Epstein Secrets

CROSS-MOTION TO COMPEL The United States of America, by and through the undersigned Assistant United States Attorney, hereby files its response to Jeffrey Epstein's motion to intervene and to quash two grand jury subpoenas issued to William Riley (Subpoena No. OLY-63) and to the Custodian of Records for Riley Ki

(9th Cir. 1989). Accordingly, the United States asks the Court to compel the witnesses to appear before the grand jury on the next available date. Epstein's counsel argues first that his client should be allowed to intervene as a matter of right pursuant to Fed. R. Civ. P. 24(a)(2). Assuming that the C

target surfaces. In re Grand Jury Proceedings in Matter of Freeman , 708 F.2d 1571, 1574-75 (11th Cir. 1983) (citing In re Grand Jury Proceedings (Jeffrey Fine ), 641 F.2d 199, 201-03 (5th Cir. 1981)). As explained below, Mt Riley is not an attorney; Riley Kiraly is not a law firm; and the information sough

UNDER SEAL UNITED STATES' RESPONSE TO MOTION OF JEFFREY EPSTEIN TO TO INTERVENE AND TO QUASH GRAND JURY

of the investigation. When Guy Lewis stated that Mr. Epstein was willing to assist in the federal investigatio

, 930 F.2d 1554 (11th Cir. 1991); United States' Muiioz , 233 F.3d 1117 (9th Cir. 2000); Hawkins I Stables , 148 F.3d 379 (4th Cir. 1998); Motley I Marathon Oil Co. , 71 F.3d 1547 (10th Cir. 1995); Christman' Brauvin Realty Advisors, Inc. , 185 F.R.D. 251 (N.D. Ill. 1999). In making that showing, blanket assert

CROSS-MOTION TO COMPEL The United States of America, by and through the undersigned Assistant United States Attorney, hereby files its response to Jeffrey Epstein's motion to intervene and to quash two grand jury subpoenas issued to William Riley (Subpoena No. OLY-63) and to the Custodian of Records for Riley Ki

ly conflates several concepts involving different privileges that, when dissected, do not apply to the subpoenaed items. The first issue is whether Epsteins Fifth Amendment privilege applies to Riley's production of the computers removed from Epstein's home. The Fifth Amendment privilege "protects a pers

s. In re Grand Jury Proceedings in Matter of Freeman , 708 F.2d 1571, 1574-75 (11th Cir. 1983) (citing In re Grand Jury EFTA00222994 Proceedings (Jeffrey Fine) , 641 F.2d 199, 201-03 (5th Cir. 1981)). See also In re Grand Jury Subpoena , 274 F.3d 563, 570 (1st Cir. 2001) ("Colorable claims of attorney-clie

and OLY-64 UNITED STATES' RESPONSE TO MOTION OF JEFFREY EPSTEIN TO INTERVENE AND TO QUASH GRAND JURY SUB

of the investigation. When Guy Lewis stated that Mr. Epstein was willing to assist in the federal investigatio

, 930 F.2d 1554 (11th Cir. 1991); United States I Mulloz , 233 F.3d 1117 (9th Cir. 2000); Hawkins I Stables , 148 F.3d 379 (4th Cir. 1998); Motley I Marathon Oil Co. , 71 F.3d 1547 (10th Cir. 1995); Christman I Brauvin Realty Advisors, Inc. , 185 F.R.D. 251 (N.D. III. 1999). In making that showing, blanket asser

undersigned Assistant United States Attorney, hereby asks for permission to file a Supplemental ex parte Declaration in support of its Response to Jeffrey Epstein's Motion to Intervene and to Quash Subpoenas and Cross- Motion to Compel. In support thereof, the United States states the following: 1. The Declara

response consists of rambling generalizations about various areas of the law which have little or nothing to do with the issues actually raised by Epstein, and those sections of the response require no reply. In other portions, however, the government has ignored critical facts, mischaracterized or mis

target surfaces. In re Grand Jury Proceedings in Matter of Freeman, 708 F.2d 1571, 1574-75 (1 1 th Cir. 1983) (citing In re Grand Jury Proceedings (Jeffrey Fine), 641 F.2d 199, 201-03 (5th Cir. 1981)). See also In re Grand Jury Subpoena, 274 F.3d 563, 570 (1st Cir. 2001) ("Colorable claims of attorney-clien

AN & STUMPF, P.A., hereby appears as counsel for Jeffrey Epstein in the above-entitled cause. DATED at Mi

nce of a two-year term of state imprisonment for Mr. Epstein. That offer was not meant as a starting point for

"billing records." -29- EFTA00179128 States v. Mutioz, 233 F.3d 1117 (9th Cir. 2000); Hawkins v. Stables, 148 F.3d 379 (4th Cir. 1998); Motley v. Marathon Oil Co., 71 F.3d 1547 (10th Cir. 1995); Christman v. Brauvin Realty AdvisorS, Inc., 185 F.R.D. 251 (N.D. III. 1999). In making that showing, blanket asserti

tes, digital cameras, and memory cards. 2. All computer equipment and electronic storage media that currently belongs to, or has ever belonged to, Jeffrey Epstein, including but not limited to central processing units ("CPUs"), laptop computers, keyboards, printers, modems, routers, hard drives, flash drives,

. Jeffrey Epstein, including, but not limited to, retainer agreements; employment agreements; billing statements (whether submitted directly to Mr. Epstein or to a third party for reimbursement); records of the dates when services were performed and the hours worked; telephone logs or records of dates

t currently belongs to, or has ever belonged to, Jeffrey Epstein, including but not limited to central pr

illing statements (whether submitted directly to Mr. Epstein or to a third party for reimbursement); records

930 F.2d 1554 (11th Cir. 1991); United States v. Muiloz, 233 F.3d 1117 (9th Cir. 2000); Hawkins v. Stables, 148 F.3d 379 (4th Cir. 1998); Motley v. Marathon Oil Co., 71 F.3d 1547 (10th Cir. 1995); Christman v. Brauvin Realty Advisors, Inc., 185 F.R.D. 251 (N.D. Ill. 1999). Furthermore, blanket assertions are not

F FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 and JANE DOE 2, Plaintiffs, EXHIBIT A UNITED STATES OF AMERICA, Defendant. INTERVENOR JEFFREY EPSTEIN'S MOTION FOR A PROTECTIVE ORDER AND OPPOSITION TO MOTIONS OF JANE DOE I AND JANE DOE 2 FOR PRODUCTION, USE, AND DISCLOSURE OF PLEA NEGOTIATIONS Purs

DATORY AND DISCRETIONARY INTERVENTION An PROPER Intervention is proper as a matter of right under Federal Rule of Civil Procedure 24(a) because Mr. Epstein has an interest in protecting his privileged and confidential plea negotiations, and "disposing of the action may as a practical matter impair or im

rees without extending its jurisdic- tion. Keith Jeffrey Lambdin, Katzman Gar- finkel Rosenbaum, John Davi

er Federal Rule of Civil Procedure 24(a) because Mr. Epstein has an interest in protecting his privileged and

(suggesting that in case involving both federal claims and pendent state claims, "both bodies" of priv- ilege law should be considered); Motley 1. Marathon Oil Co., 71 2011 Thomson Reuters. No Claim to Orig. US Gov. Works. hups://web2.westlaw.com/print/printstream.aspx?pbc=BC6E23F98cdestinationr-atp&utid—... 9