Epstein Secrets

(14416 1 P R/1 SOA(16 EFTA00228253 Pagel of 48 ACCOUNT NUMBER PAYMENT DUE DATE NEW BALANCE MINIMUM OUE 02/13/2004 I St .617.22 I 532.00 JEFFREY E EPSTEIN 457 MADISON AVENUE C/O J. EPSTEIN CO 4TH Ft. NEW YORK NY 100226843 O CHASE Facsimile Copy Chair: Gold MasterCard❑ ACCOUNT NUMBER: NEW BALAN

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ument's "seizure" only if during that brief perusal the document's "otherwise incriminating character becomes obvious." 668 F.2d at 1267. Heldt and Andresen do not address computers, and their guidance of "brief perusal" and "minimization of invasions of privacy" to a complete physical and logical foren

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

nued validity of the broad statements contained in some of the Court's earlier cases [referring to Boyd ], have been discredited by later opinions." Andresen I Maryland , 427 U.S. 463, 472 (1976). In 1984, Justice O'Connor wrote a concurring opinion in United States I Doe , 465 U.S. 605 (1984), just to

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

nued validity of the broad statements contained in some of the Court's earlier cases [referring to Boyd], have been discredited by later opinions." Andresen v. Maryland, 427 U.S. 463, 472 (1976). In 1984, Justice O'Connor wrote a concurring opinion in United States v. Doe, 465 U.S. 605 (1984), just to m

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

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

nued validity of the broad statements contained in some of the Court's earlier cases [referring to Boyd ], have been discredited by later opinions." Andresen v. Maryland , 427 U.S. 463, 472 (1976). In 1984, Justice O'Connor wrote a concurring opinion in United States v. Doe , 465 U.S. 605 (1984), just t

S DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA GRAND JURY MATTER FILED UNDER SEAL IN RE GRAND JURY SUBPOENAS ) DUCES TECUM IS D TO ) MOTION OF JEFFREY EPSTEIN TO INTERVENE AND TO QUASH GRAND JURY SUBPOENAS AND INCORPORATED MEMORANDUM OF LAW Now comes Jeffrey Epstein and respectfully moves this Honorable

Mr. Jeffrey Epstein, including, but not ling 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; ••••••r telephone logs or records

Y SUBPOENAS ) DUCES TECUM IS D TO ) MOTION OF JEFFREY EPSTEIN TO INTERVENE AND TO QUASH GRAND JURY SUB

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

re to assure that [searches] are conducted in a manner that minimizes unwarranted intrusions upon privacy". West End, 321 F.Supp.2d at 960, quoting Andresen v. Maryland, 427 U.S. 463, 482 n.11 (1976). Most recently„th Warshak v. United States, 2007 WL 1730094 (6th Cir. June 18, 2007), the Sixth Circuit

eement of the parties. that appearance was rescheduled for July 17, 2007. The day before that scheduled appearance, i.e.. July 16. 2007. counsel for Jeffrey Epstein, who seeks to intervene in this matter, was informed by Deputy Chief that Riley did not have to appear physically before the grand jury if a motio

nformed by Deputy Chief that Riley did not have to appear physically before the grand jury if a motion to quash the subpoena at issue was filed by Epstein before the end of the day on July 17. 2007. As the Government's Response states. Epstein's motion to quash was filed on July 17, 2007 before the clo

he Response of the United States to the Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Sub

d jury subpoenas to investigator and his firm, Mr. Epstein is represented by undersigned counsel Roy Black.

re to assure that [searches] are conducted in a manner that minimizes unwarranted intrusions upon privacy". West End, 321 F.Supp.2d at 960, quoting Andresen v. Maryland, 427 U.S. 463, 482 n.I I (1976). Most recently, in Warshak v. United States, 2007 WL 1730094 (6th Cir. June 18, 2007), the Sixth Circu

THE SUBPOENA FOR THE CONTENTS OF EPSTEIN'S COMPUTERS, EVEN IF CONSIDERED "PURELY PRIVATE PAPERS," DOES NOT VIOLATE EPSTEIN'S FIFTH AMENDMENT PRIVILEGE. Lastly, Epstein argues that the subpoena seeks "purely private papers," and that a subpoena demanding those papers vi

nued validity of the broad statements contained in some of the Court's earlier cases [referring to Boyd ], have been discredited by later opinions." Andresen I Maryland , 427 U.S. 463, 472 (1976). In 1984, Justice O'Connor wrote a concurring opinion in United States I Doe , 465 U.S. 605 (1984), just to

From: Sent: To: Subject: Steven Sinofskv 11/22/2013 3:48:56 PM Jeffrey Epstein [[email protected]] Bitcoin and DC Importance: High http://www.washingtonpost.com/blogs/the-switch/wp/2013/11/21/heres-how-bitcoin-charmed-washin

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touch Regulators are busy people. They're more likely to pay attention to flesh-and-blood advocates than to anonymous Internet commenters. Murck and Andresen's trip to Washington proved to be crucial to building productive relationships with policymakers. Calvery was a keynote speaker at the June conferenc