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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
# 9/18/2007 12:22 pm draft Plea Agreement 9/18/2007 1:37pm draft Information 9/18/2007 Garcia, Villafaiia Lourie Email stating new terms that Louric negotiated with Lefkowitz 9/19/2007 A. Laurie, R. Garcia, K. A. Marie Villafana Email re negotiating strategy with attached correspondence l6
erson can be charged with a criminal 39 EFTA01718615 . offense, that is a violation of Florida Statutes Section 794.05; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 14 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 49. Paragraphs 1 through 19 of this Indictment are re-alleged
ity or process of the prior prosecution. not the sentencing outcome. Second, the state plea agreement offered was not "manifestly inadequate" tinder U.S.A.M. § 9- 2.03ID. indeed, the only real difference hews= the state and federal plea proposals was whether Mr. Epstein served his sentence in jail or comm
n to undertake discussion with the $tate Attorney's Office In ensure compliance with these procedures, which compliance will be necessary to satisfy the United States' interest. pursuant to the Perire policy. We reiterate that this case was at heart a local matter that was being fully addressed by the state crimi
ed in tc nited States Attorney's Manual that require prior notification to Washington necessary to seek a I• t 'cords). We once more requested Mr. Louric to intervene. Despite these efforts. Ms. followed up with a subpoena fur Mr. linetein's confidential medical records served direct y on his chiropr
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
out Lefkowitz's proposed language regarding immigration proceedings 9/21/2007 4:47 pm Epstein state plea jpl edits (Lefkowitz) 9/23/2007 Acosta, Louric, Sloman, Villafatia Lefkowitz Email admitting that defense based their agreement to plead to 796.03 on a "mistaken assumption" and requesting th
counsel appearing on the attached service list. /s Dexter A. Lee Assistant United States Attorney II EFTA00191209 SERVICE LIST Jane Does 1 and 4 United States, Case No. 08-80736-CIV-MARRA/MATTHEWMAN United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer, Jaffe, Weissing,
3 P-013874 Through P-013875 Inadvertently marked as privileged, will be produced Suppl. Box 3 P-013876 Thru P-013877 E-mail, Villafana to Louric, 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
Entities connected to both United States and Louric

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
PERSONJack Goldberger
PERSON
Julie K. Brown
PERSONSouthern District
LOCATION
Lesley Groff
PERSON
Joe Biden
PERSONMartin Weinberg
PERSON
Jay Lefkowitz
PERSON
A. Marie Villafana
PERSON
George Mitchell
PERSON