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

rth Amendment's particularity requirement and overbreadth prohibition are critical in the context of computer searches. See, e.g., United States v. Adjani, 452 F.3d 1140, 1149 (9th Cir. 2006) ("[wje understand the heightened specificity concerns in the computer context, given the vast amounts of data

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

rth Amendment's particularity requirement and overbreadth prohibition are critical in the context of computer searches. See, e.g., United States v. Adjani, 452 F.3d 1140, 1149 (91h Cir. 2006) ("[w]e understand the heightened specificity concerns in the computer context, given the vast amounts of data

000996 EFTA00228376 4 • EFTA00228377 Case No. 08-80736-CV-MARRA P-000998 EFTA00228378 Case No. 08-80736-CV-MARRA P-000999 EFTA00228379 U.S. Department of Justice United States Attorney Southern District of Florida 500 South Australian Ave, Suite 40', West Palen Beach. FL 33401 (361)8104711 August 15, 200

d States I. Adiani 452 F.3d 1140 (9th Cir. 2006), the court observed that ...the warrant arguably might have provided for a "less invasive search of Adjani's [email) 'inbox' and 'outbox' for the addressees specifically cited in the warrant, as opposed to the wholesale search of the contents of all emai