mirror-epstein-docs/results/IMAGES011/DOJ-OGR-00030483.json

{
  "document_metadata": {
    "page_number": "16",
    "document_number": "17-295",
    "date": "June 5, 2006",
    "document_type": "Letter",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "LAW OFFICES OF\nGerald B. Lefcourt, P.C.\nA PROFESSIONAL CORPORATION\n148 EAST 78TH STREET\nNEW YORK, NEW YORK 10021\n\nGERALD B. LEFCOURT\nlefcout@lefcoutlaw.com\n\nSHERYL E. REICH\nreich@lefcoutlaw.com\nRENATO C. STABILE\nstabile@lefcoutlaw.com\nFAITH A. FRIEDMAN\nffriedman@lefcoutlaw.com\n\nTELEPHONE\n(212) 737-0400\nFACSIMILE\n(212) 988-6192\n\nJune 5, 2006\n\nBY HAND\n\nLanna Belohlavek\nFlorida State Attorney's Office\n401 North Dixie Highway\nWest Palm Beach, FL 33401\n\nRe: Jeffrey Epstein\n\nDear Ms. Belohlavek:\n\nAs a follow up to our meeting of June 1, 2006, held in an attempt to resolve this matter, we write to address the following issues which have arisen: (1) the risk, were the client to plead to aggravated assault in Florida, that he might be subject to sex-offender registration statutes in other jurisdictions, now or in the future; (2) the nature of the charge of felony \"aggravated assault with intent to commit a felony,\" and how it does not reflect the allegations herein; and, (3) whether a felony conviction itself is justified based on the available evidence.\n\nAt the outset of our June 1, 2006 meeting, we were mindful that an understanding had been reached with prior counsel. It was reached, however, with the clear and joint understanding that the client would not be subjected to sex offender registration requirements in any state or foreign jurisdiction. Moreover, the limited time provided did not allow for an opportunity to conduct an even cursory investigation or research into the ramifications. Were any charge to be brought, having now learned of the serious danger a plea to felony aggravated assault presents with regard to sex offender registration, coupled with the facts presented at our meeting and outlined below, we strongly believe that a plea to misdemeanor solicitation is the more appropriate resolution. As we discussed, this could include an agreed upon allocution, as we are mindful of your concern about labeling the girls \"prostitutes.\" In this regard, as we discussed, the law and relevant statute are clear that the complaining witness need not be a \"prostitute\" in order to satisfy the elements of the offense.\n\n07/26/17   Page 16 of 131   Public Records Request No.: 17-295   DOJ-OGR-00030483",
  "text_blocks": [
    {
      "type": "printed",
      "content": "LAW OFFICES OF\nGerald B. Lefcourt, P.C.\nA PROFESSIONAL CORPORATION\n148 EAST 78TH STREET\nNEW YORK, NEW YORK 10021",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "GERALD B. LEFCOURT\nlefcout@lefcoutlaw.com\n\nSHERYL E. REICH\nreich@lefcoutlaw.com\nRENATO C. STABILE\nstabile@lefcoutlaw.com\nFAITH A. FRIEDMAN\nffriedman@lefcoutlaw.com",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "TELEPHONE\n(212) 737-0400\nFACSIMILE\n(212) 988-6192",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "June 5, 2006",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "BY HAND\n\nLanna Belohlavek\nFlorida State Attorney's Office\n401 North Dixie Highway\nWest Palm Beach, FL 33401",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Re: Jeffrey Epstein",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Dear Ms. Belohlavek:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "As a follow up to our meeting of June 1, 2006, held in an attempt to resolve this matter, we write to address the following issues which have arisen: (1) the risk, were the client to plead to aggravated assault in Florida, that he might be subject to sex-offender registration statutes in other jurisdictions, now or in the future; (2) the nature of the charge of felony \"aggravated assault with intent to commit a felony,\" and how it does not reflect the allegations herein; and, (3) whether a felony conviction itself is justified based on the available evidence.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "At the outset of our June 1, 2006 meeting, we were mindful that an understanding had been reached with prior counsel. It was reached, however, with the clear and joint understanding that the client would not be subjected to sex offender registration requirements in any state or foreign jurisdiction. Moreover, the limited time provided did not allow for an opportunity to conduct an even cursory investigation or research into the ramifications. Were any charge to be brought, having now learned of the serious danger a plea to felony aggravated assault presents with regard to sex offender registration, coupled with the facts presented at our meeting and outlined below, we strongly believe that a plea to misdemeanor solicitation is the more appropriate resolution. As we discussed, this could include an agreed upon allocution, as we are mindful of your concern about labeling the girls \"prostitutes.\" In this regard, as we discussed, the law and relevant statute are clear that the complaining witness need not be a \"prostitute\" in order to satisfy the elements of the offense.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "07/26/17   Page 16 of 131   Public Records Request No.: 17-295   DOJ-OGR-00030483",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Gerald B. Lefcourt",
      "Sheryl E. Reich",
      "Renato C. Stabile",
      "Faith A. Friedman",
      "Lanna Belohlavek",
      "Jeffrey Epstein"
    ],
    "organizations": [
      "Law Offices of Gerald B. Lefcourt, P.C.",
      "Florida State Attorney's Office"
    ],
    "locations": [
      "New York",
      "Florida",
      "West Palm Beach"
    ],
    "dates": [
      "June 5, 2006",
      "June 1, 2006",
      "07/26/17"
    ],
    "reference_numbers": [
      "17-295",
      "DOJ-OGR-00030483"
    ]
  },
  "additional_notes": "The document appears to be a letter from the Law Offices of Gerald B. Lefcourt, P.C. to Lanna Belohlavek of the Florida State Attorney's Office, discussing the case of Jeffrey Epstein. The letter is dated June 5, 2006, and is marked as 'BY HAND'. The document is page 16 of 131 and is associated with a Public Records Request No.: 17-295."
}