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

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

oppressive." A grand jury subpoena must be reasonable, and, in making that determination, "what is reasonable depends on the context." New Jersey. T.L.O. , 469 U.S. 325, 337 (1985). Likewise, whether a subpoena is oppressive depends on the context. In re August, 1993 Regular Grand Jury , 854E Supp. 13

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CIV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, 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, 09-8109

ERNATIVE RULE 4 APPEAL, WITH INCORPORATED OBJECTIONS AND MOTION FOR PROTECTIVE ORDER AND MEMORANDUM OF LAW Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, hereby files his Motion for Modification and Reconsideration of the Magistrate's Order (DE 555) pursua

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

e 1400 FL 33401-5012 Counsel for Defendant Jefj•ey Epstein Brad Edwards, Esq. Fanner, Jaffe, Weissing, Edw

upon review of the book or journal by Epstein's criminal lawyer, Jack Goldberger, Esq., it appeam thc "book" or "journal" doca contain the namea of Epatcin's busiftetts-asseeimes-antl-ether--highlr eetifttleyttitt4-eemtitereittilt settstitive-infermatiett-thttt-wett4d he entirely irrelevant to thio act

the Fourth Amendment clearly protects the right of people to be secure in their persons, houses, papers and effects from intrusions); New Jersey v. T.L.O., 469 U.S. 325, 375 (1985)(search of a woman's purse by a school administrator is a serious invasion of her legitimate expectation of privacy). Based

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

ppressive." A grand July subpoena must be reasonable, and, in making that determination, "what is reasonable depends on the context." New Jersey v. T.L.O., 469 U.S. 325, 337 (1985). Likewise, whether a subpoena is oppressive depends on the context. In re August, 1993 Regular Grand Jury, 854 F. Supp. 13

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

pressive." A grand jury subpoena must be reasonable, and, in making that determination, "what is reasonable depends on the context." New Jersey v. T.L.O. , 469 U.S. 325, 337 (1985). Likewise, whether a subpoena is oppressive depends on the context. In re August, 1993 Regular Grand Jury , 854E Supp. 13