Epstein Secrets

400 West Palm Beach, FL 33401 Telephone: Facsimile: I 6 EFTA00086382 GOVERNMENT EXHIBIT Case No. 08-80736-CV-MARRA P-001713 EFTA00086383 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA FCII 07-103 (WPB) IN RE: GRAND JURY PROCEEDINGS Party Filing Matter Under Seal ORDER RE: SEALED FILING Name: UNI

strict of Florida, and it appearing to the satisfaction of the Court: 1. That has been called to testify and to provide other information before the United States District Court for the Southern District of Florida, including a Grand Jury impanelled therein; and 2. That in the judgment of the said United States Attorney,

that "it is essential that a lawyer work with a certain degree of privacy, free from unnecessary intrusion by opposing parties and their counsel." Hickman v. Taylor, 329 U.S. 495, 510 (1947). The privilege is codified at Federal Rule of Civil Procedure 26(b)(3): Ordinarily, a party may not discover documents an

ROY BLACK an attorney at law, duly sworn, deposes and says: 1. I am an attorney at law, duly admitted to practice before the State of Florida and the United States District Court for the Southern District of Florida. 2. As detailed further below, I am counsel to Jeffrey Epstein, the movant herein. It is my intention herein

:4/17/2007 :4L FM Mal: 1/1 Y 1, am L. Richey, P Yiliiaa L. Richey, P.A. TO: 5 PAGE: 002 OF 00; UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA FGJ 07-103 (WPB) IN RE GRAND JURY SUBPOENAS DUCES TECUM NUMBERS FILED UNDER SEAL OLY-63 & OLY-64 REPLY OF WILLIAM

oenas violate the work-product doctrine, as well as Mr. Epstein's Fifth Amendment right to due process and his Sixth Amendment right to counsel. In Hickman v. Taylor, 329 U.S. 495, 510-11 (1947), the Supreme Court recognized the modern work- product doctrine, holding that: [lin performing his various duties, how

rt file O Destroyed 0 Returned to the party or counsel for the party, as identified above A`tancy for: United Stales of Vifierica EFTA00179092 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE: GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY-64 AND OLY-64 FGJ 07-103 (WPB) MOTION FOR LEAVE TO FILE SUPPLE

ain hidden in an attorney's file and where production of those facts is essential to that preparation of one's case, discovery may properly be had." Hickman v. Taylor, 329 U.S. 495, 511 (1947). Furthermore, the "work product rule protects work done by an attorney in anticipation of, or during, litigation," In re