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understood as a venue provision than a jurisdictional provision—it specifies in which "court of appeals" a victim should file. Cf. United States v. Ross. 963 F.3d 1056. 1063 (11th Cir. 2020) (en banc) (noting "the Supreme Court's directive that courts should avoid 'jurisdictionalizing' issues" that a
efkowitz e-mailed AUSA Villafana, requesting: "Marie - Please do whatever you can to keep this [Agreement] from becoming public." (emphasis added). AUSA Villafafia assured Lefkowitz that the Agreement would be kept confidential. 7 For example, in a December 6, 2007 letter, AUSA Villafana informed Lefkowitz tha
on attachment #9); Deposition of Adriana Mucinska Ross, March 15, 2010 (hereinafter "Ross Depo.") (Depo
t the United States Attorney's Office prepared negotiated plea agreements containing these charges. For example, in a September 18, 2007, email from AUSA Villafafia to Lefkowitz (attached hereto as Exhibit "H"), she attached the proposed plea agreement describing Epstein's witness tampering as follows: "UNITED
!, March 24, 2010 (hereinafter MB Depo.") (Deposition attachment #14); Deposition of , April 13, 2010, (Deposition attachment #9); Deposition of Ross, March 15, 2010 (hereinafter "Ross Depo.") (Deposition attachment #15). Each of these co- conspirators invoked their respective rights against self
t the United States Attorney's Office prepared negotiated plea agreements containing these charges. For example, in a September 18, 2007, email from AUSA Villafafia to Lefkowitz (attached hereto as Exhibit "H"), she attached the proposed plea agreement describing Epstein's witness tampering as follows: "UNITED
pstein and co-conspirators Sarah Kellen, Adrian& Ross, Lesley Groff and Nadia Marcinkova off the hook f
de—rlet—knew whethee-the-title-ef-ttte-deooment-was-diselesed-when4he-Agreemem-was-filed-under-sealr but 39. On July 3, 2008, Mr. Edwards sent to AUSA Villafafia a letter. See Affidavit of Bradley J. Edwards, Esq., at 15 (attachment 2). In the letter, Mr. Edwards indicated his client's desire that federal ch
ach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. . (225) On or about September 29, 2005, Defendants JEFFREY EPSTEIN, ROSS, alkla"Adriana Mucinska," and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion A
e S. Fisher, as well as the Criminal Division's Appellate Section and the Office of Enforcement Operations regarding the petit policy. By May 2007, AUSA Villafafia began seeking approval from her supervisors to indict Epstein. Her immediate supervisor was Andrew Lourie. Mr. Lourie had served as the Chief of the
Entities connected to both Wilbur Ross and AUSA Villafafia

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Joe Biden
PERSON
Prince Andrew
PERSON
Donald Trump
PERSONLeon Black
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Julie K. Brown
PERSON
Alan Dershowitz
PERSON
Department of Justice
ORGANIZATION
Eric Trump
PERSON
Bill Clinton
PERSON
Virginia Giuffre
PERSON
Stephen Hawking
PERSON
Lesley Groff
PERSON
Samantha Power
PERSON
Supreme Court
ORGANIZATION
Prince Charles
PERSON
Barry Diller
PERSON