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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
the victims that they had the absolute right to select another attorney if they so desired, were not inappropriate solicitations and did not violate the Florida Bar Rules. The attorney who filed the complaint, Jeff Herman, later resigned from the Florida Bar due to disciplinary action taken against him. Page 11 of 5
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
the victims that they had the absolute right to select another attorney if they so desired, were not inappropriate solicitations and did not violate the Florida Bar Rules. The attorney who filed the complaint, Jeff Herman, later resigned from the Florida Bar due to disciplinary action taken against him. Page 11 of 5
an Ave., Suite 400 West Palm Beach, FL 33401 Facsimile: September 3, 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
dated September 2, 2008. Please be advised that we strenuously object to your letters on various grounds, and believe that they are in violation of the Florida Bar Rules. First, your letters attempt to steer the victims to a particular attorney, Mr. Josefsberg, and advise them that Mr. Jose fsberg will be making an
008. After Epstein’s June 30, 2008 state court pleas, she sent out substantially similar notification letters to two victims who resided outside of the United States. 222 We will make our best efforts to ensure you are accorded the rights described. Most of these rights pertain to events occurring after
advise them that an attorney will be contacting them regarding possible claims against Mr. Epstein. If we don’t do that, it may be a violation of the Florida Bar Rules for the selected attorney to ‘cold call’ the girls. As discussed in greater detail in Chapter Two, on October 23, 2007, Lefkowitz sent Acosta a
Entities connected to both United States and the Florida Bar Rules

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATIONLeon Black
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Alexander Acosta
PERSONJane Doe
PERSONFBI
ORGANIZATION
Kenneth Marra
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
Julie K. Brown
PERSON
Lesley Groff
PERSON
Joe Biden
PERSON
Jay Lefkowitz
PERSON
Southern District of New York
ORGANIZATION
A. Marie Villafana
PERSON
Martha Stewart
PERSON