Epstein Secrets

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,

211804 U.S. Attorney 5 s Office 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Telephonel Facsimile: I Attorney for United States William L. Richey, Esq. William L. Richey P.A Miami, Fl Telephon Facsimile: Attorney for Subpoenaed Parties Riley Kiraly and William Riley Service via U.S. Mail

tates in evaluating that claim, but Epstein has objected to the production of those documents. F.I 1Although unpublished, the case of United States' Hunter , 1995 WL 12513 (N.D. III. Jan. 6, 1995), contains facts similar to the ones at bar and gives a detailed analysis of the applicability of the attorn

o. OLY-63 and OLY-64 United States District Court, Southern District of Florida Assistant U.S. Attorney Attorney for United States EFTA00223014 William L. Richey, Esq. Attorney for Subpoenaed Parties Riley Kiraly and William Riley Service via Federal Express Roy Black, Esq. Attorney for Intervenor Jeffrey

t be both (1) testimonial and (2) incriminating."). Later in his Reply, in order to avoid the clear similarity between this case and United States. 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,

7 EFTA00234920 SERVICE LIST In re Federal Grand Jury Subpoenas No. OLY-63 and OLY-64 United States District Court, Southern District of Florida William L. Richey, Esq. 8 EFTA00234921

ference must have specified -the purpose for which the computers were seized and delineated the limits of their subsequent search". United States v. Hunter, 13 F.Supp.2d 574, 584 (D.Vt. 1998) Given these principles, the Requests contained in ¶'s 1 and 2 of the subpoenas are clearly unreasonable, since

Biscayne Boulevard, 34th Floor, Miami Center, Miami, Florida 331314325 •---- Facsimile EFTA00178967 x/17/.:007 PH FRCII: VI: 1 ar L. Richey, P William L. Richey, P.A. TO:, ' • PAGE: 00"; of FGJ 07-103 (WPB) Therefore, contrary to the Government's claim. Riley did not flout the subpoena. Rather. Riley's n