{
  "document_metadata": {
    "page_number": "95",
    "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 95 of 348\n\nto the assault charge\" and suggesting a different factual scenario to support a federal charge.112 At this point, Sloman left on vacation, and he informed Acosta and Villafaña that in his absence Lourie had agreed \"to help finalize this.\" Lourie spent the following work week at his new post at the Department in Washington, D.C., but communicated with his USAO colleagues by phone and email.\n\nIn a Sunday, September 16, 2007 email, Villafaña informed Lefkowitz that she had drafted a factual proffer to accompany a revised \"hybrid\" federal plea proposal. In that email, Villafaña also noted that she was considering filing charges in the federal district court in Miami, \"which will hopefully cut the press coverage significantly.\" This email received considerable attention 12 years later when it was made public during the CVRA litigation and was viewed as evidence of the USAO's efforts to conceal the NPA from the victims. Villafaña, however, explained to OPR that she was concerned that news media coverage would violate the victims' privacy. She told OPR, \"[I]f [the victims] wanted to attend [the plea hearing], I wanted them to be able to go into the courthouse without their faces being splashed all over the newspaper,\" and that such publicity was less likely to happen in Miami, where the press \"in general does not care about what happens in Palm Beach.\"\n\nLefkowitz responded to Villafaña with a revised version of her latest proposed \"hybrid\" plea agreement, in a document entitled \"Agreement.\" Significantly, this defense proposal introduced two new provisions. The first related to four female assistants who had allegedly facilitated Epstein in his criminal scheme. The defense sought a government promise not to prosecute them, as well as certain other unnamed Epstein employees, and a promise to forego immigration proceedings against two of the female assistants:\n\nEpstein's fulfilling the terms and conditions of the Agreement also precludes the initiation of any and all criminal charges which might otherwise in the future be brought against [four named female assistants] or any employee of [a specific Epstein-owned corporate entity] for any criminal charge that arises out of the ongoing federal investigation . . . Further, no immigration proceeding will be instituted against [two named female assistants] as a result of the ongoing investigation.\n\nThe second new provision related to the USAO's efforts to obtain Epstein's computers:\n\nEpstein's fulfilling the terms and conditions of the Agreement resolves any and all outstanding [legal process] that have requested witness testimony and/or the production of documents and/or computers in relation to the investigation that is the subject of the Agreement. Each [legal process] will be withdrawn upon the execution of the Agreement and will not be re-issued absent reliable\n\n112 Villafaña told OPR that she sometimes used her home email account because \"[n]egotiations were occurring at nights, on weekend[s], and while I was [away from the office for personal reasons], . . . and this occurred during a time when out of office access to email was very limited.\" Records show her supervisors were aware that at times she used her personal email account in communicating with defense counsel in this case.\n\n69\nDOJ-OGR-00003271",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 95 of 348",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "to the assault charge\" and suggesting a different factual scenario to support a federal charge.112 At this point, Sloman left on vacation, and he informed Acosta and Villafaña that in his absence Lourie had agreed \"to help finalize this.\" Lourie spent the following work week at his new post at the Department in Washington, D.C., but communicated with his USAO colleagues by phone and email.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "In a Sunday, September 16, 2007 email, Villafaña informed Lefkowitz that she had drafted a factual proffer to accompany a revised \"hybrid\" federal plea proposal. In that email, Villafaña also noted that she was considering filing charges in the federal district court in Miami, \"which will hopefully cut the press coverage significantly.\" This email received considerable attention 12 years later when it was made public during the CVRA litigation and was viewed as evidence of the USAO's efforts to conceal the NPA from the victims. Villafaña, however, explained to OPR that she was concerned that news media coverage would violate the victims' privacy. She told OPR, \"[I]f [the victims] wanted to attend [the plea hearing], I wanted them to be able to go into the courthouse without their faces being splashed all over the newspaper,\" and that such publicity was less likely to happen in Miami, where the press \"in general does not care about what happens in Palm Beach.\"",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Lefkowitz responded to Villafaña with a revised version of her latest proposed \"hybrid\" plea agreement, in a document entitled \"Agreement.\" Significantly, this defense proposal introduced two new provisions. The first related to four female assistants who had allegedly facilitated Epstein in his criminal scheme. The defense sought a government promise not to prosecute them, as well as certain other unnamed Epstein employees, and a promise to forego immigration proceedings against two of the female assistants:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Epstein's fulfilling the terms and conditions of the Agreement also precludes the initiation of any and all criminal charges which might otherwise in the future be brought against [four named female assistants] or any employee of [a specific Epstein-owned corporate entity] for any criminal charge that arises out of the ongoing federal investigation . . . Further, no immigration proceeding will be instituted against [two named female assistants] as a result of the ongoing investigation.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The second new provision related to the USAO's efforts to obtain Epstein's computers:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Epstein's fulfilling the terms and conditions of the Agreement resolves any and all outstanding [legal process] that have requested witness testimony and/or the production of documents and/or computers in relation to the investigation that is the subject of the Agreement. Each [legal process] will be withdrawn upon the execution of the Agreement and will not be re-issued absent reliable",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "112 Villafaña told OPR that she sometimes used her home email account because \"[n]egotiations were occurring at nights, on weekend[s], and while I was [away from the office for personal reasons], . . . and this occurred during a time when out of office access to email was very limited.\" Records show her supervisors were aware that at times she used her personal email account in communicating with defense counsel in this case.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "69",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003271",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Sloman",
      "Acosta",
      "Villafaña",
      "Lourie",
      "Lefkowitz",
      "Epstein"
    ],
    "organizations": [
      "USAO",
      "OPR",
      "Department"
    ],
    "locations": [
      "Washington, D.C.",
      "Miami",
      "Palm Beach"
    ],
    "dates": [
      "September 16, 2007",
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204-3",
      "DOJ-OGR-00003271"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the Epstein case, discussing the negotiations and agreements surrounding his plea deal. The text is printed and clear, with no visible handwriting or stamps."
}