Epstein Secrets

. 1980); United States v. Landof, 591 F.2d 36, 38 (9th Cir. 1978); In re Grand Jury Proceedings, 73 F.R.D. 647, 651 (M.D. Fl. 1977)). In Blackburn, the Middle District of Florida applied the act of production privilege under the premise that Boyd was still binding precedent. Even applying Boyd, the court found that

Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross- Motion to Compel, Ex Parte Declaration Number One in Support of United States' Response to Motion to Quash Subpoenas, the Declaration of , and the Ex Parte Declaration Number Two in Support of United States' Response to Motio

ct Court for the Southern District of Florida; and (2) I am a member in good standing of the Florida Bar and the bar for the U.S. District Court for the Middle District of Florida. EFTA00177249 Case 9:08-cv- 3-KAM Document 20 Entered on FLED Docket 08/ 08 Page 6 of 7 CERTIFICATE OF SERVICE 1 HEREBY CERTIFY

he sworn declaration of the Assistant U.S. Attorney handling this matter also recounts the same language. See Declaration of A. Marie Villafafia in Support of United States' Response to Victims' Emergency Petition at 3-4. The sworn declaration also states that victims were told about this language in October 2007. See D

e documents being held by the U.S. Attorney's Office in the other district that is handling conflict matters. (It appears that this other office is the Middle District of Florida.) This appears to be improbable, because the conflict matters would presumably generate many documents covered by the victims' discovery

Victim's Petition; CVRA- authorized release; Material Severable Box #3 P-012171 Thru P-012173 Supplement to Ex Parte Declaration Number One in Support of United States' Response to Motion to Quash Subpoenas 6(e) Investigative Privilege Also contains information subject to privacy rights of victims who are not