DOJ-OGR-00021277.json 7.9 KB

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  1. {
  2. "document_metadata": {
  3. "page_number": "77",
  4. "document_number": "Case 22-1426, Document 77",
  5. "date": "06/29/2023",
  6. "document_type": "Court Document",
  7. "has_handwriting": false,
  8. "has_stamps": false
  9. },
  10. "full_text": "Case 22-1426, Document 77, 06/29/2023, 3536038, Page105 of 258\nSA-103\nCase 1:20-cr-00330-AJN Document 204-3 Filed 04/16/21 Page 103 of 348\neverything, but I really do not think that Mr. Epstein is going to engage in serious negotiations until he sees the Indictment and shows up in mag [federal magistrate judge] court.\" She suggested charging Epstein on a federal conspiracy charge, and if he refused to plead to that offense, superseding with additional charges and going to trial. She complained that after seven weeks of negotiations, \"we are just spinning our wheels.\" Her proposed email to Lefkowitz detailed all of the objectionable provisions in his draft, and concluded, \"If you or your client insists on these, there can be no plea agreement.\"\n\nH. Acosta Edits the Federal Plea Agreement, and Villafaña Sends a Final Version to the Defense\nThe next day, Thursday, September 20, 2007, Villafaña emailed Assistant State Attorney Belohlavek and informed her:\nOur deadline is Monday evening for a signed agreement and arraignment in the federal system. At this time, things don't look promising anyway, but I will keep you posted. In their latest draft, they changed what they agreed to plead to in the state from solicitation of minors for prostitution (a registrable offense) to forcing adults into prostitution (a non-registrable offense). We will not budge on this issue, so it is looking unlikely that we will reach a mutually acceptable agreement. If that changes, I will let you know.\nAcosta sent Lourie \"[s]ome thoughts\" about the USAO version of the proposed \"hybrid\" federal plea agreement he had received from Lourie the evening before, commenting that \"it seems very straightforward\" and \"we are not changing our standard charging language\" for the defense. Noting that the draft was prepared for his signature, Acosta told Lourie that he did not typically sign plea agreements and \"this should not be the first,\" adding that the USAO \"should only go forward if the trial team supports and signs this agreement.\" Lourie forwarded the email to Villafaña with a transmittal message simply reading, \"I think Alex's changes are all good ones. Please try to incorporate his suggestions, change the signature block to your name and send as final to Jay.\" Lourie also noted to Acosta and Villafaña that he believed the defense would want to go back to the initial offer of a state plea with a non-prosecution agreement. When Villafaña sent the revised plea agreement to Lefkowitz later that afternoon, she advised him that if the defense wanted to return to the original offer of a state plea only, the draft NPA she had sent to him on September 17, 2007, would control.\nThe USAO had standard federal plea agreement language, from which this \"hybrid\" plea agreement had substantially diverged.\nThe standard procedure was for documents such as plea agreements to be signed by an AUSA under the name of the U.S. Attorney. In his OPR interview, Acosta further explained that wanted to give \"the trial team\" an opportunity to voice any objections because \"if it's something they don't feel comfortable with we . . . shouldn't go forward with it.\"\n77\nDOJ-OGR-00021277",
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  14. "content": "Case 22-1426, Document 77, 06/29/2023, 3536038, Page105 of 258",
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  18. "type": "printed",
  19. "content": "SA-103",
  20. "position": "header"
  21. },
  22. {
  23. "type": "printed",
  24. "content": "Case 1:20-cr-00330-AJN Document 204-3 Filed 04/16/21 Page 103 of 348",
  25. "position": "header"
  26. },
  27. {
  28. "type": "printed",
  29. "content": "everything, but I really do not think that Mr. Epstein is going to engage in serious negotiations until he sees the Indictment and shows up in mag [federal magistrate judge] court.\" She suggested charging Epstein on a federal conspiracy charge, and if he refused to plead to that offense, superseding with additional charges and going to trial. She complained that after seven weeks of negotiations, \"we are just spinning our wheels.\" Her proposed email to Lefkowitz detailed all of the objectionable provisions in his draft, and concluded, \"If you or your client insists on these, there can be no plea agreement.\"\n\nH. Acosta Edits the Federal Plea Agreement, and Villafaña Sends a Final Version to the Defense\nThe next day, Thursday, September 20, 2007, Villafaña emailed Assistant State Attorney Belohlavek and informed her:\nOur deadline is Monday evening for a signed agreement and arraignment in the federal system. At this time, things don't look promising anyway, but I will keep you posted. In their latest draft, they changed what they agreed to plead to in the state from solicitation of minors for prostitution (a registrable offense) to forcing adults into prostitution (a non-registrable offense). We will not budge on this issue, so it is looking unlikely that we will reach a mutually acceptable agreement. If that changes, I will let you know.\nAcosta sent Lourie \"[s]ome thoughts\" about the USAO version of the proposed \"hybrid\" federal plea agreement he had received from Lourie the evening before, commenting that \"it seems very straightforward\" and \"we are not changing our standard charging language\" for the defense. Noting that the draft was prepared for his signature, Acosta told Lourie that he did not typically sign plea agreements and \"this should not be the first,\" adding that the USAO \"should only go forward if the trial team supports and signs this agreement.\" Lourie forwarded the email to Villafaña with a transmittal message simply reading, \"I think Alex's changes are all good ones. Please try to incorporate his suggestions, change the signature block to your name and send as final to Jay.\" Lourie also noted to Acosta and Villafaña that he believed the defense would want to go back to the initial offer of a state plea with a non-prosecution agreement. When Villafaña sent the revised plea agreement to Lefkowitz later that afternoon, she advised him that if the defense wanted to return to the original offer of a state plea only, the draft NPA she had sent to him on September 17, 2007, would control.\nThe USAO had standard federal plea agreement language, from which this \"hybrid\" plea agreement had substantially diverged.\nThe standard procedure was for documents such as plea agreements to be signed by an AUSA under the name of the U.S. Attorney. In his OPR interview, Acosta further explained that wanted to give \"the trial team\" an opportunity to voice any objections because \"if it's something they don't feel comfortable with we . . . shouldn't go forward with it.\"\n77\nDOJ-OGR-00021277",
  30. "position": "body"
  31. },
  32. {
  33. "type": "printed",
  34. "content": "77",
  35. "position": "footer"
  36. },
  37. {
  38. "type": "printed",
  39. "content": "DOJ-OGR-00021277",
  40. "position": "footer"
  41. }
  42. ],
  43. "entities": {
  44. "people": [
  45. "Epstein",
  46. "Lefkowitz",
  47. "Villafaña",
  48. "Belohlavek",
  49. "Acosta",
  50. "Lourie",
  51. "Alex",
  52. "Jay"
  53. ],
  54. "organizations": [
  55. "USAO",
  56. "U.S. Attorney",
  57. "AUSA"
  58. ],
  59. "locations": [],
  60. "dates": [
  61. "06/29/2023",
  62. "04/16/21",
  63. "September 20, 2007",
  64. "September 17, 2007"
  65. ],
  66. "reference_numbers": [
  67. "Case 22-1426",
  68. "Document 77",
  69. "3536038",
  70. "Case 1:20-cr-00330-AJN",
  71. "Document 204-3",
  72. "DOJ-OGR-00021277"
  73. ]
  74. },
  75. "additional_notes": "The document appears to be a court document related to the case of Jeffrey Epstein. It contains details about plea agreements and negotiations between the defense and prosecution. The document is well-formatted and mostly free of damage or redactions."
  76. }