{
  "document_metadata": {
    "page_number": "173",
    "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 173 of 348\nd[id]n't want to have to relive what happened to them.\"217 The co-case agent told OPR that one of the \"strategies\" for dealing with the victims' fear was \"to keep them off the stand,\" and he generally remembered discussions about resolving the Epstein case in a way that protected the victims' identities. In addition, the CEOS Trial Attorney who briefly worked with Villafaña on the case after the NPA was signed told OPR that in her meetings with some of the victims, she formed the impression that they were not interested in the prosecution going forward. The CEOS Trial Attorney told OPR that \"[the victims] would have testified,\" but would have required an extensive amount of \"victim management\" because they were \"deeply embarrassed\" about potentially being labeled as prostitutes. The CEOS Trial Attorney also told OPR that \"there were obvious weaknesses in the case,\" from an evidentiary perspective.218\n\nThe contemporaneous records also reflect discussions of, or references to, various legal and factual issues or other concerns about the case. For example, in an early email to Menchel, Lourie noted that two key issues raised by Villafaña's proposed charges were whether the USAO could prove that Epstein traveled for the purpose of engaging in sex acts, and the fact that some minor victims had told Epstein they were 18. He later opined to Acosta and Menchel that \"there is some risk on some of the statutes [proposed in Villafaña's prosecution memorandum] as this is uncharted territory to some degree.\" In his July 5, 2007 email to Villafaña, Menchel cited Acosta's and Sloman's \"concerns about taking this case because of [the P]etit policy and a number of legal issues\" and Acosta's concerns about \"hurting Project Safe Childhood.\" Defense counsel raised myriad legal and factual challenges in their voluminous letters to the USAO. Defense submissions attacked the legal theories for a federal prosecution and detailed factors that could have undermined victims' credibility, including victim statements favorable to Epstein and evidence of victim drug and alcohol use, as well as the fact that some victims recruited other victims and purportedly lied to Epstein about their ages.\n\nAcosta also recalled that although his \"team\" had expressed concern about the \"trial issues,\" his own focus had been on \"the legal side of things.\" Notably, during his prior tenure as the Assistant Attorney General in charge of the Department's Civil Rights Division, Acosta had been involved in efforts to address sex trafficking. He told OPR that one of the \"background issues\" that the Civil Rights Division addressed under his leadership, and which influenced his view of the Epstein case, was the distinction between sex trafficking and solicitation of prostitution. Specifically, he was concerned about avoiding the creation of potentially unfavorable federal precedent on the point of delineation between prostitution, which was traditionally a matter of state concern, and sex trafficking, which remained a developing area of federal interest in 2007.219\n\n217 In an affidavit filed in the CVRA litigation, the co-case agent noted that in early 2007, when he located a victim living outside of the United States, she claimed only to \"know Jeffrey Epstein,\" and stated that she \"moved away to distance herself from this situation,\" and \"asked that [the agent] not bother her with this again.\"\n218 In April 2007, a victim who was represented by an attorney paid by Epstein participated in a video-recorded interview with the FBI, with her attorney and his investigator present. This victim denied being involved in, or being a victim of, criminal activity. Later, the victim obtained new counsel and joined the CVRA litigation as \"Jane Doe #2.\"\n219 In his March 20, 2011 letter, addressed \"To whom it may concern,\" and published online in The Daily Beast, Acosta described \"a year-long assault on the prosecution and the prosecutors\" by \"an army of legal superstars.\" Most of the allegations made against the prosecutors occurred after the NPA was signed and certainly after Acosta approved\n\n147\nDOJ-OGR-00003349",
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      "content": "Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 173 of 348",
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      "content": "d[id]n't want to have to relive what happened to them.\"217 The co-case agent told OPR that one of the \"strategies\" for dealing with the victims' fear was \"to keep them off the stand,\" and he generally remembered discussions about resolving the Epstein case in a way that protected the victims' identities. In addition, the CEOS Trial Attorney who briefly worked with Villafaña on the case after the NPA was signed told OPR that in her meetings with some of the victims, she formed the impression that they were not interested in the prosecution going forward. The CEOS Trial Attorney told OPR that \"[the victims] would have testified,\" but would have required an extensive amount of \"victim management\" because they were \"deeply embarrassed\" about potentially being labeled as prostitutes. The CEOS Trial Attorney also told OPR that \"there were obvious weaknesses in the case,\" from an evidentiary perspective.218",
