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ket 06/02/2017 Page 2 of 10 5. In May 2005, then Attorney General Gonzales issued his Attorney General Guidelines for Victi
ndersigned counsel, files its Statement of Undisputed Material Facts in Support of Cross-Motion for Summary Judgment, and states: I. The Honorable Alberto Gonzales was sworn in on February 3, 2005, as Attorney General of the United States. 2. As Attorney General, Alberto Gonzales was the head of the Department
ve duties." EFTA00799595 Case 9:08-cv-80736-KAM Document 402 Entered on FLSD Docket 06/02/2017 Page 2 of 10 5. In May 2005, then Attorney General Gonzales issued his Attorney General Guidelines for Victim and Witness Assistance. Ex. M. When the non-prosecution agreement was negotiated in 2007-2008, th
port of Cross-Motion for Summary Judgment was filed with the Clerk of the Court and served on counsel on the attached service list using CM/ECF. Is/Dexter A. Lee Dexter A. Lee Assistant United States Attorney 9 EFTA00799603 Case 9:08-cv-80736-KAM Document 402 Entered on FLSD Docket 06/02/2017 Page 10 of 10
le others ordered private investigators to follow and intimidate the victims' families; one even posed as a police officer. • Then-Attorney General Alberto Gonzales told The Daily Beast that he "would have instructed the Justice Department to pursue justice without making a political mess." Film director Roman
police officer. • Then-Attorney General Alberto Gonzales told The Daily Beast that he "would have instruct
effrey Epstein the sex offender, rather than the prosecutors who work for you. Today we had a telephone conference call with two of your attorneys, Dexter Lee and Marie Villafana, in which they told us that we would not be receiving any cooperation from your Office on our CVRA case and that, in short, we
ld, withhold from the victims information in your Office's possession that would support their claims under the CVRA. After receiving approval from Dexter and Marie, we wanted to write to you personally in one last effort to see if we can narrow our differences on these two issues and avoid a disappoin
tance In May 2005, then Attorney General Alberto Gonzales issued the "Attorney General Guidelines for Vict
e of prosecutorial discretion. A. Compliance with Attorney General Guidelines for Victim and Witness Assistance In May 2005, then Attorney General Alberto Gonzales issued the "Attorney General Guidelines for Victim and Witness Assistance." Ex. M. Article II.D provides definitions of "crime victim": I. Enforce
ent and Cross-Motion for Summary Judgment was filed with the Clerk of the Court and served on counsel on the attached service list using CM/ECF. is/Dexter . Lee 31 EFTA00211748 SERVICE LIST Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. ~It Paul G. Cassell Pro Hac
e of prosecutorial discretion. A. Compliance with Attorney General Guidelines for Victim and Witness Assistance In May 2005, then Attorney General Alberto Gonzales issued the "Attorney General Guidelines for Victim and Witness Assistance." Ex. M. Article MD provides definitions of "crime victim": 1. Enforceme
tance In May 2005, then Attorney General Alberto Gonzales issued the "Attorney General Guidelines for Vict
ent and Cross-Motion for Summary Judgment was filed with the Clerk of the Court and served on counsel on the attached service list using CM/ECF. Is/Dexter A. Lee Dexter A. Lee Assistant United States Attorney 31 EFTA00799855 Case 9:08-cv-80736-KAM Document 408 Entered on FLSD Docket 06/06/2017 Page 32 of 3
o into matters of traditionally state concern, will continue to arise and will be answered case-by-case. As Justice O'Connor said in her dissent in Gonzales I Raich, 545 U.S. 1, 47 (2005), ". . . the task is to identify a mode of analysis that allows Congress to regulate more than nothing ... and less th
V, wit JAN 2i 2,2!3 .a4P En M ZIP t20-12E 3330 Dexter Lee A. Marie Villafatia 500 S. Australian Ave., Sui
CERTIFICATE OF SERVICE I certify that the foregoing document was served on January 21, 20 I 5, on the following using the Court's CM/ECF system: Dexter Lee A. Marie Villafafia 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 (561) 820-8711 Fax: (561) 820-8777 E-mail: [email protected] E-
e of prosecutorial discretion. A. Compliance with Attorney General Guidelines for Victim and Witness Assistance In May 2005, then Attorney General Alberto Gonzales issued the "Attorney General Guidelines for Victim and Witness Assistance." Ex. M. Article MD provides definitions of "crime victim": 1. Enforceme
tance In May 2005, then Attorney General Alberto Gonzales issued the "Attorney General Guidelines for Vict
ent and Cross-Motion for Summary Judgment was filed with the Clerk of the Court and served on counsel on the attached service list using CM/ECF. Is/Dexter A. Lee Dexter A. Lee Assistant United States Attorney 31 EFTA00591492 Case 9:08-cv-80736-KAM Document 401-2 Entered on FLSD Docket 06/02/2017 Page 33 of
police officer. * Then-Attorney General Alberto Gonzales told The Daily Beast that he “would have instruct
ile others ordered private investigators to follow and intimidate the victims’ families; one even posed as a police officer. * Then-Attorney General Alberto Gonzales told The Daily Beast that he “would have instructed the Justice Department to pursue justice without making a political mess.” Film director Roman P
according to Edwards. Edwards said the latter action “eviscerated the rights” of the two women to bring Epstein to justice. Assistant U.S. Attorney Dexter Lee told Marra that the Crime Victims’ Rights Act dictates that victim notification is triggered only after an indictment. Cassell disagreed. “It wasn’t
s "list"). The transcript of her interview with the Palm Beach Police over a year before the FRI became involved in any investigation shows that Ms. Gonzalez admitted to lying about her age. that she did not engage in sexual intercourse with Mr. Epstein, and that she was never induced over the telephone.
he asked of me. I immediately documented this conversation and informed the U.S. Attorney who informed Senior Litigation Counsel and Ethics Advisor Dexter Lee. AUSA Lee opined that he did not see a conflict. As soon as I -became aware of these allegations, I reported myself to the Office of Professional R
Entities connected to both Alberto Gonzales and Dexter Lee

Jeffrey Epstein
PERSON
A. Marie Villafana
PERSON
Alexander Acosta
PERSON
Bradley Edwards
PERSON
Jeffrey Sloman
PERSONJane Doe
PERSON
Kenneth Marra
PERSONLeon Black
PERSONKaren
PERSON
Karen Atkinson
PERSON
United States
LOCATION
Paul Cassell
PERSONMarie
PERSON
George W. Bush
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSONAlicia
PERSON
Department of Justice
ORGANIZATIONRoy Black
PERSON
Prince Andrew
PERSON