DOJ-OGR-00021416.jpg
899 KB
Extraction Summary
9
People
8
Organizations
0
Locations
3
Events
6
Relationships
6
Quotes
Document Information
Type:
Legal document
File Size:
899 KB
Summary
This document, a legal filing, details disputes and communications from 2007 concerning victim notification and compensation in a federal case related to Epstein. It highlights arguments between legal figures like Lefkowitz, Starr, Acosta, and Villafaña regarding the interpretation of victim rights laws and the handling of specific victims, including 'Jane Doe #2' whose attorney was paid by Epstein. The text reveals concerns about the government's adherence to victim notification requirements and allegations of misconduct.
People (9)
| Name | Role | Context |
|---|---|---|
| Acosta |
Advises the Defense, received submissions from Starr, instructed OPR regarding victim status.
|
|
| Starr |
Transmitted submissions authored by Lefkowitz to Acosta, asserted concerns regarding victim notification.
|
|
| Lefkowitz |
Authored submissions, argued that the government was not required to notify victims, took issue with USAO's assertion...
|
|
| Epstein |
Subject of investigation, due process rights mentioned, paid the attorney for a victim (Jane Doe #2).
|
|
| Villafaña |
Made a decision to utilize a civil remedy statute, proposed a Victims Notification letter, wrote a letter to Lefkowit...
|
|
| Jane Doe #2 | Victim |
A victim who gave a video-recorded interview to the FBI, was not included on the victim list, her attorney was paid b...
|
| Sloman |
Instructed Villafaña (or Acosta) not to consider an individual as a victim for NPA purposes.
|
|
| one girl's attorney | Attorney |
Received oral notification of the victim notification letter.
|
| this individual | Victim |
Refers to Jane Doe #2, instructed not to be considered a victim for NPA purposes.
|
Organizations (8)
| Name | Type | Context |
|---|---|---|
| USAO | Government Agency |
United States Attorney's Office, defers decisions, would notify victims, asserted obligations, misinterpreted laws.
|
| State Attorney | Government Agency |
The USAO will defer to the State Attorney regarding victim notification for state plea hearing.
|
| NPA | Legal Agreement |
Non-Prosecution Agreement, subject of substantive challenges.
|
| FBI | Government Agency |
Federal Bureau of Investigation, conducted a recorded interview with a victim.
|
| OPR | Government Agency |
Office of Professional Responsibility, Villafaña told OPR about instructions regarding victim status.
|
| the government | Government Entity |
General reference to authorities, complained about by Starr, argued against by Lefkowitz, accused of misconduct by Vi...
|
| the defense | Legal Party |
Acosta advises the defense, received victim list.
|
| the Office | Government Agency |
Refers to the office that was not prepared to include an individual in a federal charging document.
|
Timeline (3 events)
2007-04
A victim (Jane Doe #2) gave a video-recorded interview to the FBI that was favorable to Epstein.
2007-12-19
Acosta advises the Defense that the USAO will defer to the State Attorney regarding victim notification for the State Plea Hearing, but the USAO would notify victims of the Federal Resolution.
Relationships (6)
Starr transmitted submissions to Acosta, indicating a professional communication channel.
Lefkowitz authored submissions transmitted to Acosta, and Lefkowitz's arguments often countered positions taken by the USAO, which Acosta was involved with.
Villafaña sent a letter to Lefkowitz responding to allegations of misconduct, indicating a professional dispute.
Jane Doe #2 was a victim in the investigation into Epstein, and Epstein paid her attorney.
Villafaña told OPR she was instructed by Sloman (or Acosta) regarding how to classify a victim for the NPA.
Key Quotes (6)
""to go above and beyond in terms of caring for the victims.""Source
DOJ-OGR-00021416.jpg
Quote #1
""as Required by Law""Source
DOJ-OGR-00021416.jpg
Quote #2
""latest episodes involving [§] 2255 notification to the alleged victims put illustratively in bold relief our concerns that the ends of justice, time and time again, are not being served.""Source
— Starr
(Starr's assertion in his transmittal letter regarding victim notification issues.)
DOJ-OGR-00021416.jpg
Quote #3
""did not in any manner view herself as a victim.""Source
— one girl
(From a girl's recorded FBI interview, indicating her self-perception.)
DOJ-OGR-00021416.jpg
Quote #4
""false" allegations"Source
DOJ-OGR-00021416.jpg
Quote #5
""not to consider [this individual] as a victim for purposes of the NPA because she was not someone whom the Office was prepare[d] to include in" a federal charging document."Source
— Sloman or Acosta (as told by Villafaña to OPR)
(Instruction given to Villafaña regarding the status of a specific victim (Jane Doe #2).)
