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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
person. and assisted in finding counseling and other services for them. Justice Denar ment Personnel CEOS Deputy Chief Gelber (still at DOJ): Ms. Gelber was part of the team that reviewed the case and the NPA when Epstein "appealed" to DOJ. Ms. Gelber also is familiar with my work from a prior case
victims, met with them in person. and assisted in finding counseling and other services for them. Justice Denar ment Personnel CEOS Deputy Chief Gelber (still at DOJ): Ms. Gelber was part of the team that reviewed the case and the NPA when Epstein "appealed" to DOJ. Ms. Gelber also is familiar with
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
y. Now, victims from many child pornography "series" have been identified and have attorney contact information for purposes of restitution. CEOS' Gelber is the national expert in this area. To summarize, my understanding of my obligation was: to do my best to notify victims of upcoming court proceed
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,
on Deliberative Process Work Product Attorney-Client Privilege 30 3/19/2008-3/21/2008 emails between Marie Villafafia, Drew Oosterbaan (CEOS), Gelber (CEOS), Jeff Sloman, and Robert Senior about meeting between Esptein counsel and CEOS and follow-up questions Work Product 6(e) Deliberative Pr
Entities connected to both United States and Gelber

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
PERSONFBI
ORGANIZATION
Kenneth Marra
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
Virginia Giuffre
PERSON
Joe Biden
PERSONMartin Weinberg
PERSON
Jay Lefkowitz
PERSON
A. Marie Villafana
PERSON
Eric Trump
PERSONRoy Black
PERSON