Epstein Secrets

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

tem called for in the subpoena." (Epstein Reply at 6.) -2- EFTA00179087 document would tend to incriminate the target. See, e.g., United States v. Grable, 98 F.3d 251, 255, 257 (6 11' Cir. 1996) ("The existence of `substantial and real hazards of self-incrimination' is a prerequisite to the proper as

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

ge on a document by document basis explaining how the production of that document would tend to incriminate the target. See, e.g., United States v. Grable , 98 F.3d 251, 255, 257 (6 di Cir. 1996) ("The existence of `substantial and real hazards of self-incrimination' is a prerequisite to the proper ass

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

Accordin 1 , the United States has not previously had the opportunity to respond to the issue raised by EFTA01728790 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, and would file a motion to quash

TES' PLY TO REPLIES FILED BY WITNESS INTERVENOR JEFFREY EPSTEIN RE: ON TO OUASH GRAND JURY SUBPOENAS U

the computersthe items as they were removed from Mr. Epstein's home. The grand jury probably has the authority

tem called for in the subpoena." (Epstein Reply at 6.) -2- EFTA01728791 document would tend to incriminate the target. See, e.g., United States v. Grable, 98 F.3d 251, 255, 257 (6 h Cir. 1996) ("The existence of `substantial and real hazards of self-incrimination' is a prerequisite to the proper asse