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

ulloz , 233 F.3d 1117 (9th Cir. 2000); Hawkins I Stables , 148 F.3d 379 (4th Cir. 1998); Motley I Marathon Oil Co. , 71 F.3d 1547 (10th Cir. 1995); Christman I Brauvin Realty Advisors, Inc. , 185 F.R.D. 251 (N.D. III. 1999). In making that showing, blanket assertions of the privilege are not proper—the as

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

Mutioz, 233 F.3d 1117 (9th Cir. 2000); Hawkins v. Stables, 148 F.3d 379 (4th Cir. 1998); Motley v. Marathon Oil Co., 71 F.3d 1547 (10th Cir. 1995); Christman v. Brauvin Realty AdvisorS, Inc., 185 F.R.D. 251 (N.D. III. 1999). In making that showing, blanket assertions of the privilege are not proper—the a

tes, digital cameras, and memory cards. 2. All computer equipment and electronic storage media that currently belongs to, or has ever belonged to, Jeffrey Epstein, including but not limited to central processing units ("CPUs"), laptop computers, keyboards, printers, modems, routers, hard drives, flash drives,

. Jeffrey Epstein, including, but not limited to, retainer agreements; employment agreements; billing statements (whether submitted directly to Mr. Epstein or to a third party for reimbursement); records of the dates when services were performed and the hours worked; telephone logs or records of dates

t currently belongs to, or has ever belonged to, Jeffrey Epstein, including but not limited to central pr

illing statements (whether submitted directly to Mr. Epstein or to a third party for reimbursement); records

Muiloz, 233 F.3d 1117 (9th Cir. 2000); Hawkins v. Stables, 148 F.3d 379 (4th Cir. 1998); Motley v. Marathon Oil Co., 71 F.3d 1547 (10th Cir. 1995); Christman v. Brauvin Realty Advisors, Inc., 185 F.R.D. 251 (N.D. Ill. 1999). Furthermore, blanket assertions are not proper, and the assertion must be made o

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

noz , 233 F.3d 1117 (9th Cir. 2000); Hawkins v. Stables , 148 F.3d 379 (4th Cir. 1998); Motley v. Marathon Oil Co. , 71 F.3d 1547 (10th Cir. 1995); Christman v. Brauvin Realty Advisors, Inc. , 185 F.R.D. 251 (N.D. III. 1999). In making that showing, blanket assertions of the privilege are not proper—the a

te/florida/article247183924.html> (11/14, Wieder, Hall, 1.09M) reports, "A Justice Department look-back report into its abortive 2008 prosecution of Jeffrey Epstein found that the Federal Bureau of Investigation had planned to arrest Jeffrey Epstein in May 2007, but pulled back after the U.S. Attorney's Office f

y's Office for the Southern District of Florida, led by former Labor Secretary Alexander Acosta, frowned on the plan. The report also concludes that Epstein wasn't assisting the federal government in prosecuting Wall Street traders behind the collapse of investment bank Bear Stearns or serving as an "in

-abuse> Norfolk, VA (11/15, 163K) reports Bradley Jeffrey-Moe "was convicted Friday on charges of receivin

entered into a nationwide database last month. The FBI's Next Generation Identification system matched the prints with those from the 1968 murder," Christman said, and "fingerprint examiners also confirmed the match, he said. He said agents and police had been searching for Moses for years, following up o

fore Plea Deal. The Miami Herald (11/14, Wieder, Hall, 1.09M) reports, "A Justice Department look-back report into its abortive 2008 prosecution of Jeffrey Epstein found that the Federal Bureau of Investigation had planned to arrest Jeffrey Epstein in May 2007, but pulled back after the U.S. Attorney's Office

y's Office for the Southern District of Florida, led by former Labor Secretary Alexander Acosta, frowned on the plan. The report also concludes that Epstein wasn't assisting the federal government in prosecuting Wall Street traders behind the collapse of investment bank Bear Stearns or serving as an "in

WTKR-TV Norfolk, VA (11/15, 163K) reports Bradley Jeffrey-Moe "was convicted Friday on charges of receivin

entered into a nationwide database last month. The FBI's Next Generation Identification system matched the prints with those from the 1968 murder," Christman said, and "fingerprint examiners also confirmed the match, he said. He said agents and police had been searching for Moses for years, following up o

fore Plea Deal. The Miami Herald (11/14, Wieder, Hall, 1.09M) reports, "A Justice Department look-back report into its abortive 2008 prosecution of Jeffrey Epstein found that the Federal Bureau of Investigation had planned to arrest Jeffrey Epstein in May 2007, but pulled back after the U.S. Attorney's Office

y's Office for the Southern District of Florida, led by former Labor Secretary Alexander Acosta, frowned on the plan. The report also concludes that Epstein wasn't assisting the federal government in prosecuting Wall Street traders behind the collapse of investment bank Bear Stearns or serving as an "in

WTKR-TV Norfolk, VA (11/15, 163K) reports Bradley Jeffrey-Moe "was convicted Friday on charges of receivin

entered into a nationwide database last month. The FBI's Next Generation Identification system matched the prints with those from the 1968 murder," Christman said, and "fingerprint examiners also confirmed the match, he said. He said agents and police had been searching for Moses for years, following up o

fore Plea Deal. The Miami Herald (11/14, Wieder, Hall, 1.09M) reports, "A Justice Department look-back report into its abortive 2008 prosecution of Jeffrey Epstein found that the Federal Bureau of Investigation had planned to arrest Jeffrey Epstein in May 2007, but pulled back after the U.S. Attorney's Office

y's Office for the Southern District of Florida, led by former Labor Secretary Alexander Acosta, frowned on the plan. The report also concludes that Epstein wasn't assisting the federal government in prosecuting Wall Street traders behind the collapse of investment bank Bear Stearns or serving as an "in

WTKR-TV Norfolk, VA (11/15, 163K) reports Bradley Jeffrey-Moe "was convicted Friday on charges of receivin

entered into a nationwide database last month. The FBI's Next Generation Identification system matched the prints with those from the 1968 murder," Christman said, and "fingerprint examiners also confirmed the match, he said. He said agents and police had been searching for Moses for years, following up o

nt) of the Federal Aviation I (We) Therefore SIGNATURE(S) OF LJESIUNATED ENGINEERING E ESENTATIvES Off$IGNATION NUMBER(3) CLAS3IFICATION(8) (1) Jeffrey D.Shutrump DERY-605526-NM Structures - . . " FAA Form 81104 (11-70) SUPERSEDES PREVIOUS EDITION (Computer Generated by Rohr, Inc.) EFTA00277

s and that the information furnished herein is true and correct to the best of my knowledge. Date August 7, 1999 Signature of Authorized Gregory A Christman 4/ i ____- 7. Approval for Return To Service Pursuant Administrator BY to the authority given persons specified of the Federal Aviation Admini