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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
hez, counsel to Mr. Epstein. Ms. Sanchez had formerly served as Deputy Chief in the Major Crimes Section at the USAO while Mr. Menchel was Chief of Major Crimes. As discussed below, on July 26, 2007, Criminal Chief Menchel announced to the investigative team that U.S. Attorney Acosta had decided to offer a
10T1 GEN I l OFFICE OF TH£ SOLICITOR GENERAL OFFICE SOLICI GEN OFFICE OF JUSTICE PROGRAMS OFfl, JUSTJ, PROGi EXEWTIVE O"ICE FOil THE UNITED STATB EXEWTI1 O"ICEF UNITED OFFICE OF DISPUTE RESOLUTION OFH DISPI RESOLI ASSOCIATE ATTORNEY GENERAL COMMUNITY OIIIENTED CIVIL RIGKTS -- DMS
RAL -- CRIMINAL IIUUAUOI' IN\lfSTlGATlON DIVISION DRUG BUREAU OF tNFCRClMENT -- AOMlfflSTRATION PRISONS EXEQITlVE UNITfD STATB Ol'RCEFOR -- UNITED STATl'S MARSHALS SERVICE ATTOIINEYS UNITED U.S.NATIONAL STATES -- CENTIIAL BUREAU ATTORNEYS INT1'RPOI. IUIIIAU OF OfFKEOl' THE Al.<Oo<OI., -- FED
fice for the Northern District of Georgia. 7 United States Attorney First Assistant United States Attorney Criminal Chief Managing Assistant United Stales Attorney West Palm Beach Office Assistant United States Attorney - - - -- May 23, 2006 i"' USAO opens federal • '-)~i:t~·tt:ier~~: F1IIiia U
ised him that she also represented Epstein. Sanchez was employed by the USAO from 2000 to September 2005 and had been a Deputy Chief of the USAO’s Major Crimes section at the time Menchel was the Chief. According to Sloman’s contemporaneous email recounting the conversation, when Sanchez indicated to him
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
matter with Lilly counsel to Mr. Epstein. Ms. had formerly served as Deputy Chief in the Major Crimes Section at the USAO while Mr. was Chief of Major Crimes. As discussed below, on July 26, 2007, Criminal Chief announced to the investigative team that U.S. Attorney Acosta had decided to offer I two-yea
Entities connected to both United States and Major Crimes

Jeffrey Epstein
PERSON
George W. Bush
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
PERSON
Donald Trump
PERSONJack Goldberger
PERSON
Julie K. Brown
PERSONSouthern District
LOCATION
Lesley Groff
PERSON
Joe Biden
PERSONMartin Weinberg
PERSON