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e and authenticate a defendant's tax-work papers. Fisher v. United States, 425 U.S. 391, 410 (1976). Jane Does 2-8 also rely extensively on U.S. v. Ghidoni, 732 F.2d 814 (11 th Cir. 1984) wherein the court directed a defendant to execute a consent directive to a foreign bank allowing the bank to releas
's 9 Case 9:08-cv-80119-KAM Document 522 Entered on FLSD Docket 04/09/2010 Page 10 of 15 accountant (Fisher) or a defendant's foreign bank (Ghidoni) where the Defendant in no way authenticates the documents nor attests to control or genuiness or even existence and, therefore, where no Fifth Ame
timonial admissions and to be a witness against himself and to authenticate the existence of certain items. In re Grand Jury Subpoena, 1F.3d 87, 93 (2d Cir. 1993). For the same reasons set out above, the interrogatories seek compelled statements and further ask that Epstein authenticate and testify to t
itten authorization allowing unidentified third-party banks to produce records within the banks' custody that relate to the target. United States v. Ghidoni , 732 F.2d 814 (11th Cir. 1984). In this case, the subpoenas are addressed to William Riley and to the Custodian of Records of Riley Kiraly. Neithe
would effectively insulate discoverable acts merely because they were enacted in the presence of an attorney.") (emphasis added). Just a month ago, the Second Circuit addressed this issue when a defendant tried to disqualify prosecutors who had seen four documents that the defense alleged were privileged. United
tten authorization allowing unidentified third-party banks to produce records within the banks' custody that relate to the target. United States v. Ghidoni, 732 F.2d 814 (11th Cir. 1984). In this case, the subpoenas are addressed to William Riley and to the Custodian of Records of Riley Kiraly. Neither
ould effectively insulate discoverable acts merely because they were enacted in the presence of an attorney.") (emphasis added). Just a month ago, the Second Circuit addressed this issue when a defendant tried to disqualify prosecutors who had seen four documents that the defense alleged were privileged. -19- EF
Entities connected to both Ghidoni and Second Circuit

Jeffrey Epstein
PERSON
United States
LOCATION
Julie K. Brown
PERSONJane Doe
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSON
Alan Dershowitz
PERSONFBI
ORGANIZATIONJack Goldberger
PERSONSouthern District
LOCATIONLeon Black
PERSON
Scarlett Johansson
PERSON
United States District Court
ORGANIZATIONEmmy Taylor
PERSON
Alexander Acosta
PERSONHubbell
PERSONWalker
PERSONRobert C. Josefsberg
PERSONRoy Black
PERSON
Adam D. Horowitz
PERSON