{
  "document_metadata": {
    "page_number": "136",
    "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 136 of 348\n\nOn Monday, June 23, 2008, Roth sent a brief letter to Starr and Lefkowitz informing them that the office had \"completed a thorough review\" of the USAO's handling of the Epstein matter and did not believe intervention by the Deputy Attorney General was warranted in view of the \"considerable discretion\" vested by the Department in U.S. Attorneys. He added, \"Even if we were to substitute our judgment for that of the U.S. Attorney, we believe that federal prosecution of this case is appropriate.\"\n\nImmediately after receiving a copy of Roth's letter, Villafaña notified defense counsel that Epstein would have until close of business on Monday, June 30, 2008, to comply with the NPA by entering his guilty plea, being sentenced, and surrendering to begin serving his sentence. On June 26, 2008, Roth alerted the Office of the Attorney General that Epstein's counsel might try to contact the Attorney General to request additional review and urged the Attorney General not to take defense counsel's calls. Roth told OPR that he was concerned that Epstein's team would try to take a further appeal in order to delay resolution of the case.\n\nMeanwhile, Starr sent a concluding email to Acosta, acknowledging they had reached \"the end of a long and arduous road\" and adding, \"While I am obviously very unhappy at what I believe is the government's treatment of my client, a man whom I have come to deeply admire, I recognize that we have filed and argued our 'appellate motions' and lost. . . . I would like to have . . . some closure with you on this matter so that in the years to come, neither of us will harbor any ill will over the matter.\"\n\nX. JUNE 2008 - JUNE 2009: EPSTEIN ENTERS HIS PLEAS AND SERVES HIS CUSTODIAL SENTENCE\n\nOn Friday, June 27, 2008, Villafaña renewed her requests to Epstein's local attorneys Goldberger and Black for a copy of the state plea agreement reached with the State Attorney's Office, noting that their failure to provide it was a material breach of the NPA. After receiving and reviewing the plea agreement form, which was not yet signed, Villafaña sent another letter to Goldberger and Black, informing them that the proposed sentencing provision did not comply with the requirements of the NPA. Specifically, as written, the plea agreement called for a sentence of 12 months in \"the Palm Beach County Detention Facility,\" followed consecutively by \"18 months Community Control\" with a special condition that the defendant serve \"the first 6 months [of community control] in the Palm Beach County Detention Facility.\" Villafaña objected to the community control provision, reminding Goldberger and Black that the NPA required Epstein to \"make a binding recommendation of eighteen months imprisonment, which means confinement twenty-four hours a day at the County Jail.\" In a subsequent email to Sloman, Villafaña recounted that she had spoken about the issue with Goldberger, who \"swore\" that Epstein would be in custody 24-hours-a-day during the community confinement portion of his sentence.\" Villafaña added that Goldberger \"let it slip that Epstein would not be at the jail, he would be at the stockade . . . . Since we specifically discussed this at the meeting with [the State Attorney] months ago that Epstein would be at [the jail], this certainly violates the spirit of the [NPA] agreement.\"172\n\n172 The Main Detention Center for Palm Beach County is a facility housing maximum, medium, and minimum custody adult males, as well as juvenile and special population male and female inmates. See 110\n\nDOJ-OGR-00003312",
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    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 136 of 348",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "On Monday, June 23, 2008, Roth sent a brief letter to Starr and Lefkowitz informing them that the office had \"completed a thorough review\" of the USAO's handling of the Epstein matter and did not believe intervention by the Deputy Attorney General was warranted in view of the \"considerable discretion\" vested by the Department in U.S. Attorneys. He added, \"Even if we were to substitute our judgment for that of the U.S. Attorney, we believe that federal prosecution of this case is appropriate.\"",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Immediately after receiving a copy of Roth's letter, Villafaña notified defense counsel that Epstein would have until close of business on Monday, June 30, 2008, to comply with the NPA by entering his guilty plea, being sentenced, and surrendering to begin serving his sentence. On June 26, 2008, Roth alerted the Office of the Attorney General that Epstein's counsel might try to contact the Attorney General to request additional review and urged the Attorney General not to take defense counsel's calls. Roth told OPR that he was concerned that Epstein's team would try to take a further appeal in order to delay resolution of the case.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Meanwhile, Starr sent a concluding email to Acosta, acknowledging they had reached \"the end of a long and arduous road\" and adding, \"While I am obviously very unhappy at what I believe is the government's treatment of my client, a man whom I have come to deeply admire, I recognize that we have filed and argued our 'appellate motions' and lost. . . . I would like to have . . . some closure with you on this matter so that in the years to come, neither of us will harbor any ill will over the matter.\"",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "X. JUNE 2008 - JUNE 2009: EPSTEIN ENTERS HIS PLEAS AND SERVES HIS CUSTODIAL SENTENCE",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "On Friday, June 27, 2008, Villafaña renewed her requests to Epstein's local attorneys Goldberger and Black for a copy of the state plea agreement reached with the State Attorney's Office, noting that their failure to provide it was a material breach of the NPA. After receiving and reviewing the plea agreement form, which was not yet signed, Villafaña sent another letter to Goldberger and Black, informing them that the proposed sentencing provision did not comply with the requirements of the NPA. Specifically, as written, the plea agreement called for a sentence of 12 months in \"the Palm Beach County Detention Facility,\" followed consecutively by \"18 months Community Control\" with a special condition that the defendant serve \"the first 6 months [of community control] in the Palm Beach County Detention Facility.\" Villafaña objected to the community control provision, reminding Goldberger and Black that the NPA required Epstein to \"make a binding recommendation of eighteen months imprisonment, which means confinement twenty-four hours a day at the County Jail.\" In a subsequent email to Sloman, Villafaña recounted that she had spoken about the issue with Goldberger, who \"swore\" that Epstein would be in custody 24-hours-a-day during the community confinement portion of his sentence.\" Villafaña added that Goldberger \"let it slip that Epstein would not be at the jail, he would be at the stockade . . . . Since we specifically discussed this at the meeting with [the State Attorney] months ago that Epstein would be at [the jail], this certainly violates the spirit of the [NPA] agreement.\"172",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "172 The Main Detention Center for Palm Beach County is a facility housing maximum, medium, and minimum custody adult males, as well as juvenile and special population male and female inmates. See 110",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003312",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Roth",
      "Starr",
      "Lefkowitz",
      "Villafaña",
      "Epstein",
      "Goldberger",
      "Black",
      "Acosta",
      "Sloman"
    ],
    "organizations": [
      "USAO",
      "Department of Justice",
      "State Attorney's Office",
      "Palm Beach County Detention Facility"
    ],
    "locations": [
      "Palm Beach County",
      "Palm Beach County Detention Facility"
    ],
    "dates": [
      "June 23, 2008",
      "June 30, 2008",
      "June 26, 2008",
      "June 27, 2008",
      "April 16, 2021"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 204-3",
      "DOJ-OGR-00003312"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the Jeffrey Epstein case. The text is printed and there are no visible stamps or handwritten notes. The document is page 136 of 348."
}