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

ng records are either work product or attorney-client communications that need not be produced. This assertion fails both procedurally and legally. A. Epstein's Claim of Privilege Is Waived by His Failure to Carry His Burden of Proving Its Applicability. Procedurally, the person asserting the privilege bear

3)(United States District Court, S.D. Fl.); v. Jeffrey Epstein (Case No. 502008CA028051XXXXMB AB)(Florida Circuit Court, 15th Judicial Circuit). v. Jeffrey Epstein (Case No. 502008CA028058XXXXMB ABXFlorida Circuit Court, 15th Judicial Circuit). 3. In December 2009, Epstein brought a vendetta action against me

itution in Florida. Subsequently, Bradley James Edwards, a Florida lawyer, brought civil actions on behalf of several girls alleging molestation by Epstein while they were minors. Jane Doe v. Jeffrey Epstein, (08- 80893)(United States District Court, S.D. Fl.); E v. Jeffrey Epstein (Case No. 502008CA

endant's alleged sexual abuse of her when she was a minor. The subpoenas seek the production of "(a)11 taped conversations between George Rush and Jeffrey Edward Epstein, including telephone recordings, all emails to and from Jeffrey Edward Epstein or someone representing themselves to be Jeffrey Epstein," and the t

n between George Rush, one of its reporters, and Jeffrey Epstein, and granting such other relief as the C

d civil legal proceedings in Florida relating to Mr. Epstein (Rush Aff., Apr. 6, 2010 [Carroll Decl., Apr. 7,

molestation from discovery. It is for this reason, among others, that production of the tape on which he speaks about his molestation is critical. A. Epstein's Vicious Attacks on the Girls 5. Epstein's battery of attorneys have taken the girls' depositions, in which they have asked numerous questions sugg

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

ng records are either work product or attorney-client communications that need not be produced. This assertion fails both procedurally and legally. A. Epstein's Claim of Privilege Is Waived by His Failure to Carry His Burden of Proving Its Applicability. Procedurally, the person asserting the privilege bear

as just -- I couldn't tell one from the other with no last name and 20 -- like you said, 20, 22 years ago. Q. Sure. But there were other people in Epstein's world who had that same true first name; isn't that right? SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00068683 222 LBUCmax3 - cro

t's correct. Q. And she traveled frequently with Mr. Epstein on his planes; isn't that right? A. Yes. SOUTH

Ghislaine's luggage from; right? A. Yes. Q. You wouldn't pick it up from one of Epstein's residences; right? A. No, not unless I was picking up Jeffrey's luggage, I went to Mr. Epstein's residence. Q. So at all times from 1991 to the 2000s, Ghislaine maintained a separate residence in New York fro

, so nice to meet you and I'm going to call your mom. That was it. Q. That man and that woman that you had this conversation with, who were they? A. Jeffrey Epstein and Ghislaine Maxwell. Q. What was your impression of them at that point? A. They seemed very friendly. I thought they were a married couple. They

tioned. Did some of those trips include travel to New York? A. Yes. Q. Where did you stay when you traveled with Maxwell and Epstein to New York? A. Epstein's house. Q. Where was that house located? A. New York City. Q. In what borough? A. Do you need the exact address? Q. No, it's okay. Approximately