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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
Even if the act of production were testimonial for purposes of Doe , production can be refused only if the act of production also is incriminating . Butcher , 753 F.2d at 469-70. In other words, the act of authentication is incriminating only if the documents are incriminating. As explained above, Epstei
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
Even if the act of production were testimonial for purposes ofDoe, production can be refused only if the act of production also is incriminating. Butcher, 753 F.2d at 469-70. In other words, the act of authentication is incriminating only if the documents are incriminating. As explained above, Epstei
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
Even if the act of production were testimonial for purposes of Doe , production can be refused only if the act of production also is incriminating . Butcher , 753 F.2d at 469-70. In other words, the act of authentication is incriminating only if the documents are incriminating. As explained above, Epstei
l, et at) and The Associated Press (11/18, Groves) reported that the US Congress has voted almost unanimously to release Justice Department files on Jeffrey Epstein, with the House of Representatives passing the measure 427-1 and the Senate swiftly approving it. According to the articles, the bill is expected to
use official stating that Trump plans to sign it. The articles noted that the release of the files is seen as a significant victory for survivors of Epstein's abuse, who have been fighting for years to hold those responsible accountable and to have the case files made public. Additional reporting on the
animously to release Justice Department files on Jeffrey Epstein, with the House of Representatives passin
o have difficult but necessary conversations with their children about online dangers. Continued Reporting: New York Nightmare Averted as "Commander Butcher" Pleads Guilty Hoodline (11/18, Caldwell) reported that Michall Chkhikvishviii, a Georgian national known as "Commander Butcher and leader of the ne
stein Vote Reuters (11/17, Morgan, Erickson, Allen) reported that the US House of Representatives is set to vote on releasing investigative files on Jeffrey Epstein, a late sex offender, after President Donald Trump dropped his opposition. Trump's reversal came after a House petition gained enough support to for
pstein if it reaches his desk. "I do want to [sign itj; Mr. Trump told reporters at the White House. "Here's what I want. We have nothing to do with Epstein. The Democrats do. All of his friends were Democrats. You look at this Reid Hoffman, and you look at Larry Summers, Bill Clinton. They went to his
s set to vote on releasing investigative files on Jeffrey Epstein, a late sex offender, after President Do
ney), Washington Examiner (11/17, Zimmermann), Washington Post (11/17, Alfaro, Zalcrzewsld), and Washington Times (11/17, Staff Writer). 'Commander Butcher' Admits Trying to Spur Hate Attack in New York The New York Times (11/17, Nerkar) reported that Michall Chkhikvishvili, also known as "Commander But
ia, after online chatter about possible protests circulated in response to Mark Epstein's claims that Director Patel was overseeing a "cover-up" of Jeffrey Epstein-related materials. The article explained that bureau police normally based at FBI Headquarters were sent to the 256,000-square- foot facility after Ma
comment The article added that lawmakers recently passed the Epstein Files Transparency Act requiring the Justice Department to release unclassified Epstein materials within 30 days, with President Donald Trump signing the measure and asserting that DOJ had already provided Congress with nearly 50,000 pa
at Director Patel was overseeing a "cover-up" of Jeffrey Epstein-related materials. The article explained
an, was sentenced to 10 years and one month in prison for sex trafficking a 14-year-old girl from a New Jersey group home. According to the article, Butcher pleaded guilty to conspiracy to commit sex trafficking of a minor after luring the girl away from her group home and exploiting her for money. The a
ications for the Future Christopher S. Chivvis, Jeffrey Martini Article 5. NYT Jordan's Urban Refugees
, the cruelest and the least-rewarded" of all wars. Yes, the Great War, the end of empires and the old order, was triggered by a teenager. And, as Butcher writes, "It was out of this turbulent collapse EFTA00717214 that Bolshevism, socialism, fascism and other radical political currents took root."
To: Jeffrey [email protected] From: Ssulayem Sent Mon 10/19/2009 12:07:33 AM Capitalism In the month of August, a resort town sits next to the
goes to inspect the rooms upstairs in order to pick one.The hotel proprietor takes the 100 dollar bill and runs to pay his debt to the butcher.The Butcher takes the 100 dollar bill, and runs to pay his debt to the pig raiser.The pig raiser takes the 100 dollar bill, and runs to pay his debt to the supp
Entities connected to both Jeffrey Epstein and Butcher

Marc Rich
PERSONLeon Black
PERSON
Alan Dershowitz
PERSON
Donald Trump
PERSON
United States
LOCATIONJack Goldberger
PERSON
Sarah Kellen
PERSON
FedEx
ORGANIZATIONSouthern District
LOCATION
Terje Rod-Larsen
PERSON
Julie K. Brown
PERSON
Bill Clinton
PERSON
Alexander Acosta
PERSONFBI
ORGANIZATION
Scarlett Johansson
PERSONEmmy Taylor
PERSONRoy Black
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Bloomberg L.P.
ORGANIZATION
Barack Obama
PERSONBarrett
PERSON