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Case 22-1426, Document 77, SA-99 3536038, Page101 of 258 Case 1:20-cr-00330-AJN Document 204-3 Filed 04/16/21 Page 99 of 348 twelve months, with six served in home confinement, to run consecutively. I just received an e-mail asking if Mr. Epstein could just do 12 months imprisonment instead. As you can see, Mr. Epstein is having second thoughts about doing jail time. I would like to send Jay Lefkowitz an e-mail stating that if we do not have a signed agreement by tomorrow at 5:00, negotiations will end. I have selected tomorrow at 5:00 because it gives them enough time to really negotiate an agreement if they are serious about it, and if not, it gives me one day before the Jewish holiday to get [prepared] for Tuesday . . . [September 25] , when I plan to [file charges], and it gives the office sufficient time to review the indictment package. Do you concur? A few minutes later, the incoming West Palm Beach manager emailed Lourie, suggesting that Lourie “talk to Epstein and close the deal.” 1!8 Within moments, Lourie replied to the manager, with a copy to Villafafia, reporting that he had just spoken with Lefkowitz and agreed “to two fed[eral] obstruction[] charges (24 month cap) with nonbinding recommendation for 18 months. When [Epstein] gets out, he has to plead to state offenses, including against minor, registrable, and then take one year house arrest/ecommunity confinement.” By reply email, Villafafia asked Lourie to call her, but there is no record of whether they spoke. F. Defense Counsel Offers New Proposals Substantially Changing the Terms of the Federal Plea Agreement, which the USAO Rejects Approximately an hour after Lourie’s email reporting the deal he had reached with Lefkowitz, Lefkowitz sent Villafafia a revised draft plea agreement. Despite the agreement Lourie believed he and Lefkowitz had reached that morning, Lefkowitz’s proposal would have resulted in a 16-month federal sentence followed by 8 months of supervised release served in the form of home detention. Lefkowitz also inserted a statement in his proposal explicitly prohibiting the USAO from requesting, initiating, or encouraging immigration authorities to institute immigration proceedings against two of Epstein’s female assistants. Villafafia circulated the defense’s proposed plea agreement to Lourie and two other supervisors, and expressed frustration that the new defense version incorporated terms that were “completely different from what Jay just told Andy they would agree to.” Villafafia also pointed out that the defense “wants us to recommend an improper calculation” of the sentencing guidelines 118 The manager told OPR that he probably meant this as a joke because in his view the continued back-and- forth communications with defense counsel “was ridiculous,” and the only way to “get this deal done” might be to have a direct conversation with Epstein. 73 DOJ-OGR-00021273

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Filename DOJ-OGR-00021273.jpg
File Size 805.7 KB
OCR Confidence 94.5%
Has Readable Text Yes
Text Length 2,917 characters
Indexed 2026-02-03 20:09:42.091591