DOJ-OGR-00021416.jpg
Quote #6
Full Extracted Text
Complete text extracted from the document (3,379 characters)
Case 22-1426, Document 77, 06/29/2023, 3536038, Page244 of 258
SA-242
Case 1:20-cr-00330-AJN Document 204-3 Filed 04/16/21 Page 242 of 348
SA-242
Case 1:20-cr-00330-AJN Document 204-3 Filed 04/16/21 Page 242 of 348
her a victim for purposes of the federal charges, and continued to treat her as a victim because she
wanted "to go above and beyond in terms of caring for the victims."³¹⁸
wanted "to go above and beyond in terms of caring for the victims."³¹⁸
E. December 19, 2007: Acosta Advises the Defense That the USAO Will Defer to
the State Attorney the Decision Whether to Notify Victims of the State Plea
Hearing, but the USAO Would Notify Them of the Federal Resolution, "as
Required by Law"
the State Attorney the Decision Whether to Notify Victims of the State Plea
Hearing, but the USAO Would Notify Them of the Federal Resolution, "as
Required by Law"
On December 11, 2007, Starr transmitted to Acosta two lengthy submissions authored by
Lefkowitz presenting substantive challenges to the NPA and to "the background and conduct of
the investigation" into Epstein. Regarding issues relevant to victim notification, in his transmittal
letter, Starr asserted that the "latest episodes involving [§] 2255 notification to the alleged victims
put illustratively in bold relief our concerns that the ends of justice, time and time again, are not
being served." By way of example, Starr complained the government had recently inappropriately
provided "oral notification of the victim notification letter" to one girl's attorney, even though it
was clear from the girl's recorded FBI interview that she "did not in any manner view herself as a
victim."
Lefkowitz presenting substantive challenges to the NPA and to "the background and conduct of
the investigation" into Epstein. Regarding issues relevant to victim notification, in his transmittal
letter, Starr asserted that the "latest episodes involving [§] 2255 notification to the alleged victims
put illustratively in bold relief our concerns that the ends of justice, time and time again, are not
being served." By way of example, Starr complained the government had recently inappropriately
provided "oral notification of the victim notification letter" to one girl's attorney, even though it
was clear from the girl's recorded FBI interview that she "did not in any manner view herself as a
victim."
In his submissions, Lefkowitz argued that the government was not required to notify
victims of the § 2255 provision:
victims of the § 2255 provision:
Villafaña's decision to utilize a civil remedy statute in the place of
a restitution fund for the alleged victims eliminates the notification
requirement under the Justice for All Act of 2004, a federal law that
requires federal authorities to notify victims as to any available
restitution, not of any potential civil remedies. Despite this fact,
[she] proposed a Victims Notification letter to be sent to the alleged
federal victims.
a restitution fund for the alleged victims eliminates the notification
requirement under the Justice for All Act of 2004, a federal law that
requires federal authorities to notify victims as to any available
restitution, not of any potential civil remedies. Despite this fact,
[she] proposed a Victims Notification letter to be sent to the alleged
federal victims.
Lefkowitz also argued that a victim trust fund would provide a more appropriate
mechanism for compensating the victims than the government's proposed use of 18 U.S.C. § 2255,
and a trust fund would not violate Epstein's due process rights. Lefkowitz took issue with the
government's "assertion" that the USAO was obligated to send a victim notification letter to the
alleged victims, or even that it was appropriate for the USAO to do so. Lefkowitz further argued
that the government misinterpreted both the CVRA and the VRRA, because neither applied to a
public, state court proceeding involving the entry of a plea on state charges.
mechanism for compensating the victims than the government's proposed use of 18 U.S.C. § 2255,
and a trust fund would not violate Epstein's due process rights. Lefkowitz took issue with the
government's "assertion" that the USAO was obligated to send a victim notification letter to the
alleged victims, or even that it was appropriate for the USAO to do so. Lefkowitz further argued
that the government misinterpreted both the CVRA and the VRRA, because neither applied to a
public, state court proceeding involving the entry of a plea on state charges.
In a letter from Villafaña to Lefkowitz, responding to his allegations that she had
committed misconduct, she specifically addressed the "false" allegations that the government had
committed misconduct, she specifically addressed the "false" allegations that the government had
³¹⁸ As noted previously, in April 2007, this victim gave a video-recorded interview to the FBI that was favorable
to Epstein. Villafaña told OPR she was instructed by either Sloman or Acosta "not to consider [this individual] as a
victim for purposes of the NPA because she was not someone whom the Office was prepare[d] to include in" a federal
charging document. Accordingly, the victim who became "Jane Doe #2" was not included on the victim list ultimately
furnished to the defense. The attorney who was representing this victim at the time of her FBI interview was paid by
Epstein, and she subsequently obtained different counsel.
to Epstein. Villafaña told OPR she was instructed by either Sloman or Acosta "not to consider [this individual] as a
victim for purposes of the NPA because she was not someone whom the Office was prepare[d] to include in" a federal
charging document. Accordingly, the victim who became "Jane Doe #2" was not included on the victim list ultimately
furnished to the defense. The attorney who was representing this victim at the time of her FBI interview was paid by
Epstein, and she subsequently obtained different counsel.
216
DOJ-OGR-00021416
Discussion 0
No comments yet
Be the first to share your thoughts on this epstein document