amount to a registrable offense under state law or a violation of federal law, and with respect to the NPA's § 2255 provision, that it was \"improper\" to require Epstein to pay damages \"to individuals who do nothing but simply assert a claim\" under the statute.\n\n156 As Assistant Attorney General Fisher's Chief of Staff, Lourie had informed Starr that Fisher hoped Starr would speak to Acosta to \"resolve the[] fairly narrow issues\" raised in Starr's correspondence with Acosta. Acosta had the Starr and Lefkowitz submissions of December 11 forwarded to Fisher.",
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    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 126 of 349",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "Notwithstanding these voluminous submissions, Lefkowitz added that Epstein \"unconditionally re-asserts his intention to fulfill and not seek to withdraw from or unwind\" the NPA.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "2. As a Result of the Starr and Lefkowitz Submissions, the New USAO Criminal Chief Begins a Full Review of the Evidence, and Acosta Agrees to Meet Again with Defense Counsel",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "After reviewing Starr's and Lefkowitz's letters, Sloman notified Villafaña that \"in light of the recent Kirkland & Ellis correspondence\" he had asked Robert Senior, who had succeeded Menchel as Chief of the USAO's Criminal Division, to review de novo the evidence underlying the proposed revised indictment, and Sloman asked Villafaña to provide Senior with all the state and FBI investigative materials.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In the meantime, Acosta agreed to meet with Starr and other Epstein defense attorneys to discuss the defense complaints raised in Lefkowitz's December 11, 2007 submissions.156 The meeting took place in Miami on December 14, 2007. The defense team included Starr, Dershowitz, Lefcourt, and Boston attorney Martin Weinberg. The USAO side included Acosta, Sloman, Villafaña, and another senior AUSA, with the Miami FBI Special Agent in Charge and Assistant Special Agent in Charge also present. In addition to previously raised arguments, during this meeting, Epstein's attorneys raised a new argument—that the state charge to which Epstein had agreed to plead guilty did not apply to the facts of the case.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "3. The Defense Notifies Acosta That It May Pursue a Department Review of the USAO's Actions",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Shortly after the December 14, 2007 meeting, Lefkowitz notified Acosta that if the issues raised at the meeting could not be resolved promptly, the defense team may \"have no alternative but to seek review in Washington.\" Acosta notified Assistant Attorney General Fisher that the defense team might make an appeal to her, and he asked her to grant such a request for review and \"to in fact review this case in an expedited manner [in order] to preserve the January 4th plea date.\" Starr and Lefkowitz then sent to Acosta a lengthy letter, with numerous previously submitted defense submissions, reviewing issues discussed at the meeting, and advising that Epstein sought a \"prompt, independent, expedited review\" of the evidence by \"you or someone you trust.\" The letter reiterated Epstein's position that his conduct did not amount to a registrable offense under state law or a violation of federal law, and with respect to the NPA's § 2255 provision, that it was \"improper\" to require Epstein to pay damages \"to individuals who do nothing but simply assert a claim\" under the statute.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "156 As Assistant Attorney General Fisher's Chief of Staff, Lourie had informed Starr that Fisher hoped Starr would speak to Acosta to \"resolve the[] fairly narrow issues\" raised in Starr's correspondence with Acosta. Acosta had the Starr and Lefkowitz submissions of December 11 forwarded to Fisher.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "99",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004423",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Lefkowitz",
      "Epstein",
      "Starr",
      "Sloman",
      "Villafaña",
      "Robert Senior",
      "Menchel",
      "Acosta",
      "Dershowitz",
      "Lefcourt",
      "Martin Weinberg",
      "Fisher",
      "Lourie"
    ],
    "organizations": [
      "Kirkland & Ellis",
      "USAO",
      "FBI",
      "Department of Justice"
    ],
    "locations": [
      "Miami",
      "Boston",
      "Washington"
    ],
    "dates": [
      "05/25/21",
      "December 11, 2007",
      "December 14, 2007",
      "January 4th"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "293-1",
      "126",
      "349",
      "DOJ-OGR-00004423"
    ]
  },
  "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 126 of 349."
}