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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
11/28/2007 with attachment 7/8/2008 Goldberger Villafafia Letter re victim notification letters B-57 7/8/2008 Lee, Sloman, cc: Villafafia, Jacobus Acosta Email with attached second draft of response in Jane Doe case 7/8/200s Villafafia Goldberger Letter that he will respond on 7/9/08 B-58
oy Black Email chain regarding call relating to the performance of the criminal Non- Prosecution Agreement 8/1/2008 Lee, Acosta; cc: Villafaiia, Jacobus, Senior Sloman Email chain regarding Jane Doe litigation 8/2/2008 Lee, Villafaiia Acosta Email re: Letter from Brad Edwards 8/5/2008 A. Acost
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
11/28/2007 with attachment 7/8/2008 Goldberger Villafatia Letter re victim notification letters It ,- 7/8/2008 Lee, Sloman, cc: Villafatia, Jacobus Acosta Email with attached second draft of response in Jane Doe case 7/8/2008 Villafatia Goldberger Letter that he will respond on 7/9/08 B-58
Roy Black Email chain regarding call relating to the performance of the criminal Non Prosecution Agreement 8/1/2008 Lee, Acosta; cc: Valhalla, Jacobus, Senior Sloman Email chain regarding Jane Doe litigation 8/2/2008 Lee, Valhalla Acosta Email re: Letter from Brad Edwards 8/5/2008 A. Acosta,
I) Subject: Update on Jane Doe I United States Dexter is en route to the NAC and asked me to update you on this morning's happenings in Jane Doe I United States. This morning, Judge Marra's clerk contacted Dexter Lee to set a status conference on the matter. You will recall that, last week, Dexter filed a N
VI',Wane, Ann Marie C. (USAFLS) Sent: Monday, August 04, 2008 10:31 AM To: Acosta, Alex (USAFLS); Sloman, Jeff (USAFLS); Senior, Robert (USAFLS); Jacobus, Wendy (USAFLS) Cc: Lee, Dexter (USAFLS); Atkinson, Karen (USAFLS); Kuyrkendall, E N. (FBI); Richards, Jason R. (FBI) Subject: Update on Jane D
enied that one of these victims is entitled to proceed under 18 U.S.C. § 2255, that will be considered a breach of the Non-Prosecution Agreement and the United States will proceed accordingly. Sincerely, R. Alexander Acosta United States Attorney afr By: cc: Karen Atkinson, AUSA A. Marie Villafafla Assistan
<[email protected]> Sent: Tuesday, July 8, 2008 6:17 PM To: Lee, Dexter (USAFLS); Sloman, Jeff (USAFLS) Cc: Villafana, Ann Marie C. (USAFLS); Jacobus, Wendy (USAFLS) Subject: RE: Draft Response in Jane Doe Attachments: victim_resp.wpd Here is a second draft, with small rewrites I reduced the
rom E0USA on whether this Office can continue to represent the government in the defense of a Crime Victims Rights Act lawsuit, Jane Does 1 and 2'. United States, Case No. 08.80736-CIV-MARRA (S.D.Fla.), in light of a request by Paul Cassell, counsel for the victims, asking for an investigation of this office
Lorene From: Lee, Dexter (USAFLS) Sent: Thursday, December 16, 2010 10:38 AM To: USAE0-GC0 Duty Cc: Villafana, Ann Marie C. (USAFLS); (USAFLS); Jacobus, Wendy (USAFLS) Subject: Request for Advice and Guidance on Potential Office-Wide Recusal - Crime Victims Rights Litigation We are seeking guidance
al Counsel on whether this Office can continue to represent the government in the defense of a Crime Victims Rights Act lawsuit, Jane Does 1 and 2'. United States, Case No. 08.80736-CIV-MARRA (S.D.Fla.), in light of a request by Paul Cassell, counsel for the victims, asking for an investigation of this office
00229691 Peter- Please see duty matter below. Thank you. Lorene Froa Th p... Sent: urs ay, ember 16, 2010 10:38 AM To: . (USAFLS); (USAFLS); Jacobus, Wendy (USAFLS) or Advice and Guidance on Potential Office-Wide Recusal - Crime Victims Rights Litigation We are seeking guidance and advice from E
Entities connected to both United States and Jacobus

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Department of Justice
ORGANIZATIONthe Southern District
LOCATIONLeon Black
PERSON
Prince Andrew
PERSON
Alexander Acosta
PERSON
Alan Dershowitz
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSONFBI
ORGANIZATIONJack Goldberger
PERSON
Julie K. Brown
PERSON
A. Marie Villafana
PERSONSouthern District
LOCATION
Lesley Groff
PERSON
Joe Biden
PERSONMartin Weinberg
PERSON
Paul Cassell
PERSON