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al decision, strategy or tactic regarding bail, release, plea, sentencing, or parole." Id. at 424(citation omitted). Similarly, in United States v. Thetford 935 F.Supp.2d 1289 (N.D.Ala. 2013), Jack and Shirley Winslett had their boat stolen by Michael Thetford. A third party subsequently purchased the W
289 (N.D.Ala. 2013), Jack and Shirley Winslett had their boat stolen by Michael Thetford. A third party subsequently purchased the Winslett's boat. Thetford was criminally charged and entered into a plea agreement with the Government. The Winsletts sought to reopen the plea under § 3771(d), complaining
the government's cross-motion for summary judgment. Consequently, their motion should be denied. DATED: August 25, 2017 Respectfully submitted, BENJAMIN G. GREENBERG ACTING UNITED STATES ATTORNEY By: /s/ Dexter A. Lee Dexter A. Lee Assistant United States Attorney Fla Bar No. 0936693 99 N.E. 4'h Street, Sui
al decision, strategy or tactic regarding bail, release, plea, sentencing, or parole." Id. at 424(citation omitted). Similarly, in United States v. Thetford 935 F.Supp.2d 1289 (N.D.Ala. 2013), Jack and Shirley Winslett had their boat stolen by Michael Thetford. A third party subsequently purchased the W
289 (N.D.Ala. 2013), Jack and Shirley Winslett had their boat stolen by Michael Thetford. A third party subsequently purchased the Winslett's boat. Thetford was criminally charged and entered into a plea agreement with the Government. The Winsletts sought to reopen the plea under § 3771(d), complaining
the government's cross-motion for summary judgment. Consequently, their motion should be denied. DATED: August 25, 2017 Respectfully submitted, BENJAMIN G. GREENBERG ACTING UNITED STATES ATTORNEY By: is/Dexter A. Lee Dexter A. Lee Assistant United States Attorney Flat No. 0936693 8 EFTA00799971 Case 9:08
chapter shall be construed to impair the prosecutorial discretion of the Attorney General or any officer under his direction." In United States 1. Thetford, 935 F. Supp. 2d 1280 (N.D. Ala. 2013), victims of a boat theft sought to reopen the defendant's guilty plea. The victims complained that the FBI f
gment based on the undisputed factual record that has since been developed in this case. 111 /// /// 30 EFTA00211747 Respectfully submitted, BENJAMIN G. GREENBERG ACTING UNITED STATES ATTORNEY By: Attorneys for the Government CERTIFICATE OF SERVICE I HEREBY CERTIFY that on June 2, 2017, the foregoing Respo
chapter shall be construed to impair the prosecutorial discretion of the Attorney General or any officer under his direction." In United States v. Thetford, 935 F. Supp. 2d 1280 (N.D. Ala. 2013), victims of a boat theft sought to reopen the defendant's guilty plea. The victims complained that the FBI f
e. / / / I/I I/I 30 EFTA00799854 Case 9:08-cv-80736-KAM Document 408 Entered on FLSD Docket 06/06/2017 Page 31 of 32 Respectfully submitted, BENJAMIN G. GREENBERG ACTING UNITED STATES ATTORNEY By: Is/Dexter A. Lee Dexter A. Lee Assistant United States Attorney Fla Bar No. 0936693 99 N.E. 4th Street, Suite
chapter shall be construed to impair the prosecutorial discretion of the Attorney General or any officer under his direction." In United States v. Thetford, 935 F. Supp. 2d 1280 (N.D. Ala. 2013), victims of a boat theft sought to reopen the defendant's guilty plea. The victims complained that the FBI f
/ / / / / / / 30 EFTA00591491 Case 9:08-cv-80736-KAM Document 401-2 Entered on FLSD Docket 06/02/2017 Page 32 of 33 Respectfully submitted, BENJAMIN G. GREENBERG ACTING UNITED STATES ATTORNEY By: Is/Dexter A. Lee Dexter A. Lee Assistant United States Attorney Fla Bar No. 0936693 99 N.E. 4'h Street, Suite
Entities connected to both Thetford and BENJAMIN G. GREENBERG

Jeffrey Epstein
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONLeon Black
PERSON
Bradley Edwards
PERSONJacqueline Perczek
PERSONMaria Farmer
PERSONAce Greenberg
PERSON
United States
LOCATION
Dexter Lee
PERSONFISTOS & LEHRMAN
ORGANIZATION
S.J. Quinney College of Law
ORGANIZATION
the University of Utah
ORGANIZATION
A. Marie Villafana
PERSON
Department of Justice
ORGANIZATION
Jay Lefkowitz
PERSONJane Doe
PERSONJames Eisenberg
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Executive
ORGANIZATIONKuyrkendall
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