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1.04 MB

Extraction Summary

10
People
5
Organizations
3
Locations
3
Events
10
Relationships
11
Quotes

Document Information

Type: Legal document
File Size: 1.04 MB
Summary

This document, part of a legal case filed in 2021, details communications and negotiations from September 2007 concerning a potential plea deal for Mr. Epstein. It highlights discussions among various legal professionals regarding charges, sexual offender registration, and the scope of a Non-Prosecution Agreement (NPA). A key aspect is the USAO's agreement, as part of a draft NPA, not to criminally charge Epstein's female assistants, employees of his corporate entity, and 'potential co-conspirators' in an ongoing federal investigation.

People (10)

Name Role Context
Jay Lefkowitz Defense counsel
Will try to talk out of registrable offense; attempted to reach Acosta; sent Villafaña a revised draft NPA; was 'waff...
Acosta
Directed Villafaña to return a call; received email from Villafaña; received forwarded email from Sloman; replied to ...
Lourie
Told by Acosta not to open a 'backchannel'; instructed Villafaña; alerted by Villafaña; received forwarded email from...
Villafaña
Directed by Acosta to return a call; instructed by Lourie; emailed Acosta on Sept 21, 2007; alerted Lourie; received ...
Mr. Epstein Defendant
Subject of potential charges; pleading to a state charge; owned a corporate entity.
Krischer
Villafaña would confer with Krischer.
Belohlavek
Villafaña would confer with Belohlavek.
Sanchez Epstein attorney
Emailed Sloman about finalizing plea deal; had not been involved in negotiations for several weeks; Lourie stated San...
Sloman
Received email from Sanchez; forwarded email to Acosta and Lourie; on out-of-town vacation; working with Marie.
[M]arie
Working with Sloman.

Organizations (5)

Name Type Context
West Palm Beach Government agency (implied)
Manager reviewing charging package.
Miami office Government agency (implied)
Needed to review charging package.
USAO Government agency
Agrees not to criminally charge 'Potential Co-Conspirators'; drafted federal plea agreement.
Epstein-owned corporate entity Company
Employees protected by the defense draft of the NPA.
Southern District of Florida Government agency / Legal jurisdiction
Federal criminal liability resolved by the plea agreement.

Timeline (3 events)

2007-09-21
Villafaña emailed Acosta about impending charges against Mr. Epstein, the review of the charging package, and discussions with Krischer and Belohlavek regarding Epstein's state charge and sexual offender registration.
West Palm Beach (implied), Miami (implied)
2007-09-21
Epstein attorney Sanchez emailed Sloman to finalize a plea deal, which Sloman then forwarded to Acosta and Lourie, leading to discussions about Sanchez's involvement in negotiations.
Lefkowitz sent Villafaña a revised draft Non-Prosecution Agreement (NPA) proposing an 18-month sentence, community control, a trust fund, and protection from criminal charges for Epstein's female assistants, corporate entity employees, and 'potential co-conspirators' in an ongoing federal investigation.

Locations (3)

Location Context
Location of a manager reviewing a charging package.
Location of an office that needed to review a charging package.
Area where federal criminal liability is resolved by the plea agreement.

Relationships (10)

Jay Lefkowitz Professional (defense counsel-client implied) Mr. Epstein
Lefkowitz is described as 'defense counsel' and is negotiating on behalf of Epstein.
Acosta Professional (colleagues) Villafaña
Acosta directed Villafaña; Villafaña emailed Acosta.
Lourie Professional (colleagues) Villafaña
Lourie instructed Villafaña; Villafaña alerted Lourie.
Mr. Epstein Professional (attorney-client) Sanchez
Sanchez is identified as 'Epstein attorney Sanchez'.
Sanchez Professional (colleagues) Sloman
Sanchez emailed Sloman about finalizing a plea deal.
Sloman Professional (colleagues) Acosta
Sloman forwarded an email to Acosta.
Sloman Professional (colleagues) Lourie
Sloman forwarded an email to Lourie.
Sloman Professional (colleagues) [M]arie
Sloman mentioned 'Working with [M]arie on this'.
Krischer Professional (colleagues) Belohlavek
Villafaña noted she would 'confer with Krischer and Belohlavek'.
Mr. Epstein Employer-Employee Four female assistants and unnamed employees of the specific Epstein-owned corporate entity
The defense draft NPA promised not to criminally charge these individuals.

