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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
Lilly Ann Sanchez A. Marie Villafaria Requesting a meeting to discuss 11/16/06 letter 11 11/29/2006 Lilly Ann Sanchez A. Marie Villafafia AUSA Villafatia will be out of district and will not be available for meeting during the proposed dates, but will schedule the meeting when she returns. 1 1 I 2/1
nd date a copy of this letter in the space provided below as an acknowledgment that you have received, read, EFTA00206895 Re: Jane Does #1 and #2 I. United States Case No.: 9:08-cv-80736-KAM November 2, 2010 Page -4- Privileged Communication and agree to comply with the preservation instructions contained i
ication letters that were sent. DE 14. Attached to that Declaration are copies of redacted letters provided to victims "C.W.", "T.M.", and "S.R." by AUSA Villafatia and the FBI's Victim-Witness Specialist Twiller Smith. DE 14. In addition, appended to the Declaration are AUSA letters to the victim's counsel, B
of Litigation Hold Letter: I acknowledge that I have received and read the Litigation Hold letter dated November 2, 2010 regarding Jane Does #1 and Itli United States, Case No.: 08-80736-CP/-MARRA/Johnson and I have taken and agree to continue to take all reasonable steps necessary to preserve the documents and da
ication letters that were sent. DE 14. Attached to that Declaration are copies of redacted letters provided to victims "C.W.", "T.M.", and "S.R." by AUSA Villafatia and the FBI's Victim-Witness Specialist Twiller Smith. DE 14. In addition, appended to the Declaration are AUSA Villafaila's letters to the victim'
mail chain from Jeff Sloman to Andrew Oosterbaan, Marie Villafana, and Alex Acosta regarding Epstein meeting 8/ 7/ 200- Reply of Jeffrey Epstein to United States' Response to His Motion to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel and Sealed Document Tracking Form 8/8/2007 Andre
Lilly Ann Sanchez A. Marie Villafaila Requesting a meeting to discuss 11/16/06 letter I 11/29/2006 Lilly Ann Sanchez A. Marie Villafatia AUSA Villafatia will be out of district and will not be available for meeting during the proposed dates, but will schedule the meeting when she returns. I I 12/1/
Entities connected to both United States and AUSA Villafatia

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
Scarlett Johansson
PERSONJack Goldberger
PERSON
Julie K. Brown
PERSON
Lesley Groff
PERSON
Joe Biden
PERSONMartin Weinberg
PERSON
Jay Lefkowitz
PERSON
A. Marie Villafana
PERSON
the United States District Court
ORGANIZATION