Epstein Secrets

of the breach and then move forward with Epstein's prosecution. Accordingly, the undersigned would agree with Epstein's statement at page 4 of its Response, that the fact there exists a Non-Prosecution Agreement does not mean that Epstein is free from future criminal prosecution, and that in fact, "the

party meets its burden, the burden shifts to the moving party to show the information is relevant and necessary. Gober, 197 F.R.D. at 521; see also Hunter's Ridge Golf Co. Inc. v. Georgia-Pacific Corp., 233 F.R.D. 678, 680 (MD. Fla. 2006). Here, the information requested concerns Epstein's dates of tr

of the breach and then move forward with Epstein's prosecution. Accordingly, the undersigned would agree with Epstein's statement at page 4 of its Response, that the fact there exists a Non-Prosecution Agreement does not mean that Epstein is free from future criminal prosecution, and that in fact, "the

party meets its burden, the burden shifts to the moving party to show the information is relevant and necessary. Gober, 197 F.R.D. at 521; see also Hunter's Ridge Golf Co. Inc. v. Georgia-Pacific Corp., 233 F.R.D. 678, 680 (M.D. Fla. 2006). Here, the information requested concerns Epstein's dates of t

through the undersigned Assistant United States Attorney, hereby asks for permission to file a Supplemental ex parte Declaration in support of its Response to Jeffrey Epstein's Motion to Intervene and to Quash Subpoenas and Cross- Motion to Compel. In support thereof, the United States states the follow

be both (1) testimonial and (2) incriminating."). Later in his Reply, in order to avoid the clear similarity between this case and United States v. Hunter, Epstein goes out of his way to assert that the computers are not incriminating. Epstein argues: "Unlike a murder weapon or bank robbery proceeds,

he litigant standing to challenge the validity of that subpoena." In re Grand Jury, Ill F.3d 1066, 1073 (3d Cir. 1997)(collecting On page 38 of its Response, the government finally admits what it is looking for: evidence of sexual exploitation of minors, including surveillance camera footage, "computer p

poena, 204 F.3d 516 (4th Cir. 2000), see Response at 21-22, was simply a claim of privilege with respect to the client's identity. United States v. Hunter, 1995 WI, 12513 (N.D.111. January 6, 1995), does not, as the government would have it. "contain[] facts similar to the ones, at bar." Response at 21