mirror-epstein-docs/results/IMAGES002/DOJ-OGR-00003295.json

{
  "document_metadata": {
    "page_number": "119",
    "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 119 of 348\n\n... \n\nWhy don't we agree to mutual recission [sic] and indict him?\n\nAcosta also weighed in, sending both Villafaña and Sloman an email with a subject line that read \"This has to stop,\" in which he stated:\n\nJust read the letter.\n\n1. We specifically refused to include the provision saying that we would not communicate. If I recall the conference call, we told him we could not agree to a gag order using those words.\n\n2. The purpose of the agreement was not an out of court settlement. Seems that they can't take no. Let's talk re how to proceed. I'm not sure we will ever agree on a letter [to the special master about how to select an attorney representative] at this point.\n\nNotwithstanding Acosta's assessment and prediction, after Sloman sent to Lefkowitz a new draft addendum and they spoke by phone, the parties reached agreement on the addendum's terms.147\n\nOn October 25, 2007, Sloman sent a letter to the person whom the USAO had selected to serve as special master, outlining the special master's duties. A few days later, on October 29, 2007, Epstein and his attorneys Lefcourt and Sanchez signed the NPA addendum.148 Villafaña's name was printed as the USAO representative, but at Villafaña's request, Sloman signed the addendum for her on behalf of the USAO.\n\nVillafaña later emailed Sloman thanking him for \"the advice and the pep talk,\" which apparently related to the defense attorneys' allegation of impropriety concerning her initial selection of the private attorney to assist the victims. Villafaña explained to Sloman:\n\nThe funny thing is that I had never met (and still haven't met) or spoken to [the private attorney] before I asked him if he would be willing to take on this case. . . . But as soon as you mentioned the appearance problem, I saw where the problem would arise and agreed that the Special Master would be a safer route. I just worry that the defense's attacks on me could harm the victims.\n\nSloman responded that defense counsel had \"put an . . . insidious spin\" on Villafaña's role in proposing the private attorney, but Sloman added, \"I hope that you understand that these ad hominem attacks against you do not diminish in our eyes what you and the agents have accomplished.\"\n\n147 Acosta and Villafaña were copied on this email.\n148 The Addendum is attached as Exhibit 4 to this Report.",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 119 of 348",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "... \n\nWhy don't we agree to mutual recission [sic] and indict him?",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Acosta also weighed in, sending both Villafaña and Sloman an email with a subject line that read \"This has to stop,\" in which he stated:",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Just read the letter.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "1. We specifically refused to include the provision saying that we would not communicate. If I recall the conference call, we told him we could not agree to a gag order using those words.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "2. The purpose of the agreement was not an out of court settlement. Seems that they can't take no. Let's talk re how to proceed. I'm not sure we will ever agree on a letter [to the special master about how to select an attorney representative] at this point.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Notwithstanding Acosta's assessment and prediction, after Sloman sent to Lefkowitz a new draft addendum and they spoke by phone, the parties reached agreement on the addendum's terms.147",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "On October 25, 2007, Sloman sent a letter to the person whom the USAO had selected to serve as special master, outlining the special master's duties. A few days later, on October 29, 2007, Epstein and his attorneys Lefcourt and Sanchez signed the NPA addendum.148 Villafaña's name was printed as the USAO representative, but at Villafaña's request, Sloman signed the addendum for her on behalf of the USAO.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Villafaña later emailed Sloman thanking him for \"the advice and the pep talk,\" which apparently related to the defense attorneys' allegation of impropriety concerning her initial selection of the private attorney to assist the victims. Villafaña explained to Sloman:",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "The funny thing is that I had never met (and still haven't met) or spoken to [the private attorney] before I asked him if he would be willing to take on this case. . . . But as soon as you mentioned the appearance problem, I saw where the problem would arise and agreed that the Special Master would be a safer route. I just worry that the defense's attacks on me could harm the victims.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Sloman responded that defense counsel had \"put an . . . insidious spin\" on Villafaña's role in proposing the private attorney, but Sloman added, \"I hope that you understand that these ad hominem attacks against you do not diminish in our eyes what you and the agents have accomplished.\"",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "147 Acosta and Villafaña were copied on this email.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "148 The Addendum is attached as Exhibit 4 to this Report.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "93",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00003295",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Acosta",
      "Villafaña",
      "Sloman",
      "Lefkowitz",
      "Epstein",
      "Lefcourt",
      "Sanchez"
    ],
    "organizations": [
      "USAO"
    ],
    "locations": [],
    "dates": [
      "October 25, 2007",
      "October 29, 2007",
      "04/16/21"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "204-3",
      "DOJ-OGR-00003295"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case involving Jeffrey Epstein. The text discusses the negotiation of an addendum to a non-prosecution agreement (NPA) and the role of various individuals and attorneys involved in the case. The document is well-formatted and mostly free of errors or damage."
}