Epstein Secrets

m Epstein's home. The Fifth Amendment privilege "protects a person . . . against being incriminated by his own compelled testimonial communication." Fisher v. United States , 425 U.S. 391, 409 (1976). Thus, to receive Fifth Amendment protection, a person's statement or act must be: (1) compelled; (2) t

ney (or his agent) can use the attorney-client privilege to EFTA00211784 assert an act of production immunity on behalf of his client. See, e.g., Fisher , 425 U.S. at 402-04. Those circumstances do not apply here. In Fisher , the Supreme Court determined that a defendant does not suffer a Fifth Amen

protected, not the relationship as a whole. McKay v. C.I.R. , 886 F.2d 1237 (9th Cir. 1989). VII. THE SUBPOENAS ARE NOT OPPRESSIVE, OVERBROAD, AND UNPARTICULARIZED. Epstein also asserts that the subpoenas seeking the computer equipment are unreasonable because they are oppressive, overbroad, and unparticulariz

m Epstein's home. The Fifth Amendment privilege "protects a person . . . against being incriminated by his own compelled testimonial communication." Fisher I United States , 425 U.S. 391, 409 (1976). Thus, to receive Fifth Amendment protection, a person's statement or act must be: (1) compelled; (2) te

ney (or his agent) can use the attorney-client privilege to EFTA00223000 assert an act of production immunity on behalf of his client. See, e.g., Fisher , 425 U.S. at 402-04. Those circumstances do not apply here. In Fisher , the Supreme Court determined that a defendant does not suffer a Fifth Amen

re protected, not the relationship as a whole. McKay' C.I.R. , 886 F.2d 1237 (9th Cir. 1989). VII. THE SUBPOENAS ARE NOT OPPRESSIVE, OVERBROAD, AND UNPARTICULARIZED. Epstein also asserts that the subpoenas seeking the computer equipment are unreasonable because they are oppressive, overbroad, and unparticulariz

Biscayne Boulevard. Suite 1300 • Miami. Florida 33131- Phone: 305-371-6421• Fax 305-358-2006 • www.RoyBlack.com EFTA01713175 under the teaching of Fisher v. United States, 425 U.S. 391, 398 (1976), result in compelling testimony from Mr. Epstein himself, in violation of his right against self incrimi

e: 305-371-6421 • Fax 305-358-2006 • www.RoyBlackcom EFTA01713179 incriminating effect". United States v. Doe, 465 U.S. 605, 612 (1984); see also Fisher, 425 U.S. at 410 ("the act of producing evidence in response to a subpoena . . . has communicative aspects of its own, wholly aside from the content

ERMITTED TO SEIZE THE COMPUTERS ON THE BASIS OF A GRAND JURY SUBPOENA, THE SUBPOENAS MUST BE QUASHED AS UNREASONABLE AND OPPRESSIVE, OVERBROAD AND UNPARTICULARIZED. Paragraphs 1 and 2 of the subpoenas suggest no limitation on the ability of the government to search the contents of the computers. Instead, the g

, Komspan & Stum 201 S. Biscayne Boulevard, Suite 1300 • Miami, Florida 33131. Phone: Fax • www.RoyBlack.com EFTA00178998 under the teaching of Fisher v. United States, 425 U.S. 391, 398 (1976), result in compelling testimony from Mr. Epstein himself, in violation of his right against self incrimi

Florida 33131 • Phone: • Fax: • vwov.RoyBlack.com EFTA00179002 incriminating effect". United States v. Doe, 465 U.S. 605, 612 (1984); see also Fisher, 425 U.S. at 410 ("the act of producing evidence in response to a subpoena . . . has communicative aspects of its own, wholly aside from the content

ERMITTED TO SEIZE THE COMPUTERS ON THE BASIS OF A GRAND JURY SUBPOENA, THE SUBPOENAS MUST BE QUASHED AS UNREASONABLE AND OPPRESSIVE, OVERBROAD AND UNPARTICULARIZED. Paragraphs 1 and 2 of the subpoenas suggest no limitation on the ability of the govemmel ters. Instead, the government purports to be sessi

rom Epstein's home. The Fifth Amendment privilege "protects a person ... against being incriminated by his own compelled testimonial communication." Fisher v. United States, 425 U.S. 391, 409 (1976). Thus, to receive Fifth Amendment protection, a person's statement or act must be: (1) compelled; (2) te

ances, an attorney (or his agent) can use the attorney-client privilege to assert an act of production immunity on behalf of his client. See, e.g., Fisher, 425 U.S. at 402-04. Those circumstances do not apply here. In Fisher, the Supreme Court determined that a defendant does not suffer a Fifth Amendme

protected, not the relationship as a whole. McKay v. C.I.R., 886 F.2d 1237 (9th Cir. 1989). VII. THE SUBPOENAS ARE NOT OPPRESSIVE, OVERBROAD, AND UNPARTICULARIZED. Epstein also asserts that the subpoenas seeking the computer equipment are unreasonable because they are oppressive, overbroad, and unparticulariz