Key Quotes (11)

"U can tell [J]ay that [A]lex will not agree to a nonregistration offense."
Source
— Lourie (Lourie instructing Villafaña regarding negotiations with Jay Lefkowitz.)
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Quote #1
"it looks like we will be [filing charges against] Mr. Epstein on Tuesday"
Source
— Villafaña (Villafaña informing Acosta via email about the impending charges.)
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Quote #2
"was waffling"
Source
— Villafaña (Villafaña describing Lefkowitz's stance on Epstein pleading to a state charge requiring sexual offender registration.)
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Quote #3
"to make sure the defense doesn’t try to do an end run."
Source
— Villafaña (Villafaña's stated purpose for conferring with Krischer and Belohlavek regarding Epstein's plea.)
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Quote #4
"[I] want to finalize the plea deal and there is only one issue outstanding and [I] do not believe that [A]lex has read all the defense submissions that would assist in his determination on this point . . . [U]pon resolution, we will be prepared to sign as soon as today."
Source
— Sanchez (Sanchez emailing Sloman about the status of the plea deal.)
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Quote #5
"Enjo[y] vacation. Working with [M]arie on this."
Source
— Acosta (Acosta's reply to Sloman after Sloman forwarded Sanchez's email.)
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Quote #6
"Do you know what she’s talking about?"
Source
— Sloman (Sloman's question to Lourie after forwarding Sanchez's email.)
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Quote #7
"has not been in any negotiations. Don’t even engage with yet another cook."
Source
— Lourie (Lourie's response to Sloman regarding Sanchez's involvement.)
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Quote #8
"who seek reimbursement by filing suit pursuant to 18 U.S.C. § 2255."
Source
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Quote #9
"any potential co-conspirators"
Source
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Quote #10
"This agreement resolves the federal criminal liability of the defendant and any co-conspirators in the Southern District of Florida growing out of any criminal conduct by those persons known to the [USAO] . . . ."
Source
— USAO's draft federal plea agreement (Language from the USAO's draft federal plea agreement, cited in footnote 122.)
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Quote #11

Full Extracted Text

Complete text extracted from the document (3,415 characters)

Case 1:20-cr-00330-PAE Document 204-3 Filed 04/16/21 Page 105 of 348
I think Jay [Lefkowitz] will try to talk you out of a registrable offense. Regardless of the merits of his argument, in order to get us down in time they made us an offer that included pleading to an offense against a minor (encouraging a minor into prostitution) and touted that we should be happy because it was registrable. For that reason alone, I don’t think we should consider allowing them to come down from their own offer, either on this issue or on time of incarceration.
Lefkowitz attempted to reach Acosta that night, but Acosta directed Villafaña to return the call, and told Lourie that he did not want to open “a backchannel” with defense counsel. Lourie instructed Villafaña, “U can tell [J]ay that [A]lex will not agree to a nonregistration offense.”
On the morning of Friday, September 21, 2007, Villafaña emailed Acosta informing him that “it looks like we will be [filing charges against] Mr. Epstein on Tuesday,” reporting that the charging package was being reviewed by the West Palm Beach manager, and asking if anyone in the Miami office needed to review it. Villafaña also alerted Lourie that she had spoken that morning to Lefkowitz, who “was waffling” about Epstein pleading to a state charge that required sexual offender registration, and she noted that she would confer with Krischer and Belohlavek “to make sure the defense doesn’t try to do an end run.”
That same morning, Epstein attorney Sanchez, who had not been involved in negotiations for several weeks, emailed Sloman, advising, “[I] want to finalize the plea deal and there is only one issue outstanding and [I] do not believe that [A]lex has read all the defense submissions that would assist in his determination on this point . . . [U]pon resolution, we will be prepared to sign as soon as today.” From his out-of-town vacation, Sloman forwarded the email to Acosta, who replied, “Enjo[y] vacation. Working with [M]arie on this.” Sloman also forwarded Sanchez’s email to Lourie and asked, “Do you know what she’s talking about?” Lourie responded that Sanchez “has not been in any negotiations. Don’t even engage with yet another cook.”
J. The USAO Agrees Not to Criminally Charge “Potential Co-Conspirators”
Lefkowitz, in the meantime, sent Villafaña a revised draft NPA that proposed an 18-month sentence in the county jail, followed by 12 months of community control, and restored the provision for a trust fund for disbursement to an agreed-upon list of individuals “who seek reimbursement by filing suit pursuant to 18 U.S.C. § 2255.” This defense draft retained the provision promising not to criminally charge Epstein’s four female assistants and unnamed employees of the specific Epstein-owned corporate entity, but also extended the provision to “any potential co-conspirators” for any criminal charge arising from the ongoing federal investigation. This language had evolved from similar language that Villafaña had included in the USAO’s earlier proposed draft federal plea agreement. ¹²² Lefkowitz also again included the sentence
¹²² The language in the USAO’s draft federal plea agreement stated, “This agreement resolves the federal criminal liability of the defendant and any co-conspirators in the Southern District of Florida growing out of any criminal conduct by those persons known to the [USAO] . . . .”
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