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

(9th Cir. 1989). Accordingly, the United States asks the Court to compel the witnesses to appear before the grand jury on the next available date. Epstein's counsel argues first that his client should be allowed to intervene as a matter of right pursuant to Fed. R. Civ. P. 24(a)(2). Assuming that the C

target surfaces. In re Grand Jury Proceedings in Matter of Freeman , 708 F.2d 1571, 1574-75 (11th Cir. 1983) (citing In re Grand Jury Proceedings (Jeffrey Fine ), 641 F.2d 199, 201-03 (5th Cir. 1981)). As explained below, Mt Riley is not an attorney; Riley Kiraly is not a law firm; and the information sough

UNDER SEAL UNITED STATES' RESPONSE TO MOTION OF JEFFREY EPSTEIN TO TO INTERVENE AND TO QUASH GRAND JURY

of the investigation. When Guy Lewis stated that Mr. Epstein was willing to assist in the federal investigatio

Attorney for United States William L. Richey. Esq. William L. Richey P.A. 201 S. Biscayne Boulevard, 34th Floor Miami, Florida 33131 Attorney for Subpoenaed Parties Riley Kiraly and William Riley Black, Srebnick, Komspan & Stumpf, P.A. 201 S. Biscayne Boulevard, Suite 1300 Miami, FL 33131 Attorney for Interve

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

strict 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 Epstein Service via Hand Delivery aRi

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

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 Black, Srebnick, Koms an & Stum f, P.A. Miami, FL 33131 Telephon Facsimile Attorney or n e

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

torney for United States EFTA00211798 William L. Richey, Esq. William L. Richey P.A. Miami, Florida 33131 Telephone l Facsimile: Attorney for Subpoenaed Parties Riley Kiraly and William Riley Service via Federal Express Roy Black, Esq. Black Srebnick, Koms an & Stum f, P.A. Miami, FL 33131 Telephone l F

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. 2. In the Reply filed by Intervenor Epstein, counsel asserts that "simple possession of the physical containers [the computers] is not the government's real object here. What the government ac

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

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

Attorney for United States William L. Riche Esq. William L. Richey P.A. 201 S. Biscayne Boulevard, 34th Floor Miami, Florida 33131 Attorney for Subpoenaed Parties Riley Kiraly and William Riley Service via U.S. Mail I Roy Black, Esq. EFTA00222978 Black, Srebnick, Komspan & Stumpf, P.A. 201 S. Biscayne Bou

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

L. Richey, Esq. .com William L. Richey P.A. 201 S. Biscayne Boulevard, 34th Floor Miami, Florida 33131 Telephone: (=1 Facsimile: Attorney for Subpoenaed Parties Riley Kiraly and William Riley Roy Black, Esq. .com Black, Srebnick, Komspan & Stumpf, P.A. 201 S. Biscayne Boulevard, Suite 1300 Miami, FL 3313

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

Richey, Esq. EFTA00222982 William L. Richey P.A. 201 S. Biscayne Boulevard, 34th Floor Miami, Florida 33131 Telephone Facsimile: Attorney for Subpoenaed Parties Riley Kiraly and William Riley Roy Black, Esq. Black, Srebnick, Komspan & Stumpf, P.A. 201 S. Biscayne Boulevard, Suite 1300 Miami, FL 33131 Tel