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

o. OLY-63 and OLY-64 United States District Court, Southern District of Florida Assistant U.S. Attorney Attorney for United States EFTA00223014 William L. Richey, Esq. Attorney for Subpoenaed Parties Riley Kiraly and William Riley Service via Federal Express Roy Black, Esq. Attorney for Intervenor Jeffrey

SUBPOENAS FGJ 07-103(WPB) DUCES TECUM NUMBERS OLY-63 and OLY-64 UNITED STATES' SURREPLY TO REPLIES FILED BY WITNESS WILLIAM RILEY AND INTERVENOR JEFFREY EPSTEIN RE: MOTION TO QUASH GRAND JURY SUBPOENAS UNDER SEAL UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE GRAND JURY SUBPOENAS FGJ 07-

Riley's counsel, and it has been agreed that Mr. Riley will appear before the grand jury on September 18, 2007. However, in footnote 3 of Intervenor Epstein's Reply, counsel asserts that, if "the Court were to sustain the government's standing objection as to Epstein, Riley and Riley Kiraly would file a

ES FILED BY WITNESS WILLIAM RILEY AND INTERVENOR JEFFREY EPSTEIN RE: MOTION TO QUASH GRAND JURY SUBPOENAS

computers cx the items as they were removed from Mr. Epstein's home. EFTA00211802 The grand jury probably h

211804 U.S. Attorney 5 s Office 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Telephonel Facsimile: I Attorney for United States William L. Richey, Esq. William L. Richey P.A Miami, Fl Telephon Facsimile: Attorney for Subpoenaed Parties Riley Kiraly and William Riley Service via U.S. Mail

States, by and through the undersigned Assistant United States Attorney, hereby files this Surreply to the Replies filed by Witness and Intervenor Jeffrey Epstein,' and notes the following: I. Both the witness and the intervenor assert that was excused from appearing before the grand jury and that lid not

office of I. counsel, and it has been agreed that 'Swill appear before the grand jury on September 18, 2007. However, in footnote 3 of Intervenor Epstein's Reply, counsel asserts that, if "the Court were to sustain the government's standing objection as to 'Witness did not file an initial motion to

PLY TO REPLIES FILED BY WITNESS M iND INTERVENOR JEFFREY EPSTEIN RE: MOTION TO QUASH GRAND JURY SUBPOENAS

computers B the items as they were removed from Mr. Epstein's home. The grand jury probably has the authorit

7 EFTA00234920 SERVICE LIST In re Federal Grand Jury Subpoenas No. OLY-63 and OLY-64 United States District Court, Southern District of Florida William L. Richey, Esq. 8 EFTA00234921

6 P. 06 .PACE 06. To: From: Data: JEFFREY E. EPSTEIN Mernoraqdu83 William Dohert , IP Morgan Darren

6 2010 10:16 P. 06 .PACE 06. To: From: Data: JEFFREY E. EPSTEIN Mernoraqdu83 William Dohert , IP Morgan Darren

6 2010 10:16 P. 06 .PACE 06. To: From: Data: JEFFREY E. EPSTEIN Mernoraqdu83 William Dohert , IP Morgan

6 2010 10:16 P. 06 .PACE 06. To: From: Data: JEFFREY E. EPSTEIN Mernoraqdu83 William Dohert , IP Morgan

Account # .Please wire Two Hundred Thirty Nine Donors & 20/100 023920) from the above account to: Hank name: CNL Bank AB!i• /0: Account name: William L. Richey. P.A. Account #: • Reference: File Number 3743.2 ID: 036002265575068 DATE: 02126/2010 03:08:00 PM DID: 8887316607 CSID: Pape 6 of 9 Confidential

NCIAL SPONSORS Jan 12 2010 15:42 P.01 JEFFREY E. EPSTEIN Memorandum. To:. William Doherty, JP Morgan Da

JPM FINANCIAL SPONSORS Jan 12 2010 15:42 P.01 JEFFREY E. EPSTEIN Memorandum. To:. William Doherty, JP Morgan Da

JPM FINANCIAL SPONSORS Jan 12 2010 15:42 P.01 JEFFREY E. EPSTEIN Memorandum. To:. William Doherty, JP M

JPM FINANCIAL SPONSORS Jan 12 2010 15:42 P.01 JEFFREY E. EPSTEIN Memorandum. To:. William Doherty, JP Mo

se wire Two Thousand One Hundred Eight Dollars 60/100 ($2,108.60) from the above account to: Bank man e: CNL Bank ABA #: 063114289 Account name: William L. Richey, P.A. Account #: Reference: i e um er 3743-2 EFTA01587367 DATE: '01/12/201'0 081:06 PM.DI EFTA01587368

eement of the parties. that appearance was rescheduled for July 17, 2007. The day before that scheduled appearance, i.e.. July 16. 2007. counsel for Jeffrey Epstein, who seeks to intervene in this matter, was informed by Deputy Chief that Riley did not have to appear physically before the grand jury if a motio

nformed by Deputy Chief that Riley did not have to appear physically before the grand jury if a motion to quash the subpoena at issue was filed by Epstein before the end of the day on July 17. 2007. As the Government's Response states. Epstein's motion to quash was filed on July 17, 2007 before the clo

he Response of the United States to the Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Sub

d jury subpoenas to investigator and his firm, Mr. Epstein is represented by undersigned counsel Roy Black.

Biscayne Boulevard, 34th Floor, Miami Center, Miami, Florida 331314325 •---- Facsimile EFTA00178967 x/17/.:007 PH FRCII: VI: 1 ar L. Richey, P William L. Richey, P.A. TO:, ' • PAGE: 00"; of FGJ 07-103 (WPB) Therefore, contrary to the Government's claim. Riley did not flout the subpoena. Rather. Riley's n

d States of America, by and through the undersigned Assistant United States Attorney, hereby moves to seal this Motion, the United States' Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel , the United States' Motion for Permission to File Ex Pane Affidavits, th

this Motion, the United States' Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas a

to seal this Motion, the United States' Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Sub

usdoj.gov U.S. Attorney's Office 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Telephone: Facsimile: Attorney for United States William L. Richey, Esq. .com William L. Richey P.A. 201 S. Biscayne Boulevard, 34th Floor Miami, Florida 33131 Telephone: (=1 Facsimile: Attorney for Subpoenaed

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 Declarati

that the Court allow the United States to file a Supplemental Ex Parte declaration, which further addresses the factual issues raised by Intervenor Epstein, without being forced to disclose the status of the grand jury investigation and the matters occurring before the grand jury to Epstein. Prior to i

parte Declaration in support of its Response to Jeffrey Epstein's Motion to Intervene and to Quash Subpoe

.S. Attorne U.S. Attorney's Office 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Telephone: Facsimile: Attorney for United States William L. Richey, Esq. EFTA00222982 William L. Richey P.A. 201 S. Biscayne Boulevard, 34th Floor Miami, Florida 33131 Telephone Facsimile: Attorney for Subpoe

JPN FINANCIAL SPONSORS Jan 12 2010 15:42 P.01 JEFFREY E..EPSTE1N To: William Doherty, JP K . / Froth

JPN FINANCIAL SPONSORS Jan 12 2010 15:42 P.01 JEFFREY E..EPSTE1N To: William Doherty, JP K . / Froth:

wire Two Thousand One Hundred*Bight Dollars 60/100 ($2,10040) from the. above account to; -Bank nein& CM, Bank _ABA, #: 063114289 'Account name: William L. Richey, P.A. • Account #: Reference: File Numbs 3743-2 ID: 03030.112M Ogg 01 M01 PM DID: 8887316607 CSID Pagel of Confidential Treatment Requested by