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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
SC Coordinator, on September 26, 2006, I had prepared a memo to management summarizing the Adam Walsh Child Protection and Safety Act of 2006 (the "Adam Walsh Act") (Exhibit 16). One of the provisions of the Adam Walsh Act that I noted was an amendment to 18 U.S.C. § 2255: "Section 2255 has been expanded to al
istration of Mr. Jeffrey Epstein, Offender ID' as a sex offender in the State of New York, this is to advise you 23, 2016, Mr. Epstein was issued a United States Passport bearing Passport No and expiring May 22, 2026. This assport replaces Mr. Epstein's United States Passport bearing Passport No. A copy of
my colleague, Kimberly Homan Esq, spoke briefly with you regarding Mr. Epstein, and ascertained that the State of New York has not yet adopted the Adam Walsh Act SORNA guidelines, including, specifically, the guideline imposing certain notification responsibilities on a registered offender when his travel, aw
internal as I tried to deal professionally with opposing counsel. In the midst of all of the post-NPA back-and-forth with Epstein, was the Jane Doe. United States litigation.4 Despite the Office's request to be recused from the case, the Justice Department decided that there was no conflict of interest and I w
SC Coordinator, on September 26, 2006, I had prepared I memo to management summarizing the Adam Walsh Child Protection and Safety Act of 2006 (the "Adam Walsh Act") (Exhibit 16). One of the provisions of the Adam Walsh Act that I noted was an amendment to 18 U.S.C. § 2255: "Section 2255 has been expanded to al
Entities connected to both United States and Adam Walsh Act

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATIONLeon Black
PERSON
Alan Dershowitz
PERSON
Alexander Acosta
PERSONJane Doe
PERSONFBI
ORGANIZATION
Kenneth Marra
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONDarren Indyke
PERSON
Lesley Groff
PERSON
Joe Biden
PERSONMartin Weinberg
PERSON
Jay Lefkowitz
PERSON
Martha Stewart
PERSONRoy Black
PERSON