Epstein Secrets

. Sincerely, William L. Richey Transcnbed as Dictated.• Minted & Approved for Electronic Transmission Absent Signature WLR/ dct EFTA00178978 U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave.. Suite 400 ch, FL 3340! Facsimile: VIA FACSIMILE Roy Black, Esq.

at liberty to discuss this matter with you. Moreover, it is not the practice of this Office to discuss internal Department of Justice policies with non-Justice Department personnel. If Mr. believes he has cause to move to quash the subpoena, or if Mr. Epstein does for that matter, counsel for the respective parties

ropriety of those other subpoenas is not at issue here, the subpoenas to Mr. Riley and to his firm are. When it was pointed out to prosecutors that internal Department of Justice rules require, inter-O11a, that issuance of the subpoenas be predicated on the pre-approval of the Assistant Attorney General of the Criminal Divis

puters, it is that content which must be particularly described in the subpoena to comply with the reasonableness requirement. See In re Grand Jury Subpoena Duces Tecum Dated November 15, 1993, 846 F.2d 11, 13 (S.D.N.Y. 1994). The subpoenas at issue fail utterly to do so. Rather,- they are overbroad and unpar

RANSMISSION OK TX/RX NO 2691 CONNECTION TEL 3556727 SUBADDRESS CONNECTION ID ST. TIME 09/06 20:41 USAGE T 06'34 PGS. SENT 16 RESULT OK U.S. Department of Justice United States Attorney Southern District of Florida Ave. Suite 400 West Palm Beak Florida 33401 FACSIMILE COVER SHEET TO: DENISE COFFMAN, EGO,

Attorney West Palm Beach, FL 33401-6235 • To lass1 • In of AO110 FORM ORD-227 JAILF6 Case No. 08-80736-CV-MARRA P-000188 EFTA00227568 U.S. Departn of Justice United States Attorney Southern District of Florida 500 S Australian Ave.. Suite 400 West Palm Beach. FL 334014233 (361)8204711 APPEARANCE NOTI

. 431 F.2d 384, 388 (5th Cir.1970), cert. denied. 400 U.S. Page 14 1000, 91 S.Ct. 456, 27 L.Ed.2d 451 (1971); In re 1980 United States Grand Jury Subpoena Duces Team 502 F.Supp. 576, 579-80 (E.D.La.1980); United States v. Grand Jury Investigation, 417 F.Supp. 389, 393 (E.D.Pa.1976). Thus, the case law cl

U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mollo Building One Saint Andrew's Plaza New York. New York 10007 February 28

ny CONFIDENTIAL INFORMATION at trial in this matter."). The parties could not have—as, for example, they might in a bankruptcy proceeding such as in Subpoena Duces Tecwn—relied upon the Protective Order to indefinitely keep the relevant materials hidden. In this case, where the Protective Order is limited by i

poena to a defense investigator under these circumstances is the same as a subpoena to defense counsel. And USAM Guideline §9-11.255 requires prior Department of Justice approval for the issuance of a subpoena to a lawyer. That requirement evidently was not met. See Black Aft 115. Second, "because of the potential e

puters, it is that content which must be particularly described in the subpoena to comply with the reasonableness requirement. See In re Grand Jury Subpoena Duces Tecum Dated November 15, 1993, 846 F.2d 11, 13 (S.D.N.Y. 1994). The subpoenas at issue fail utterly to do so. Rather,-they are overbroad and unpart

U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mediu Building One Saint Andrew's Plaza New York. New York 10007 February 28

ny CONFIDENTIAL INFORMATION at trial in this matter."). The parties could not have—as, for example, they might in a bankruptcy proceeding such as in Subpoena Duces Tecwn—relied upon the Protective Order to indefinitely keep the relevant materials hidden. In this case, where the Protective Order is limited by i

U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Mediu Building One Saint Andrew's Plaza New York. New York 10007 February 28

ny CONFIDENTIAL INFORMATION at trial in this matter."). The parties could not have—as, for example, they might in a bankruptcy proceeding such as in Subpoena Duces Tecwn—relied upon the Protective Order to indefinitely keep the relevant materials hidden. In this case, where the Protective Order is limited by i

0: Exhibit 11: Exhibit 12: Notes from the U.S. Attorney's Office for the Southern District of New York June 14, 2007 Email November 2020 Report, U.S. Department of Justice, Office of Professional Responsibility Notes from February 11, 2021 Call Notes from February 29, 2016 Meeting November 30, 2018 Email December 6

401 (2d Cir. 2004) 36, 43, 44 In re Grand Jucv Subpoena Duces Tecum Dated Apr. 19, 1991, 945 F.2d 1221 (2d Cir. 1991) 108, 113 In re Grand Jury Subpoena Duces Tecum Dated Oct. 29, 1992, 1 F.3d 87 (2d Cir. 1993) 140, 145 In re Grand Jury Subpoena, 826 F.2d 1166 (1987) 136 In re Grand Jury Subpoena,

t 1: Notes from the U.S. Attorney's Office for the Southern District of New York Exhibit 2: June 14, 2007 Email Exhibit 3: November 2020 Report, U.S. Department of Justice, Office of Professional Responsibility Exhibit 4: Notes from February 11, 2021 Call Exhibit 5: Notes from February 29, 2016 Meeting Exhibit 6:

, 485 U.S. 681 (1988) 254 In re Enter. Mort. Acceptance Co. Sec. Litig. ("Enterprise", ), 391 F.3d 401 (2d Cir. 2004) 36,43,44 In re Grand Jury Subpoena Duces Tecum Dated Apr. 19, 1991, 945 F.2d 1221 (2d Cir. 1991) 108, 113 In re Grand Jury Subpoena Duces Tecum Dated Oct 29, 1992, 1 F.3d 87 (2d Cir. 199

t 1: Notes from the U.S. Attorney's Office for the Southern District of New York Exhibit 2: June 14, 2007 Email Exhibit 3: November 2020 Report, U.S. Department of Justice, Office of Professional Responsibility Exhibit 4: Notes from February 11, 2021 Call Exhibit 5: Notes from February 29, 2016 Meeting Exhibit 6:

, 485 U.S. 681 (1988) 254 In re Enter. Mort. Acceptance Co. Sec. Litig. ("Enterprise", ), 391 F.3d 401 (2d Cir. 2004) 36,43,44 In re Grand Jury Subpoena Duces Tecum Dated Apr. 19, 1991, 945 F.2d 1221 (2d Cir. 1991) 108, 113 In re Grand Jury Subpoena Duces Tecum Dated Oct 29, 1992, 1 F.3d 87 (2d Cir. 199

DFL has explained, the NPA did not bind other districts, and could not. That is because the USAO-SDFL lacked the authority to do so under applicable Department of Justice guidelines: Significantly, under the governing provision of the United States Attorney's Manual, the USAO-SDFL did not have the authority to unila

States, 485 U.S. 681 (1988) 166 In re Enter. Mort. Acceptance Co. Sec. Litig. ("Enterprise"), 391 F.3d 401 (2d Cir. 2004) 27, In re Grand Jury Subpoena Duces Tecum Dated Apr. 19, 1991, 945 F.2d 1221 (2d Cir. 1991) In re Grand Jury Subpoena Duces Tecum Dated Oct 29, 1992, 28, 77, 33 81 1 F.3d 87 (2d