Epstein Secrets

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

[defendant] from his files; [c]learly such an act of production is testimonial, and may not be compelled"); United States v. Bell, 217 F.R.D. 335 (M.D. Pa. 2003) (where government lacks knowledge of specific documents, party's production of the subpoenaed documents would testify to their existence and his p

Beach, Florida. KENNETH A. MARRA UNITED STATES DISTRICT JUDGE cc: AUSA M IATest Palm Beach Roy Black, Esq. William Richey, Esq. EFTA01728800 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE GRAND JURY SUBPOENAS DUCES TECUM NUMBERS MOTION TO FILE DOCUMENTS UNDER SEAL FILED UNDER SEAL EFTA01728801

allow Court to conduct in camera inspection to determine whether act of production privilege applied); United States v. Be11,3 217 F.R.D. 335, 339 (M.D. Pa. 2003) (Although voluntarily created documents are not protected by the Fifth Amendment, an act of production privilege can be asserted, but only when "it

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

allow Court to conduct in camera inspection to determine whether act of production privilege applied); United States v. Bell; 217 F.R.D. 335, 339 (M.D. Pa. 2003) (Although voluntarily created documents are not protected by the Fifth Amendment, an act of production privilege can.be asserted, but only when "it