Epstein Secrets

y, and, as shown by Attachment E to the Black Affidavit, Epstein was receiving professional chiropractic services from a licensed chiropractor, Dr. Thomas Rofrano. Epstein's counsel misstates the state charges pending against his client. The state grand jury returned a three-count indictment. Each count charg

protected, not the relationship as a whole. McKay v. C.I.R. , 886 F.2d 1237 (9th Cir. 1989). VII. THE SUBPOENAS ARE NOT OPPRESSIVE, OVERBROAD, AND UNPARTICULARIZED. Epstein also asserts that the subpoenas seeking the computer equipment are unreasonable because they are oppressive, overbroad, and unparticulariz

y, and, as shown by Attachment E to the Black Affidavit, Epstein was receiving professional chiropractic services from a licensed chiropractor, Dr. Thomas Rofrano. Epstein's counsel misstates the state charges pending against his client. The state grand jury returned a three-count indictment. Each count charg

re protected, not the relationship as a whole. McKay' C.I.R. , 886 F.2d 1237 (9th Cir. 1989). VII. THE SUBPOENAS ARE NOT OPPRESSIVE, OVERBROAD, AND UNPARTICULARIZED. Epstein also asserts that the subpoenas seeking the computer equipment are unreasonable because they are oppressive, overbroad, and unparticulariz

l records including treatment notes of Mr. Epstein's treatment by a chiropractor (see Grand Jury Subpoena Duces Tecum, dated March 13, 2007, to Dr. Thomas Rofrano annexed as Exhibit "E"), and now, invasion of the defense camp by seeking records of the investigative work performed by Mr. Riley on behalf of you

ERMITTED TO SEIZE THE COMPUTERS ON THE BASIS OF A GRAND JURY SUBPOENA, THE SUBPOENAS MUST BE QUASHED AS UNREASONABLE AND OPPRESSIVE, OVERBROAD AND UNPARTICULARIZED. Paragraphs 1 and 2 of the subpoenas suggest no limitation on the ability of the govemmel ters. Instead, the government purports to be sessi