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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
nd jury subpoena to victim/witness, revisions to indictment, planned grand jury presentation, and plans to supersede indictment IS Ill 6/23/2008 DAG Filip completes review of Epstein's appeal 6/23/2008 6/23/2008-6/26/2008 Emails between Marie Villafaiia and grand jury witne, regarding immunity and tra
lm Beach, FL 33401 (561) 820-8711 Facsimile: (56!) 820-8777 July 10, 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
e victim all asked to address the Court. I cited the CVRA and other statutes to support the Court's authority to hear from them. The second case was United States' Oliver, which was the Office's first case seeking the appointment of a guardian ad litem (GAL). Through these cases, I researched statutes, cases,
, and London, England. Ms. Villafafia remained in civil practice, specializing in intellectual property litigation until 2001, when she was hired by the United States Attorney's Office in Miami. While she enjoyed civil practice, Ms. Villafafia for many years had wanted to be an Assistant United States Attorney. T
shes." (Exhibit B-19.) Although I did not know it at the time, in preparing this response, I noticed that, in FAUSA Sloman's June 3, 2008 letter to DAG Filip, he stated that the quoted language was proposed by USA Acosta "in consultation with DAAG Mandelker." (Exhibit B-123 at 7.) On December 21, 2007, a
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
and jury subpoena to victim/witness, revisions to indictment, planned grand jury presentation, and plans to supersede indictment B 13; 6/23/2008 DAG Filip completes review of Epstein's appeal 6/23/2008 6/23/2008-6/26/2008 Emits between Marie Villafana and grand jury witness regarding immunity and tra
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
if he wishes." (Exhibit B-19.) Although I did not know it at the time, in preparing this response, I noticed that, in FAUSA June 3, 2008 letter to DAG Filip, he stated that the quoted language was proposed by USA Acosta "in consultation with DAAG ." (Exhibit B-123 at 7.) On December 21, 2007, attorney
Entities connected to both United States and DAG Filip

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
LOCATIONJack Goldberger
PERSON
Julie K. Brown
PERSONSouthern District
LOCATION
Lesley Groff
PERSON
Joe Biden
PERSONMartin Weinberg
PERSON