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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
to Laurie and R. Garcia - draft plea agreement issues l6 9/19/2007 Andrew Lourie, Rolando Garcia, Karen Atkinson A. Marie Villafana Email re Draft Plea Agreement with email from Lefkowitz to Villafana (9/19/07) and Lefkowitz to Villafana (9/19/07) attached 46 9/ 19/2007 Research re Federal Bureau of Prison
e)(3)(E); Court Inherent Power to Release; Proper Victim's Petition; CVRA-authorized release; Material Severable Box #3 P-012089 Thru P-012129 United States' Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel 6(e) Inadequate Log; No Factual
s Through P-013875 Suppl. Box 3 P-013876 Thru P-013877 E-mail, Villafana to Lourie,Garcia, and Atkinson, September 19, 2007, 4:33 p.m., RE: Draft Plea Agreement, with e-mail from Lefkowitz to Villafana (September 19, 2007, 3:44 p.m.), and Lefkowitz to Villafana (September 19, 2007, 3:35 p.m.) attached An
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
to Lourie and R. Garcia - draft plea agreement issues if) 9/19/2007 Andrew Lourie, Rolando Garcia, Karen Atkinson A. Marie Villafana Email re Draft Plea Agreement with email from Lefkowitz to Villafafia (9/19/07) and Lefkowitz to Valhalla (9/19/07) attached 9/19/2007 Research re Federal Bureau of Prisons Des
andatory for wire fraud only if the government exercises its discretion to seek such forfeiture. See 28 U.S.C. § 2461(c); Fed. R. Crim. P. 32.2(a); United States v. Liquidators of European Fed. Credit Bank, 630 F.3d 1139, 1144 (9th Cir. 2011) (describing procedure for forfeiture). "[T]he Government retains b
s Through P-013875 Suppl. Box 3 P-013876 Thru P-013877 E-mail, Villafana to Lourie,Garcia, and Atkinson, September 19, 2007, 4:33 p.m., RE: Draft Plea Agreement, with e-mail from Lefkowitz to Villafana (September 19, 2007, 3:44 p.m.), and Lefkowitz to Villafana (September 19, 2007, 3:35 p.m.) attached At
Entities connected to both United States and Draft Plea Agreement

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
New York
LOCATIONJack Goldberger
PERSON
Julie K. Brown
PERSON
Samantha Power
PERSONSouthern District
LOCATION
Lesley Groff
PERSON
Joe Biden
PERSONMartin Weinberg
PERSON
Jay Lefkowitz
PERSON