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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
led to AAG Alice Fisher, Mr. Lourie was on detail as AAG Fisher's Chief of Staff and facilitated the meeting between Epstein's counsel and the AAG. AAG Fisher's written response was issued while MAUSA Lourie was still her Chief of Staff. I do not know who drafted the written response. Acting MAUSA Rolando G
ATTORNEY FOR JEFFREY EPSTEIN EFTA00225211 U.S. Department nfitist ire United States Attorney Southern District of Florida R ALEXANDER ACOSTA UNITEDSTATES ATTORNEY DELIVERY BY FACSIMILE Lilly Ann Sanchez Fowler White Burnett, PA 1395 Brickell Ave, 14th Floor Miami, FL 33131 Re: Jeffrey Epstein D
leged — Attorney Work Product EXHIBIT B-123 EFTA00225178 Division Andrew Lourie, Chief of the Criminal Division Matthew Menchel', First Assistant United States Attorney Jeffrey H. Sloman', United States Attorney R. Alexander Acosta as well as various members of the Child Exploitation and Obscenity Section (
mate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration. 13. The parties anticipate that t
s the interim Chief of the Public Integrity Section at DOJ at the request of AAG Fisher. By October 2007, Mr. Lourie would leave the SDFL to become AAG Fisher's Chief of Staff.' Above Mr. Lourie in the SDFL's chain of command were Matthew Menchel, Criminal Division Chief, First Assistant USA Sloman and final
e following language regarding the 2255 provision: "Any person, who while a minor, was a victim of a violation of an offense enumerated in Tide 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein been tried federally and convicted
s the interim Chief of the Public Integrity Section at DOJ at the request of AAG Fisher. By October 2007, Mr. Lourie would leave the SDFL to become AAG Fisher's Chief of Staff.2 Above Mr. Lourie in the SDFL's chain of command were Matthew Menchel, Criminal Division Chief, First Assistant USA Sloman and fina
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
E stein's attorneys appealed to AAa., Mr. was on detail as AAG Chief of Staff and facilitated the meeting between Epstein's counsel and the AAG. AAG Fisher's written response was issued while MAUSA was still her Chief of Staff. I do not know who drafted the written response. Acting MAUSA (still with th
following language regarding the 2255 provision: "Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, § 2255, will have the same rights to proceed under § 2255 as she would have had, if Mr. Epstein been tried federally and convicted of an enume
s the interim Chief of the Public Integrity Section at DOJ at the request of AAG Fisher. By October 2007, Mr. Lourie would leave the SDFL to become AAG Fisher's Chief of Staffs Above Mr. Lourie in the SDFL's chain of command were Matthew Menchel, Criminal Division Chief, First Assistant USA Sloman and final
following language regarding the 2255 provision: "Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she would have had, if Mr. Epstein been tried federally and convicted
s the interim Chief of the Public Integrity Section at DOJ at the request of AAG Fisher. By October 2007, Mr. Lourie would leave the SDFL to become AAG Fisher's Chief of Staff.2 Above Mr. Lourie in the SDFL's chain of command were Matthew Menchel, Criminal Division Chief, First Assistant USA Sloman and fina
following language regarding the 2255 provision: "Any person, who while a minor, was a victim of a violation of an offense enumerated in Title 18, United States Code, § 2255, will have the same rights to proceed under § 2255 as she would have had, if Mr. Epstein been tried federally and convicted of an enume
s the interim Chief of the Public Integrity Section at DOJ at the request of AAG Fisher. By October 2007, Mr. Lourie would leave the SDFL to become AAG Fisher's Chief of Staff.5 Above Mr. Lourie in the SDFL's chain of command were Matthew Menchel, Criminal Division Chief, First Assistant USA Sloman and fina
mate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration. 13. The parties anticipate that t
as the interim iallifiLof the Public Integrity Section at DOJ at the request of AAG Fisher. By October 2007. Mr. UM would leave the SDFL to become AAG Fisher's Chief of Staff.' Above Mr. in the SDFL's chain of command were 1 Criminal Division Chief, First Assistant USA Sloman and finally, U.S. Attorney A
Entities connected to both United States and AAG Fisher's

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
New York
LOCATION
Bill Clinton
PERSONJack Goldberger
PERSON
Lesley Groff
PERSON
Joe Biden
PERSONMartin Weinberg
PERSON
Jay Lefkowitz
PERSON