{
  "document_metadata": {
    "page_number": "52",
    "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 52 of 348\nforward with charges in this case. Lourie forwarded a copy of the prosecution memorandum to Menchel. Lourie's transmittal message read:\nMarie did a 50 [sic] page pros memo in the Epstein case. I am going to start reading it tonight. . . . It's a major case because the target is one of the richest men in the country and it has been big news. He has a stable of attorneys, including Dershowitz, [Roy] Black, Lefcourt, Lewis, and Lily [sic] Sanchez. Jeff Sloman is familiar with the investigation. The state intentionally torpedoed it in the grand jury so it was brought to us. I am going to forward the pros memo to you so you can start reading it at the same time I do. The FBI is pushing to do it in Mid [sic] May, which I think is not critical, but we might as well get a jump on it. I have some ideas about the indictment (needs to be ultra lean with only clean victims), so I am not sending that yet.\nLourie explained to OPR that by \"clean\" victims, he meant those for whom the defense did not have impeachment evidence to use against them.\nA few days later, Lourie emailed Menchel, asking if Menchel had read the prosecution memorandum. Lourie directed Menchel's attention to particular pages of the prosecution memorandum, noting that the \"keys\" were whether the USAO could prove that Epstein traveled for the purpose of engaging in sexual acts, and the fact that some minor victims told Epstein they were 18.37 Lourie asked for Menchel's \"very general opinion as to whether this is a case you think the office should do,\" and reminded Menchel that the State Attorney's Office \"went out of their way to get a no-bill on this . . . and thus only charged adult solicitation, which they would bargain away to nothing.\"\nDuring his OPR interview, Menchel said that Lourie's email transmitting the prosecution memorandum was his \"official introduction\" to the case and at that point in time, he had never heard of Epstein and had no information about his background. He recalled that the USAO had been asked to review the case because the state had not handled it appropriately. Menchel told OPR, however, that he had little memory about the facts of the case or what contemporaneous opinions he formed about it.\nAcosta told OPR that he could not recall whether he ever read Villafaña's prosecution memorandum, explaining that he \"would typically rely on senior staff,\" who had more prosecutorial experience, and that instead of reading the memorandum, he may have discussed the case with Sloman, Menchel, and Lourie, who he assumed would have read the document. Acosta\n37    In various submissions to the USAO, the defense contended that the federal statute required proof that engaging in a sexual act was the \"paramount or dominant purpose\" of Epstein's travel, but that Epstein's travel was motivated by his desire to live outside of New York for over half of each year for tax purposes. The defense also asserted that the federal statutes at issue required proof that the defendant knew the victims were under 18, but that Epstein \"took affirmative steps to ensure that every woman was at least 18 years of age.\" In her prosecution memorandum, however, Villafaña set forth her conclusion that the statute only required proof that engaging in a sexual act was one of the motivating factors for the travel. She also concluded that the statutes did not require proof that the defendant knew the victims were minors.\n26\nDOJ-OGR-00003228",
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      "content": "Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 52 of 348",
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    {
      "type": "printed",
      "content": "forward with charges in this case. Lourie forwarded a copy of the prosecution memorandum to Menchel. Lourie's transmittal message read:\nMarie did a 50 [sic] page pros memo in the Epstein case. I am going to start reading it tonight. . . . It's a major case because the target is one of the richest men in the country and it has been big news. He has a stable of attorneys, including Dershowitz, [Roy] Black, Lefcourt, Lewis, and Lily [sic] Sanchez. Jeff Sloman is familiar with the investigation. The state intentionally torpedoed it in the grand jury so it was brought to us. I am going to forward the pros memo to you so you can start reading it at the same time I do. The FBI is pushing to do it in Mid [sic] May, which I think is not critical, but we might as well get a jump on it. I have some ideas about the indictment (needs to be ultra lean with only clean victims), so I am not sending that yet.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Lourie explained to OPR that by \"clean\" victims, he meant those for whom the defense did not have impeachment evidence to use against them.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "A few days later, Lourie emailed Menchel, asking if Menchel had read the prosecution memorandum. Lourie directed Menchel's attention to particular pages of the prosecution memorandum, noting that the \"keys\" were whether the USAO could prove that Epstein traveled for the purpose of engaging in sexual acts, and the fact that some minor victims told Epstein they were 18.37 Lourie asked for Menchel's \"very general opinion as to whether this is a case you think the office should do,\" and reminded Menchel that the State Attorney's Office \"went out of their way to get a no-bill on this . . . and thus only charged adult solicitation, which they would bargain away to nothing.\"",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "During his OPR interview, Menchel said that Lourie's email transmitting the prosecution memorandum was his \"official introduction\" to the case and at that point in time, he had never heard of Epstein and had no information about his background. He recalled that the USAO had been asked to review the case because the state had not handled it appropriately. Menchel told OPR, however, that he had little memory about the facts of the case or what contemporaneous opinions he formed about it.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Acosta told OPR that he could not recall whether he ever read Villafaña's prosecution memorandum, explaining that he \"would typically rely on senior staff,\" who had more prosecutorial experience, and that instead of reading the memorandum, he may have discussed the case with Sloman, Menchel, and Lourie, who he assumed would have read the document. Acosta",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "37    In various submissions to the USAO, the defense contended that the federal statute required proof that engaging in a sexual act was the \"paramount or dominant purpose\" of Epstein's travel, but that Epstein's travel was motivated by his desire to live outside of New York for over half of each year for tax purposes. The defense also asserted that the federal statutes at issue required proof that the defendant knew the victims were under 18, but that Epstein \"took affirmative steps to ensure that every woman was at least 18 years of age.\" In her prosecution memorandum, however, Villafaña set forth her conclusion that the statute only required proof that engaging in a sexual act was one of the motivating factors for the travel. She also concluded that the statutes did not require proof that the defendant knew the victims were minors.",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "26",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003228",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Lourie",
      "Menchel",
      "Marie",
      "Dershowitz",
      "Roy Black",
      "Lefcourt",
      "Lewis",
      "Lily Sanchez",
      "Jeff Sloman",
      "Epstein",
      "Villafaña",
      "Acosta"
    ],
    "organizations": [
      "USAO",
      "FBI",
      "State Attorney's Office",
      "OPR"
    ],
    "locations": [
      "New York"
    ],
    "dates": [
      "04/16/21",
      "Mid May"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "204-3",
      "DOJ-OGR-00003228"
    ]
  },
  "additional_notes": "The document appears to be a court document related to the Epstein case. The text is mostly printed, with some footnotes and a header/footer. There are no visible stamps or handwritten text."
}