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934 KB
Extraction Summary
10
People
1
Organizations
3
Locations
1
Events
4
Relationships
6
Quotes
Document Information
Type:
Legal document
File Size:
934 KB
Summary
This legal document details plea negotiations in the case against Mr. Epstein on and around September 21, 2007. It reveals intense back-and-forth communication between prosecutors (Acosta, Villafaña, Lourie) and defense attorneys (Lefkowitz, Sanchez) over critical terms, including whether Epstein would have to register as a sex offender and the scope of a non-prosecution agreement for his alleged co-conspirators. The document highlights internal prosecution strategies and their dismissive view of some members of Epstein's legal team.
People (10)
| Name | Role | Context |
|---|---|---|
| Jay Lefkowitz | Defense Counsel |
Mentioned as part of Epstein's defense team, negotiating a plea deal and attempting to avoid a registrable offense.
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| Acosta | Prosecutor/Government Official |
Involved in plea negotiations, directing colleagues Villafaña and Lourie. Referred to as 'Alex'.
|
| Villafaña | Prosecutor/Government Official |
Communicating with both the defense (Lefkowitz) and her colleagues (Acosta, Lourie) regarding the plea deal and poten...
|
| Lourie | Prosecutor/Government Official |
Involved in plea negotiations, instructing Villafaña and expressing dismissal of Epstein's attorney Sanchez.
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| Mr. Epstein | Defendant |
The subject of the criminal charges and plea negotiations discussed in the document.
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| Krischer |
Mentioned as someone Villafaña would confer with to prevent the defense from doing an "end run".
|
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| Belohlavek |
Mentioned as someone Villafaña would confer with to prevent the defense from doing an "end run".
|
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| Sanchez | Epstein attorney |
An attorney for Epstein who emailed Sloman to finalize a plea deal, but was dismissed by Lourie as not being involved...
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| Sloman |
Received an email from Sanchez and forwarded it to Acosta and Lourie while on vacation.
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| Marie |
Mentioned in an email from Acosta to Sloman, indicating she is working on the case.
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Organizations (1)
| Name | Type | Context |
|---|---|---|
| USAO | Government Agency |
Mentioned in the heading "The USAO Agrees Not to Criminally Charge..." and in a footnote describing language from its...
|
Timeline (1 events)
2007-09-21
A series of communications occurred between the prosecution (Acosta, Villafaña, Lourie) and defense counsel (Lefkowitz, Sanchez) regarding the terms of a plea agreement for Mr. Epstein, focusing on sexual offender registration and non-prosecution of co-conspirators.
Locations (3)
| Location | Context |
|---|---|
|
Mentioned in the context of the "West Palm Beach manager" reviewing the charging package.
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|
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Mentioned in the context of the "Miami office" potentially needing to review the charging package.
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Mentioned in a footnote quoting a draft plea agreement regarding the resolution of federal criminal liability.
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Relationships (4)
Lefkowitz, as defense counsel, is negotiating with Acosta's team (the prosecution). Acosta directed his subordinates not to open a 'backchannel' with Lefkowitz, indicating a formal, adversarial relationship.
Villafaña reports to Acosta via email about the status of the case and takes direction from him regarding communications with the defense.
Lourie instructs Villafaña on what message to deliver to the defense counsel, indicating a working relationship on the prosecution team.
Key Quotes (6)
"U can tell [J]ay that [A]lex will not agree to a nonregistration offense."Source
— Lourie
(An instruction from Lourie to Villafaña regarding the prosecution's stance in plea 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
(In an email to Acosta on September 21, 2007, updating him on the status of the case.)
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Quote #2
"to make sure the defense doesn’t try to do an end run."Source
— Villafaña
(Her stated reason for planning to confer with Krischer and Belohlavek regarding the negotiations.)
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Quote #3
"[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
(In an email to Sloman expressing a desire to finalize the plea agreement.)
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Quote #4
"has not been in any negotiations. Don’t even engage with yet another cook."Source
— Lourie
(Her response after Sloman forwarded Sanchez's email, dismissing Sanchez's involvement in the negotiations.)
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Quote #5
"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
(Language from the USAO's draft federal plea agreement, as described in a footnote.)
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Quote #6
Full Extracted Text
Complete text extracted from the document (3,484 characters)
Case 22-1426, Document 77, 06/29/2023, 3536038, Page107 of 258
SA-105
Case 1:20-cr-00330-AJN Document 204-3 Filed 04/16/21 Page 105 of 348
SA-105
Case 1:20-cr-00330-AJN 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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