{
  "document_metadata": {
    "page_number": "236",
    "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 236 of 348\n\nfor [victims] to enhance their stories\" and that the defense would try to have Villafaña or the case agents removed from the case.\n\nBoth the lead case agent and Villafaña told OPR that after the FBI raised with Villafaña the concern that notifying the victims would create potential impeachment material in the event of a breach and subsequent trial, they contacted the USAO's Professional Responsibility Officer for advice. Villafaña recalled that during a brief telephone consultation, the Professional Responsibility Officer advised her and the case agent that \"it's not really that big a concern, but if you're concerned about it then you should stop making the notification.\"305 In her 2017 CVRA declaration, the case agent stated that after conferring with the USAO, the case agents stopped notifying victims about the NPA.\n\nB. October 2007: Defense Attorneys Object to Government Victim Notifications\n\nWhile the case agents and Villafaña considered the impact that notifying the victims about the resolution of the case might have on a potential trial, defense counsel also raised concerns about what the victims could be told about the NPA. As discussed in Chapter Two, after the NPA was signed on September 24, 2007, the USAO proposed using a special master to select the attorney representative for the victims, which led to further discussions about the § 2255 provision. On October 5, 2007, when defense attorney Lefkowitz sent Villafaña a letter responding to the USAO's proposal to use a special master, he cautioned that \"neither federal agents nor anyone from your Office should contact the identified individuals to inform them of the resolution of the case\" because such communications would \"violate the confidentiality of the agreement\" and would prevent Epstein from having control over \"what is communicated to the identified individuals at this most critical stage.\" Lefkowitz followed this communication with an October 10, 2007 letter to Acosta, arguing that \"[n]either federal agents nor anyone from your Office should contact the identified individuals to inform them of the resolution of the case.\"306 Rather, Lefkowitz wanted to \"participate in crafting a mutually acceptable communication to the identified individuals.\"\n\nOn October 23, 2007, Villafaña raised the issue of victim notification with Sloman, stating:\n\nWe also have to contact the victims to tell [them] about the outcome of the case and to advise them that an attorney will be contacting them regarding possible claims against Mr. Epstein. If we don't do that, it may be a violation of the Florida Bar Rules for the selected attorney to 'cold call' the girls.\n\nAs discussed in greater detail in Chapter Two, on October 23, 2007, Lefkowitz sent Acosta a letter stating that Epstein expected to enter a guilty plea in state court on November 20, 2007,\n\n305 The Professional Responsibility Officer told OPR that he did not recall the case agent contacting him about victim notification, nor did he recall being involved in the Epstein matter before the CVRA litigation was instituted in July 2008 and he was assigned to handle the litigation. Villafaña told OPR that they consulted the Professional Responsibility Officer over the telephone, the call took no more than \"five minutes,\" and the Professional Responsibility Officer had no other exposure to the case and thus \"wouldn't have [any] context for it.\"\n\n306 Lefkowitz also argued that direct contact with the victims could violate grand jury secrecy rules.\n\n210\n\nDOJ-OGR-00003412",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 236 of 348",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "for [victims] to enhance their stories\" and that the defense would try to have Villafaña or the case agents removed from the case.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Both the lead case agent and Villafaña told OPR that after the FBI raised with Villafaña the concern that notifying the victims would create potential impeachment material in the event of a breach and subsequent trial, they contacted the USAO's Professional Responsibility Officer for advice. Villafaña recalled that during a brief telephone consultation, the Professional Responsibility Officer advised her and the case agent that \"it's not really that big a concern, but if you're concerned about it then you should stop making the notification.\"305 In her 2017 CVRA declaration, the case agent stated that after conferring with the USAO, the case agents stopped notifying victims about the NPA.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "B. October 2007: Defense Attorneys Object to Government Victim Notifications",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "While the case agents and Villafaña considered the impact that notifying the victims about the resolution of the case might have on a potential trial, defense counsel also raised concerns about what the victims could be told about the NPA. As discussed in Chapter Two, after the NPA was signed on September 24, 2007, the USAO proposed using a special master to select the attorney representative for the victims, which led to further discussions about the § 2255 provision. On October 5, 2007, when defense attorney Lefkowitz sent Villafaña a letter responding to the USAO's proposal to use a special master, he cautioned that \"neither federal agents nor anyone from your Office should contact the identified individuals to inform them of the resolution of the case\" because such communications would \"violate the confidentiality of the agreement\" and would prevent Epstein from having control over \"what is communicated to the identified individuals at this most critical stage.\" Lefkowitz followed this communication with an October 10, 2007 letter to Acosta, arguing that \"[n]either federal agents nor anyone from your Office should contact the identified individuals to inform them of the resolution of the case.\"306 Rather, Lefkowitz wanted to \"participate in crafting a mutually acceptable communication to the identified individuals.\"",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "On October 23, 2007, Villafaña raised the issue of victim notification with Sloman, stating:\n\nWe also have to contact the victims to tell [them] about the outcome of the case and to advise them that an attorney will be contacting them regarding possible claims against Mr. Epstein. If we don't do that, it may be a violation of the Florida Bar Rules for the selected attorney to 'cold call' the girls.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "As discussed in greater detail in Chapter Two, on October 23, 2007, Lefkowitz sent Acosta a letter stating that Epstein expected to enter a guilty plea in state court on November 20, 2007,",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "305 The Professional Responsibility Officer told OPR that he did not recall the case agent contacting him about victim notification, nor did he recall being involved in the Epstein matter before the CVRA litigation was instituted in July 2008 and he was assigned to handle the litigation. Villafaña told OPR that they consulted the Professional Responsibility Officer over the telephone, the call took no more than \"five minutes,\" and the Professional Responsibility Officer had no other exposure to the case and thus \"wouldn't have [any] context for it.\"\n\n306 Lefkowitz also argued that direct contact with the victims could violate grand jury secrecy rules.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "210",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003412",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Villafaña",
      "Lefkowitz",
      "Acosta",
      "Sloman",
      "Epstein"
    ],
    "organizations": [
      "FBI",
      "USAO",
      "OPR"
    ],
    "locations": [],
    "dates": [
      "04/16/21",
      "September 24, 2007",
      "October 5, 2007",
      "October 10, 2007",
      "October 23, 2007",
      "November 20, 2007",
      "July 2008"
    ],
    "reference_numbers": [
      "Case 1:20-cr-00330-PAE",
      "Document 204-3",
      "DOJ-OGR-00003412"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the Epstein case. The text is mostly printed, with no handwritten content or stamps visible. The document is well-formatted and legible."
}