{
  "document_metadata": {
    "page_number": "116",
    "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 116 of 349\n\nthat Epstein pay the victims' legal fees incurred from contested litigation would \"trigger profound ethical problems,\" in that the attorney representative would have an incentive to reject settlement offers in order to incur more fees. In addition, Lefkowitz rejected Villafaña's view that Epstein had waived the right to challenge § 2255 liability as to victims who did not want to settle their claims, and contended that any such victims \"will have to prove, among other things, that they are victims under the enumerated statutes.\" Finally, Lefkowitz again argued that the USAO should not discuss the settlement process with the victims who were to be identified as eligible for settlement under § 2255:\n\nMs. Villafaña proposes that either she or federal agents will speak with the [victims] regarding the settlement process. We do not think it is the government's place to be co-counsel to the [victims], nor should the FBI be their personal investigators. Neither federal agents nor anyone from your Office should contact the [victims] to inform them of the resolution of the case, including appointment of the attorney representative and the settlement process. Not only would that violate the confidentiality of the Agreement, but Mr. Epstein also will have no control over what is communicated to the [victims] at this most critical stage. We believe it is essential that we participate in crafting a mutually acceptable communication to the [victims]. We further believe that communications between your Office or your case agents and the [victims] might well violate Rule 6(e)(2)(B) of the Federal Rules of Criminal Procedure. The powers of the federal grand jury should not, even in appearance, be utilized to advance the interests of a party to a civil lawsuit.137\n\nLefkowitz concluded, \"I look forward to resolving these open issues with you during our 4:30 call today.\"138\n\nVillafaña was at that time on sick leave, and Sloman and Acosta exchanged emails about crafting an addendum to the NPA to address the method of appointing an attorney representative and to articulate the representative's duties. The next day, October 11, 2007, Sloman exchanged emails with Lefkowitz about the text of a proposed addendum.\n\nB. October 12, 2007: Acosta and Defense Attorney Lefkowitz Meet for Breakfast\n\nOn the morning after his scheduled afternoon phone call with Lefkowitz, Acosta exchanged emails with Lefkowitz, arranging to meet for breakfast the following day, on October 12, 2007, at a Marriott hotel in West Palm Beach. Contemporaneous records show that Acosta was previously scheduled to be in West Palm Beach for a press event on October 11 and to speak at the Palm Beach County Bench Bar conference the following midday, and that he stayed overnight at the Marriott.\n\n137 Federal Rule of Criminal Procedure 6(e)(2)(B) relates to secrecy of federal grand jury matters.\n138 OPR did not locate any emails indicating what happened on the call.\n\n89\nDOJ-OGR-00004413",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 293-1 Filed 05/25/21 Page 116 of 349",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "that Epstein pay the victims' legal fees incurred from contested litigation would \"trigger profound ethical problems,\" in that the attorney representative would have an incentive to reject settlement offers in order to incur more fees. In addition, Lefkowitz rejected Villafaña's view that Epstein had waived the right to challenge § 2255 liability as to victims who did not want to settle their claims, and contended that any such victims \"will have to prove, among other things, that they are victims under the enumerated statutes.\" Finally, Lefkowitz again argued that the USAO should not discuss the settlement process with the victims who were to be identified as eligible for settlement under § 2255:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Ms. Villafaña proposes that either she or federal agents will speak with the [victims] regarding the settlement process. We do not think it is the government's place to be co-counsel to the [victims], nor should the FBI be their personal investigators. Neither federal agents nor anyone from your Office should contact the [victims] to inform them of the resolution of the case, including appointment of the attorney representative and the settlement process. Not only would that violate the confidentiality of the Agreement, but Mr. Epstein also will have no control over what is communicated to the [victims] at this most critical stage. We believe it is essential that we participate in crafting a mutually acceptable communication to the [victims]. We further believe that communications between your Office or your case agents and the [victims] might well violate Rule 6(e)(2)(B) of the Federal Rules of Criminal Procedure. The powers of the federal grand jury should not, even in appearance, be utilized to advance the interests of a party to a civil lawsuit.137",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Lefkowitz concluded, \"I look forward to resolving these open issues with you during our 4:30 call today.\"138",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Villafaña was at that time on sick leave, and Sloman and Acosta exchanged emails about crafting an addendum to the NPA to address the method of appointing an attorney representative and to articulate the representative's duties. The next day, October 11, 2007, Sloman exchanged emails with Lefkowitz about the text of a proposed addendum.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "B. October 12, 2007: Acosta and Defense Attorney Lefkowitz Meet for Breakfast",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "On the morning after his scheduled afternoon phone call with Lefkowitz, Acosta exchanged emails with Lefkowitz, arranging to meet for breakfast the following day, on October 12, 2007, at a Marriott hotel in West Palm Beach. Contemporaneous records show that Acosta was previously scheduled to be in West Palm Beach for a press event on October 11 and to speak at the Palm Beach County Bench Bar conference the following midday, and that he stayed overnight at the Marriott.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "137 Federal Rule of Criminal Procedure 6(e)(2)(B) relates to secrecy of federal grand jury matters.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "138 OPR did not locate any emails indicating what happened on the call.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "89",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00004413",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Epstein",
      "Villafaña",
      "Lefkowitz",
      "Acosta",
      "Sloman"
    ],
    "organizations": [
      "FBI",
      "USAO"
    ],
    "locations": [
      "West Palm Beach",
      "Palm Beach County"
    ],
    "dates": [
      "05/25/21",
      "October 11, 2007",
      "October 12, 2007"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 293-1",
      "DOJ-OGR-00004413"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the Epstein case. It discusses the settlement process and the involvement of various individuals and organizations. The text is mostly printed, with some footnotes and citations. There are no visible stamps or handwritten notes."
}