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      "content": "The contemporaneous records also reflect discussions of, or references to, various legal and factual issues or other concerns about the case. For example, in an early email to Menchel, Lourie noted that two key issues raised by Villafaña's proposed charges were whether the USAO could prove that Epstein traveled for the purpose of engaging in sex acts, and the fact that some minor victims had told Epstein they were 18. He later opined to Acosta and Menchel that \"there is some risk on some of the statutes [proposed in Villafaña's prosecution memorandum] as this is uncharted territory to some degree.\" In his July 5, 2007 email to Villafaña, Menchel cited Acosta's and Sloman's \"concerns about taking this case because of [the P]etit policy and a number of legal issues\" and Acosta's concerns about \"hurting Project Safe Childhood.\" Defense counsel raised myriad legal and factual challenges in their voluminous letters to the USAO. Defense submissions attacked the legal theories for a federal prosecution and detailed factors that could have undermined victims' credibility, including victim statements favorable to Epstein and evidence of victim drug and alcohol use, as well as the fact that some victims recruited other victims and purportedly lied to Epstein about their ages.",
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      "content": "Acosta also recalled that although his \"team\" had expressed concern about the \"trial issues,\" his own focus had been on \"the legal side of things.\" Notably, during his prior tenure as the Assistant Attorney General in charge of the Department's Civil Rights Division, Acosta had been involved in efforts to address sex trafficking. He told OPR that one of the \"background issues\" that the Civil Rights Division addressed under his leadership, and which influenced his view of the Epstein case, was the distinction between sex trafficking and solicitation of prostitution. Specifically, he was concerned about avoiding the creation of potentially unfavorable federal precedent on the point of delineation between prostitution, which was traditionally a matter of state concern, and sex trafficking, which remained a developing area of federal interest in 2007.219",
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      "content": "217 In an affidavit filed in the CVRA litigation, the co-case agent noted that in early 2007, when he located a victim living outside of the United States, she claimed only to \"know Jeffrey Epstein,\" and stated that she \"moved away to distance herself from this situation,\" and \"asked that [the agent] not bother her with this again.\"\n218 In April 2007, a victim who was represented by an attorney paid by Epstein participated in a video-recorded interview with the FBI, with her attorney and his investigator present. This victim denied being involved in, or being a victim of, criminal activity. Later, the victim obtained new counsel and joined the CVRA litigation as \"Jane Doe #2.\"\n219 In his March 20, 2011 letter, addressed \"To whom it may concern,\" and published online in The Daily Beast, Acosta described \"a year-long assault on the prosecution and the prosecutors\" by \"an army of legal superstars.\" Most of the allegations made against the prosecutors occurred after the NPA was signed and certainly after Acosta approved",
      "position": "footer"
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    {
      "type": "printed",
      "content": "147",
      "position": "footer"
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    {
      "type": "printed",
      "content": "DOJ-OGR-00003349",
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  ],
  "entities": {
    "people": [
      "Jeffrey Epstein",
      "Villafaña",
      "Menchel",
      "Lourie",
      "Acosta",
      "Sloman"
    ],
    "organizations": [
      "USAO",
      "FBI",
      "Department's Civil Rights Division",
      "CVRA"
    ],
    "locations": [
      "United States"
    ],
    "dates": [
      "04/16/21",
      "July 5, 2007",
      "March 20, 2011",
      "April 2007",
      "early 2007"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "204-3",
      "DOJ-OGR-00003349"
    ]
  },
  "additional_notes": "The document appears to be a court document related to the Jeffrey Epstein case. It contains discussions about the case, including the victims' identities, the prosecution, and the legal challenges faced. The document is well-formatted and free of significant damage or redactions."
}