Epstein Secrets

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

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

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ____________________________________/ Related Cases: 08-80232, 08-80380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-804

apprehend incrimination for answering questions about other unrelated business activities at other times? 59 B.R. at 435. Likewise, Defendant Epstein’s assertion of the Fifth Amendment privilege in response to all responsive net worth documents appears egregiously overbroad and dubious. Plain

s at other times? 59 B.R. at 435. Likewise, Defendant Epstein’s assertion of the Fifth Amendment privilege in

Introduction This appeal concerns Defendant Jeffrey Epstein’s blanket assertion of the Fifth Amendme

Epstein. Finally, Plaintiffs’ document request no. 5 seeks primarily statements for bank accounts and investment accounts. In United States v. Ghidoni, 732 F.2d 814 (11th Cir. 1984), the Eleventh Circuit held that bank account statements were not protected by the Fifth Amendment act-of-production

10 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, Plaintiff, CASE NO.: 08-CIV-80119-MARRA/JOHNSON vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591,09-80656,09-80802,09-81092

ant's Response In Opposition to Jane Doe 2-8s' Rule 4 Appeal (DE 493), With Incorporated Memorandum Of Law Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Response In Opposition to Jane Doe 2-8s Rule 4 Appeal (DE 493), With Memorandum Of La

With Incorporated Memorandum Of Law Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through h

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

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

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