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

h makes a suspect or accused the source of 'real or physical evidence' [which does not].'" United States v. Wade, 388 U.S. 218, 223 (1967) (quoting Schmerber v. State of California, 384 U.S. 757, 764 (1966)). And the contents of the computers are not protected because the creation of the contents was not

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

ch makes a suspect or accused the source of 'real or physical evidence' [which does not]." United States v. Wade , 388 U.S. 218, 223 (1967) (quoting Schmerber v. State of California , 384 U.S. 757, 764 (1966)). And the contents of the computers are not protected because the creation of the contents was no

tiff, CASE NO.: 08-CIV-80119-MARRA/JOHNSON vs. JEFFREY EPSTEIN, Defendant. I ---------------- Related cases:

Of Law Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, her

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

et 08/31/2009 Page 14 of 18 U.S. 27, 36 (2000); Schmerber v. California, 384 U.S., 757, 763-764, (1966) ("t

Page 1 of 24 JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. UNITED STATES DISTRICT COURT SOUTH

Of Law Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, her

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

for production. Hubbell, 530 U.S. 27, 36 (2000); Schmerber v. California, 384 U.S., 757, 763-764, (1966) ("

Case 9:08-cv-80119-KAM Document 391 Entered on FLSD Docket 11/03/2009 Page 1 of 15 JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON --------------~/ Related cases: 08-

al And Objections To Magistrate Judge's Order Entered September 10, 2009 (DE 293), With Memorandum Of Law Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Response in Opposition to Plaintiffs' Appeal and Objections to the Magistrate Judge's

009 (DE 293), With Memorandum Of Law Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through h

tary subpoenas, which is no different from producing documents responsive to a request for production. See U.S. v Hubbell, 530 U.S. 27, 36 (2000); Schmerber v. California, 384 U.S., 757, 763-764, (1966) ("the privilege reaches ... the compulsion of responses which are also communications, for example, c