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applies based upon the crime charged, then "the defendant carries the burden of production to come forward with evidence to rebut the presumption." United State v. Ouartermaine, 913 F.2d 910, 916 (11th Cir. 1990). Although the statutory presumption places a burden of production on a defendant, the burden of
original jurisdiction over the offense, a motion EFTA00191636 for revocation of the order or amendment of the conditions of release." Accordingly, the United States hereby files this emergency motion with the District Judge assigned to the case for immediate revocation of the Magistrate Judge's Order. THE CHARG
tates Supreme Court has interpreted this amendment to prohibit the imposition of excessLve bail without creating a right to bail in criminal cases. See United States' Salerno. 481 U.S. 739, 754.55 (1987)("Eighth Amendment does not grant absolute right to bail"). The subject of bail and detention also implicates t
atter for the pu ose of arriving at f its own "independent conclusion." See United States I uncan. 897 F. Supp. 688, 689-90 (N.D.N.Y. 1995) citing United States Lam, 766 F.2d Ch. 17 Bail and Deternion 553 EFTA00191622 77, 80 (2d Cir. 1985); see also U ted States ' King, 849 F.2d 485, 489-91 (11th Cir. 1988)
Division Rolando Garcia, Deputy Chief, Criminal Division Karen Atkinson, Chief, Northern Region From: cc: A. Marie Villafafia Drew Oosterbaan Myesha Braden INTRODUCTION This third supplement summarizes the changes to the indictment and prosecution memo since the first presentation in May 2007. The mos
lm Beach, FL 33401 (561) 820-8711 Facsimile: (56!) 820-8777 July 10, 2008 NOTIFICATION OF IDENTIFIED VICTIM NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED STATES CODE, SECTION 3509(d) AND FLORIDA LAW, THE ATTACHED DOCUMENT IS TO BE TREATED AS CONFIDENTIAL AND SHALL NOT BE DISCLOSED EXCEPT IN CONNECTION WITH
e victim all asked to address the Court. I cited the CVRA and other statutes to support the Court's authority to hear from them. The second case was United States' Oliver, which was the Office's first case seeking the appointment of a guardian ad litem (GAL). Through these cases, I researched statutes, cases,
, and London, England. Ms. Villafafia remained in civil practice, specializing in intellectual property litigation until 2001, when she was hired by the United States Attorney's Office in Miami. While she enjoyed civil practice, Ms. Villafafia for many years had wanted to be an Assistant United States Attorney. T
stein's team was equally successful in DC, where they dictated who could and could not participate in the "independent review" at CEOS. For example, Myesha Braden, who had not yet joined the Leap Year team, was excluded from consideration because she had disagreed with Lilly Ann Sanchez about the handling of
DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Matthewman JANE DOE #1 AND JANE DOE #2, Petitioners, v. UNITED STATES OF AMERICA, Respondent, UNITED STATES' NOTICE OF FILING SECOND SUPPLEMENTAL PRIVILEGE LOG Pursuant to the Court's June 18, 2013 Omnibus Order (DE 190), the Respondent, United States of A
nt, UNITED STATES' NOTICE OF FILING SECOND SUPPLEMENTAL PRIVILEGE LOG Pursuant to the Court's June 18, 2013 Omnibus Order (DE 190), the Respondent, United States of America, by and through the undersigned Assistant United States Attorney, hereby gives notice of its filing of its Second Supplemental Privilege Log. The in
pre-indictment consultation contract Work Product 6(e) Investigative Privilege P-013977 thru P-013979 5/21/2007 email from Marie Villafafia to Myesha Braden (CEOS) re 2423(b) charging question Work Product 6(e) Deliberative Process Investigative Privilege P-013980 5/21/2007 email from Marie Villafa
DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Matthewman JANE DOE #1 AND JANE DOE #2, Petitioners, v. UNITED STATES OF AMERICA, Respondent. UNITED STATES' NOTICE OF FILING SECOND SUPPLEMENTAL PRIVILEGE LOG Pursuant to the Court's June IS, 2013 Omnibus Order (DE 190), the Respondent, United States of A
nt. UNITED STATES' NOTICE OF FILING SECOND SUPPLEMENTAL PRIVILEGE LOG Pursuant to the Court's June IS, 2013 Omnibus Order (DE 190), the Respondent, United States of America, by and through the undersigned Assistant United States Attorney, hereby gives notice of its filing of its Second Supplemental Privilege Log. The in
pre-indictment consultation contract Work Product 6(e) Investigative Privilege P-013977 thru P-013979 5/21/2007 email from Marie Villafana to Myesha Braden (CEOS) re 2423(b) charging question Work Product 6(e) Deliberative Process Investigative Privilege P-013980 5/21/2007 email from Marie Villafa
counsel appearing on the attached service list. /s Dexter A. Lee Assistant United States Attorney II EFTA00191209 SERVICE LIST Jane Does 1 and 4 United States, Case No. 08-80736-CIV-MARRA/MATTHEWMAN United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer, Jaffe, Weissing,
ps taken to obtain DOJ authorization Work Product 6(e) Deliberative Process Investigative Privilege 2 5/21/2007 email from Marie Villafafta to Myesha Braden (CEOS) re 2423(b) charging question Work Product 6(e) Deliberative Process Investigative Privilege 3 5/21/2007 email from Marie Villafafia to
/ UNITED STATES' NOTICE OF FILING SECOND SUPPLEMENTAL PRIVILEGE LOG Pursuant to the Court's June IS, 2013 Omnibus Order (DE 190), the Respondent, United States of America, by and through the undersigned Assistant United States Attorney, hereby gives notice of its filing of its Second Supplemental Privilege Log. The in
pre-indictment consultation contract Work Product 6(e) Investigative Privilege P-013977 thru P-013979 5/21/2007 email from Marie Villafana to Myesha Braden (CEOS) re 2423(b) charging question Work Product 6(e) Deliberative Process Investigative Privilege P-013980 5/21/2007 email from Marie Villafa
Entities connected to both United States and Myesha Braden

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATIONLeon Black
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Alexander Acosta
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSON
Prince Charles
PERSON
New York
LOCATIONJack Goldberger
PERSONMaria Farmer
PERSON
Virginia Giuffre
PERSONSouthern District
LOCATION
Jay Lefkowitz
PERSONMartin Weinberg
PERSON
Southern District of New York
ORGANIZATION