{
  "document_metadata": {
    "page_number": "47",
    "document_number": "293-1",
    "date": "05/25/21",
    "document_type": "Court Document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "equipment.74 After further communications on this issue involving Black, Sanchez, Villafaña, and Lourie, Black took legal action that effectively halted production of the computer equipment to the USAO until the issue could be decided by the court—which, as explained below, never happened because the parties entered into the NPA.\n\nC. July 2007: The Defense Continues Its Efforts to Stop the Federal Investigation\n\nIn addition to their efforts to stop the government from obtaining the computer equipment, defense counsel also sent letters to the USAO, dated July 6, 2007, and July 25, 2007, reiterating their objections to a federal investigation of Epstein. The July 25, 2007 letter included a lengthy “case analysis chart” purporting to support the defense argument that Epstein had committed no federal offense. The July 25 letter also noted that the defense had been consulting with the former Principal Deputy Chief of CEOS, reporting that she “supports our position without reservation that this is not a matter upon which the federal statu[t]es should be brought to bear.”75\n\nWhile the defense was reiterating its objections to the federal investigation, CEOS expressed its endorsement of Villafaña's legal analysis and proposed charges. On July 18, 2007, CEOS Chief Oosterbaan emailed Sloman, Menchel, and Lourie, stating that he had read Villafaña's prosecution memorandum “closely,” and noting that “[s]he did a terrific job. As we opined to Andy [Lourie] back in May, [CEOS] agree[s] with her legal analysis. Her charging decisions are legally sound.” Oosterbaan observed:\n\nI have also reviewed the arguments contained in the letters from defense counsel. Their legal analysis is detailed and comprehensive, but I find none of their arguments persuasive. That is not to say that all the arguments are completely devoid of merit. I expect the judge to consider some of the arguments closely. Nevertheless, while the law applicable here is not always crystal clear, the balance of available precedent favors us. From the prosecution memorandum it is clear that Marie has anticipated the strongest legal arguments, scrutinized the applicable law, and has charged the case accordingly. And, while with this prosecution the government clearly faces a strong and determined defense team, it is a challenge well facing. I also happen to know that there is absolutely no concern . . . about facing the challenges this case presents.\n\nIn closing, Oosterbaan renewed his offer to have CEOS “help you with this prosecution,” and to send “whatever and whoever you need” to assist.\n\n74 Villafaña forwarded Black's letter to Menchel, explaining the circumstances relating to the removal of the computer equipment from Epstein's home, the steps she had taken to make the required consultations in the Department, and that she and Lourie had worked together on her response to Black.\n\n75 The news that the former CEOS Principal Deputy Chief was advising the Epstein team led to an email exchange between Sloman and CEOS Chief Oosterbaan, who commented, “By the way, let me know if you want me to put something in writing to you with our position and detailing all of the child prostitution cases she supervised with similar facts.”\n\n47\n\nDOJ-OGR-00004371",
  "text_blocks": [
    {
      "type": "printed",
      "content": "equipment.74 After further communications on this issue involving Black, Sanchez, Villafaña, and Lourie, Black took legal action that effectively halted production of the computer equipment to the USAO until the issue could be decided by the court—which, as explained below, never happened because the parties entered into the NPA.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "C. July 2007: The Defense Continues Its Efforts to Stop the Federal Investigation",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "In addition to their efforts to stop the government from obtaining the computer equipment, defense counsel also sent letters to the USAO, dated July 6, 2007, and July 25, 2007, reiterating their objections to a federal investigation of Epstein. The July 25, 2007 letter included a lengthy “case analysis chart” purporting to support the defense argument that Epstein had committed no federal offense. The July 25 letter also noted that the defense had been consulting with the former Principal Deputy Chief of CEOS, reporting that she “supports our position without reservation that this is not a matter upon which the federal statu[t]es should be brought to bear.”75",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "While the defense was reiterating its objections to the federal investigation, CEOS expressed its endorsement of Villafaña's legal analysis and proposed charges. On July 18, 2007, CEOS Chief Oosterbaan emailed Sloman, Menchel, and Lourie, stating that he had read Villafaña's prosecution memorandum “closely,” and noting that “[s]he did a terrific job. As we opined to Andy [Lourie] back in May, [CEOS] agree[s] with her legal analysis. Her charging decisions are legally sound.” Oosterbaan observed:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "I have also reviewed the arguments contained in the letters from defense counsel. Their legal analysis is detailed and comprehensive, but I find none of their arguments persuasive. That is not to say that all the arguments are completely devoid of merit. I expect the judge to consider some of the arguments closely. Nevertheless, while the law applicable here is not always crystal clear, the balance of available precedent favors us. From the prosecution memorandum it is clear that Marie has anticipated the strongest legal arguments, scrutinized the applicable law, and has charged the case accordingly. And, while with this prosecution the government clearly faces a strong and determined defense team, it is a challenge well facing. I also happen to know that there is absolutely no concern . . . about facing the challenges this case presents.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "In closing, Oosterbaan renewed his offer to have CEOS “help you with this prosecution,” and to send “whatever and whoever you need” to assist.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "74 Villafaña forwarded Black's letter to Menchel, explaining the circumstances relating to the removal of the computer equipment from Epstein's home, the steps she had taken to make the required consultations in the Department, and that she and Lourie had worked together on her response to Black.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "75 The news that the former CEOS Principal Deputy Chief was advising the Epstein team led to an email exchange between Sloman and CEOS Chief Oosterbaan, who commented, “By the way, let me know if you want me to put something in writing to you with our position and detailing all of the child prostitution cases she supervised with similar facts.”",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "47",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004371",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Black",
      "Sanchez",
      "Villafaña",
      "Lourie",
      "Epstein",
      "Oosterbaan",
      "Sloman",
      "Menchel",
      "Andy",
      "Marie"
    ],
    "organizations": [
      "USAO",
      "CEOS",
      "Department"
    ],
    "locations": [],
    "dates": [
      "July 6, 2007",
      "July 25, 2007",
      "July 18, 2007",
      "May",
      "05/25/21"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 293-1",
      "DOJ-OGR-00004371"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case against Epstein. The text is mostly printed, with some footnotes and a page number at the bottom. There are no visible stamps or handwritten text."
}