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

, the contents were voluntarily created by the persons who used them. EFTA00222988 See, e.g., United States' Doe , 465 U.S. 605, 612 (1984); In re Grand Jury Proceedings , 393 F.3d 905, 909 (9th Cir. 2004); In re Foster , 188 F.3d 1259, 1269 (10th Cir. 1999). This reasoning applies even when the documents or informa

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

ed, instead, the contents were voluntarily created by the persons who used them. F15 See, e.g., United States' Doe , 465 U.S. 605, 612 (1984); In re Grand Jury Proceedings , 393 F.3d 905, 909 (9th Cir. 2004); In re Foster , 188 F.3d 1259, 1269 (10th Cir. 1999). This reasoning applies even when the documents or informa

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

lled, instead, the contents were voluntarily created by the persons who used them.15 See, e.g., United States v. Doe, 465 U.S. 605, 612 (1984); In re Grand Jury Proceedings, 393 F.3d 905, 909 (9th Cir. 2004); In re Foster, 188 F.3d 1259, 1269 (10th Cir. 1999). This reasoning applies even when the documents or informati

DISTRICT OF FLORIDA CASE No. 08-80736-CIV-MARRA/JOHNSON JANE DOE 1 AND JANE DOE 2, Plaintiffs v. UNITED STATES OF AMERICA, Defendant MOTION OF JEFFREY EPSTEIN FOR LIMITED INTERVENTION Jeffrey Epstein hereby moves, pursuant to Fed. R. Crim. P. 24(a)(2) and 24(b)(1)(B), that he be permitted to intervene for

ure. If the plaintiffs move to compel production of any materials as to which the government has asserted the Rule 6(e) disclosure prohibition, Mr. Epstein has enforceable private interests in the continued secrecy of matters which occurred before the two grand juries which investigated the issue of whe

UNITED STATES OF AMERICA, Defendant MOTION OF JEFFREY EPSTEIN FOR LIMITED INTERVENTION Jeffrey Epstein

l v. Costle, 561 F.2d 904, 907 (D.C.Cir. 1977). Mr. Epstein's motion is timely because it seeks intervention

1004 (D.C.Cir. 1999)("[I]t would ordinarily be a violation of Rule 6(e) to disclose that a grand jury is investigating a particular person"); In re Grand Jury Proceedings, 851 F.2d 860, 866-67 (6th Cir. 1988)("[C]onfidential documentary information not otherwise public obtained by the grand jury by coercive means is

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

, instead, the contents were voluntarily created by the persons who used them. F15 See, e.g., United States v. Doe , 465 U.S. 605, 612 (1984); In re Grand Jury Proceedings , 393 F.3d 905, 909 (9th Cir. 2004); In re Foster , 188 F.3d 1259, 1269 (10th Cir. 1999). This reasoning applies even when the documents or informa

, which has been consolidated for purposes of discovery, Plaintiffs are former under-age girls who allege they were sexually assaulted by Defendant, Jeffrey Epstein ("Epstein"), at his Palm Beach mansion home. The scheme is alleged to have taken place over the course of several years in or around 2004-2005, when

nsolidated for purposes of discovery, Plaintiffs are former under-age girls who allege they were sexually assaulted by Defendant, Jeffrey Epstein ("Epstein"), at his Palm Beach mansion home. The scheme is alleged to have taken place over the course of several years in or around 2004-2005, when the girls

requests for production that were propounded on Defendant Epstein. Defendant has responded by asserting several obj

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 0

prepared in anticipation of litigation by or for a party or by or for that party's attorney acting for his client, Fed. R. Civ. P. 26(b)(3)'; In re Grand Jury Proceedings, 601 F.2d 162, 171 (5th Cir. 1979), is also not implicated as the subject documents were not created by Epstein's attorneys. Id. Finally, Epstein

, which has been consolidated for purposes of discovery, Plaintiffs are former under-age girls who allege they were sexually assaulted by Defendant, Jeffrey Epstein ("Epstein"), at his Palm Beach mansion home. The scheme is alleged to have taken place over the course of several years in or around 2004-2005, when

nsolidated for purposes of discovery, Plaintiffs are former under-age girls who allege they were sexually assaulted by Defendant, Jeffrey Epstein ("Epstein"), at his Palm Beach mansion home. The scheme is alleged to have taken place over the course of several years in or around 2004-2005, when the girls

requests for production that were propounded on Defendant Epstein. Defendant has responded by asserting several obj

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. Related cases: 08-80232, 0

prepared in anticipation of litigation by or for a party or by or for that party's attorney acting for his client, Fed. R. Civ. P. 26(b)(3)'; In re Grand Jury Proceedings, 601 F.2d 162, 171 (5th Cir. 1979), is also not implicated as the subject documents were not created by Epstein's attorneys. Id. Finally, Epstein

of their plea negotiations; and, if so, whether a privilege bars crime victims from discovering plea negotiations. The United States investigated Jeffrey Epstein's sexual abuse of minors, but failed to confer with the victims before entering a non-prosecution agreement with Epstein. Two victims filed suit agai

States investigated Jeffrey Epstein's sexual abuse of minors, but failed to confer with the victims before entering a non-prosecution agreement with Epstein. Two victims filed suit against the United States to enforce their rights under the Crime Victims' Rights Act, 18 U.S.C. § 3771, and sought to disc

erica, Defendant. Roy Black, Martin G. Weinberg, Jeffrey Epstein, Intervenors-Appellants. No. 13-12923.

rlman doctrine allows an intervenor to file an interlocutory ap- peal of an order denying a motion to quash a grand jury subpoena. See, e.g., In re Grand Jury Proceedings, 832 F.2d 554, 556-58 (11th Cir.1987). "This exception, derived from Perlman I. United States,... permits an order denying a motion to quash to be

jury, for the production of transcripts of any and all proceedings before the State Grand Jury on Wednesday, July 19, 2006, referring or relating to Jeffrey Epstein and/or including but not limited to witness testimony, statements made by any member of the State Attorney's Office, and instructions given by any

, July 19, 2006, referring or relating to Jeffrey Epstein and/or including but not limited to witness tes

ednesday, July 19, 2006, referring or relating to Jeffrey Epstein and/or including but not limited to wit

informs the Court that the transcripts of the State's grand jury proceedings relate to the substance of a federal grand jury investigation. See In m Grand Jury Proceedings , 832 F.2d 554 (11th Cir. 1987). 7. Further in accordance with the Federal Rules of Criminal Procedure, the United States informs the Court that i

ednesday, July 19, 2006, referring or relating to Jeffrey Epstein and/o including but not limited to witn

jury, for the production of transcripts of any and all proceedings before the State Grand Jury on Wednesday, July 19, 2006, referring or relating to Jeffrey Epstein and/o including but not limited to witness testimony, statements made by any member of the State Attorney's Office, and instructions given by any

, July 19, 2006, referring or relating to Jeffrey Epstein and/o including but not limited to witness test

informs the Court that the transcripts of the State's grand jury proceedings relate to the substance of a federal grand jury investigation. See In m Grand Jury Proceedings , 832 F.2d 554 (11th Cir. 1987). 6. Further in accordance with the Federal Rules of Criminal Procedure, the United States informs the Court that i