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k that physical force against the person . . . or another may be used in t the course of committing the offense." 18 U.S.C. § 16(b). Post-Johnson v. United Sta , U.S. 135 S. Ct. 2551 (2015), a court might decide differently. See, e.g., Menendez Whitaker, 908 F.3d 467 (9'b Cir. 2018). Even if not a crime
considered for work release. At some point after the NPA was signed, USA Acosta was recused from the Epstein matter. AUSA John McMillan (still at USA0): Early in the investigation, I asked AUSA McMillan if he would serve as co-counsel on the case. Before I joined the West Palm Beach Office, AUSA M
rate contact with Epstein. (See Exhibit A-1.) One of the subpoenaed victims was Individual #28, who is referred to as Jane Doe #2 in the Jane Doe' United Stales litigation. When approached for an interview, Individual #28 refused to speak with the agents, and I remember S/A Kuyrkendall telling me that she fe
GRAND JURY PROCEEDINGS SEALED ORDER GRANTING APPLICATION FOR PERMISSION TO DISCLOSE GRAND JURY MATERIAL THIS MATTER has come before the Court on the United States' Sealed Application for Permission to Disclose Grand Jury Material and for Entry of a Protective Order. The Court has considered the Motion and find
d, directing their communications to MAUSA9 Andrew Lourie, Criminal Chief Matt Menchel, First Assistant Jeff Sloman, and U.S. Attorney Alex Acosta. AUSA Atkinson did participate in meetings with the Palm Beach Sheriff's Office about Epstein's work release and several conference calls with defendant attorney
n in county jail; (3) a methodology to compensate the victims identified by the United States; (4) entry EFTA00225699 U.S. Department of Justice United Slates Attorney Southern District of Florida First As,ramt US Attorney DELIVERY BY FACSIMILE Jay P. Lefkowitz, Esq. Kirkland & Ellis LLP Cifigroup Ce
or calls unless AUSA Villafana and/or her supervisors advise him otherwise. Furthermore, you make reference to "our July 8 deadline." Respectfully, the United States Attorney's Office for the Southern District of Florida ("SDFL") has never agreed to any such deadline. Should you decide to provide the SDFL with an
ations which ultimately resulted in United States Attorney R. Alexander Acosta's' December 19, 2007 letter to Lilly Ann Sanchez. In that letter, the United States Attorney tried to eliminate all concerns which, quite frankly, the SDFL was not obligated to address, let alone consider. He proposed the following
any such deadline. Should you decide to provide the SDFL with any additional information, please do so through AUSA Villafana, and, in her absence, AUSA Atkinson. On September 24, 2007, your client, Jeffrey Epstein, in consultation with Gerald Lefcourt, Esq. and Lilly Ann Sanchez, Esq., as well as numerous o
or calls unless AUSA Villafana and/or her supervisors advise him otherwise. Furthermore, you make reference to "our July 8 deadline." Respectfully, the United States Attorney's Office for the Southern District of Florida ("SDFL") has never agreed to any such deadline. Should you decide to provide the SDFL with an
any such deadline. Should you decide to provide the SDFL with any additional information, please do so through AUSA Villafana, and, in her absence, AUSA Atkinson. On September 24, 2007, your client, Jeffrey Epstein, in consultation with Gerald Lefcoun, Esq. and Lilly Ann Sanchez, Esq., as well as numerous ot
Entities connected to both United States and AUSA Atkinson

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATION
Alan Dershowitz
PERSON
Alexander Acosta
PERSONJane Doe
PERSONFBI
ORGANIZATION
Kenneth Marra
PERSON
Marc Rich
PERSONJack Goldberger
PERSONSouthern District
LOCATION
Joe Biden
PERSON
Jay Lefkowitz
PERSON
A. Marie Villafana
PERSONGerald Lefcourt
PERSON
Wilbur Ross
PERSON
Palm Beach Police Department
ORGANIZATION
Ken Starr
PERSON
United States District Court
ORGANIZATION