{
  "document_metadata": {
    "page_number": "96 of 348",
    "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 96 of 348\nevidence of a violation of the agreement. Epstein and his counsel agree that the computers that are currently under [legal process] will be safeguarded in their current condition by Epstein's counsel or their agents until the terms and conditions of the Agreement are fulfilled.\n\nLater that day, Villafaña sent Lefkowitz a lengthy email to convey two options Lourie had suggested: \"the original proposal\" for a state plea but with an agreement for an 18-month sentence, or pleas to state charges and two federal obstruction-of-justice charges. Villafaña also told Lefkowitz she was willing to ask Acosta again to approve a federal plea to a five-year conspiracy with a Rule 11(c) binding recommendation for a 20-month sentence. Villafaña explained:\n\nAs to timing, it is my understanding that Mr. Epstein needs to be sentenced in the state after he is sentenced in the federal case, but not that he needs to plead guilty and be sentenced after serving his federal time. Andy recommended that some of the timing issues be addressed only in the state agreement, so that it isn't obvious to the judge that we are trying to create federal jurisdiction for prison purposes.\n\nWith regard to prosecution of individuals other than Epstein, Villafaña suggested standard federal plea agreement language regarding the resolution of all criminal liability, \"and I will mention 'co-conspirators,' but I would prefer not to highlight for the judge all of the other crimes and all of the other persons that we could charge.\" Villafaña told OPR that she was willing to include a non-prosecution provision for Epstein's co-conspirators, who at the time she understood to be the four women named in the proposed agreement, because the USAO was not interested in prosecuting those individuals if Epstein entered a plea. Villafaña told OPR, \"[W]e considered Epstein to be the top of the food chain, and we wouldn't have been interested in prosecuting anyone else.\" She did not consider the possibility that Epstein might be trying to protect other, unnamed individuals, and no one, including the FBI case agents, raised that concern. Villafaña also told OPR that her reference to \"all of the other crimes and all of the other persons that we could charge\" related to her concern that if the plea agreement contained information about uncharged conduct, the court might ask for more information about that conduct and inquire why it had not been charged, and if the government provided such information, Epstein's attorneys might claim the agreement was breached.113\n\nWith regard to immigration, Villafaña told OPR that the USAO generally did not take any position in plea agreements on immigration issues, and that in this case, there was no evidence that either of the two assistants who were foreign nationals had committed fraud in connection with their immigration paperwork, \"and I think that they were both in status. So there wasn't any reason\n\n113 OPR understood Villafaña's concern to be that if the government were required to respond to a court's inquiry into additional facts, Epstein would object that the government was trying to cast him in a negative light in order to influence the court to impose a sentence greater than the agreed-upon term.\n\n70\n\nDOJ-OGR-00003272",
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    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 96 of 348",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "evidence of a violation of the agreement. Epstein and his counsel agree that the computers that are currently under [legal process] will be safeguarded in their current condition by Epstein's counsel or their agents until the terms and conditions of the Agreement are fulfilled.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Later that day, Villafaña sent Lefkowitz a lengthy email to convey two options Lourie had suggested: \"the original proposal\" for a state plea but with an agreement for an 18-month sentence, or pleas to state charges and two federal obstruction-of-justice charges. Villafaña also told Lefkowitz she was willing to ask Acosta again to approve a federal plea to a five-year conspiracy with a Rule 11(c) binding recommendation for a 20-month sentence. Villafaña explained:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "As to timing, it is my understanding that Mr. Epstein needs to be sentenced in the state after he is sentenced in the federal case, but not that he needs to plead guilty and be sentenced after serving his federal time. Andy recommended that some of the timing issues be addressed only in the state agreement, so that it isn't obvious to the judge that we are trying to create federal jurisdiction for prison purposes.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "With regard to prosecution of individuals other than Epstein, Villafaña suggested standard federal plea agreement language regarding the resolution of all criminal liability, \"and I will mention 'co-conspirators,' but I would prefer not to highlight for the judge all of the other crimes and all of the other persons that we could charge.\" Villafaña told OPR that she was willing to include a non-prosecution provision for Epstein's co-conspirators, who at the time she understood to be the four women named in the proposed agreement, because the USAO was not interested in prosecuting those individuals if Epstein entered a plea. Villafaña told OPR, \"[W]e considered Epstein to be the top of the food chain, and we wouldn't have been interested in prosecuting anyone else.\" She did not consider the possibility that Epstein might be trying to protect other, unnamed individuals, and no one, including the FBI case agents, raised that concern. Villafaña also told OPR that her reference to \"all of the other crimes and all of the other persons that we could charge\" related to her concern that if the plea agreement contained information about uncharged conduct, the court might ask for more information about that conduct and inquire why it had not been charged, and if the government provided such information, Epstein's attorneys might claim the agreement was breached.113",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "With regard to immigration, Villafaña told OPR that the USAO generally did not take any position in plea agreements on immigration issues, and that in this case, there was no evidence that either of the two assistants who were foreign nationals had committed fraud in connection with their immigration paperwork, \"and I think that they were both in status. So there wasn't any reason",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "113 OPR understood Villafaña's concern to be that if the government were required to respond to a court's inquiry into additional facts, Epstein would object that the government was trying to cast him in a negative light in order to influence the court to impose a sentence greater than the agreed-upon term.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "70",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003272",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein",
      "Villafaña",
      "Lefkowitz",
      "Lourie",
      "Acosta",
      "Andy"
    ],
    "organizations": [
      "USAO",
      "FBI",
      "OPR"
    ],
    "locations": [],
    "dates": [
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204-3",
      "DOJ-OGR-00003272"
    ]
  },
  "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 96 of 348."
}