Epstein Secrets

ndersigned Assistant United States Attorney, and files this response to the Court's Order requesting the position of the United States on Defendant Jeffrey Epstein's Motion to Stay Proceedings [DE 99]. For the reasons set forth below, it is the United States' position that a stay of the proceedings is not necessa

f the civil proceedings in the "interests of justice" until the "expiration" of the Non- Prosecution Agreement ["NPA"] between the United States and Epstein? By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to the outcome of an

Y. 1655 Pike DeleePh.„,.. .ML lt Fst!ii!lefleach, IR. »CI 1 0 C) Par 1 sprat your tether rear*, taw fifty sullierdoller 2 leoseit arrest Jeffrey ipater says that pH, lir with 3 your aunt and tale ad bar bra liar trots le that I Cerrees7 S Us. 6 0. Iles ray have you bra lira with P

es the United States take any position regarding Defendant Epstein's performance of hi s obligations pursuant to th

have prepared documents to charge at least one of Mr. Epstein's lady friends in state court. If they can push

thei't NW ass. sir. O. 00 yea know who Doff fey Slow NI A. N. Pie. 0. Clo yet hew who J'effroy Mnia 14/ A. 0. That.. the layer who flest and Spytein os ynr nYlf. tleht7 500•11 au In. Noun •Pmetted piet hally any M. LIN101.0i hey coriertetlere that ~et had with At. Soso 'Nordin.; Not Issue. y

oceeding does not rise to the level of an unconstitutional infringement.'" Id. (quoting Shell Oil Co.'. Alan° Assocs., Inc., 866 F. Supp. 536, 540 (M.D. Fl. 1994)). As this Court has previously explained: The law regardii stays of civil actions is well-settled in the Eleventh Circuit. In United States

ndersigned Assistant United States Attorney, and files this response to the Court's Order requesting the position of the United States on Defendant Jeffrey Epstein's Motion to Stay Proceedings [DE 99]. For the reasons set forth below, it is the United States' position that a stay of the proceedings is not necessa

f the civil proceedings in the "interests of justice" until the "expiration" of the Non-Prosecution Agreement ["NPA"] between the United States and Epstein? EFTA00222779 By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to th

es the United States take any position regarding Defendant Epstein's performance of his obligations pursuant to the

NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. / JANE DOE NO. 3, CASE N

ntly pending, Epstein has asked the Court to unseal the victims' names so that he may make use similar press efforts to impugn their credibility. a tEpstein points to provisions requiring him to maintain certain evidence "inviolate" as proof that the grand jury investigation is still active. These provis

oceeding does not rise to the level of an unconstitutional infringement.' Id. (quoting Shell Oil Co. I Altina Assocs., Inc. , 866 F. Supp. 536, 540 (M.D. Fl. 1994)). As this Court has previously explained: The law regarding stays of civil actions is well-settled in the Eleventh Circuit. In United Stat

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

t facts to state with reasonable certainty that the privilege applies, the burden is not met." United States I Blackburn , 538 F. Supp. 1376, 1382 (M.D. Fl. 1982) (citing Federal Trade Commission I TRW Inc. , 628 F.2d 207, 213 (D.C. Cir. 1980); In re Katz , 623 F.2d 122, 125 (2d Cir. 1980); United State

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

nt facts to state with reasonable certainty that the privilege applies, the burden is not met." United States v. Blackburn, 538 F. Supp. 1376, 1382 (M.D. Fl. 1982) (citing Federal Trade Commission v. TRW, Inc., 628 F.2d 207, 213 (D.C. Cir. 1980); In re Katz, 623 F.2d 122, 125 (2d Cir. 1980); United Stat

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

facts to state with reasonable certainty that the privilege applies, the burden is not met." United States v. Blackburn , 538 F. Supp. 1376, 1382 (M.D. Fl. 1982) (citing Federal Trade Commission v. TRW Inc. , 628 F.2d 207, 213 (D.C. Cir. 1980); In re Katz , 623 F.2d 122, 125 (2d Cir. 1980); United Stat

ndersigned Assistant United States Attorney, and files this response to the Court's Order requesting the position of the United States on Defendant Jeffrey Epstein's Motion to Stay Proceedings [DE 99]. For the reasons set forth below, it is the United States' position that a stay of the proceedings is not necessa

oceedings in the "interests of justice" until the "expiration" of the Non-Prosecution EFTA00213025 Agreement ["NPA"] between the United States and Epstein? By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to the outcome of an

es the United States take any position regarding Defendant Epstein's performance of his obligations pursuant to the

NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. / JANE DOE NO. 3, CASE N

ceeding does not rise to the level of an unconstitutional infringement.' Id. (quoting Shell Oil Co. v. Altina Assocs., Inc. , 866 F. Supp. 536, 540 (M.D. Fl. 1994)). As this Court has previously explained: The law regarding stays of civil actions is well-settled in the Eleventh Circuit. In United Stat

es the United States take any position regarding Defendant Epstein's performance of his obligations pursuant to the

NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.:

spondence or oral communications between the parties in these civil suits. Based on the information presented by the Court and a review of Defendant Jeffrey Epstein's Motion to Stay and/or Continue Action for Time Certain Based on Parallel Civil and Criminal Proceedings with Incorporated Memorandum of Law (Court

f the civil proceedings in the "interests of justice" until the "expiration" of the Non- Prosecution Agreement ["NPA"] between the United States and Epstein? By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to the outcome of an

roceeding does not rise to the level of an unconstitutional infringement.' Id. (quoting Shell Oil Co.l Altina Assocs., Inc., 866 F. Supp. 536, 540 (M.D. Fl. 1994)). As this Court has previously explained: The law regardini stays of civil actions is well-settled in the Eleventh Circuit. In United State

ndersigned Assistant United States Attorney, and files this response to the Court's Order requesting the position of the United States on Defendant Jeffrey Epstein's Motion to Stay Proceedings [DE 99]. For the reasons set forth below, it is the United States' position that a stay of the proceedings is not necessa

oceedings in the "interests of justice" until the "expiration" of the Non-Prosecution EFTA00222789 Agreement ["NPA"] between the United States and Epstein? By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to the outcome of an

es the United States take any position regarding Defendant Epstein's performance of his obligations pursuant to the

NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. / JANE DOE NO. 3, CASE N

oceeding does not rise to the level of an unconstitutional infringement.' Id. (quoting Shell Oil Co. I Altina Assocs., Inc. , 866 F. Supp. 536, 540 (M.D. Fl. 1994)). As this Court has previously explained: The law regarding stays of civil actions is well-settled in the Eleventh Circuit. In United Stat

spondence or oral communications between the parties in these civil suits. Based on the information presented by the Court and a review of Defendant Jeffrey Epstein's Motion to Stay and/or Continue Action for Time Certain Based on Parallel Civil and Criminal Proceedings with Incorporated Memorandum of Law (Court

f the civil proceedings in the "interests of justice" until the "expiration" of the Non- Prosecution Agreement ["NPA"] between the United States and Epstein? By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to the outcome of an

es the United States take any position regarding Defendant Epstein's performance of his obligations pursuant to the

NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.:

roceeding does not rise to the level of an unconstitutional infringement.' Id. (quoting Shell Oil Co.l Altina Assocs., Inc., 866 F. Supp. 536, 540 (M.D. Fl. 1994)). As this Court has previously explained: The law regardini stays of civil actions is well-settled in the Eleventh Circuit. In United State

ndersigned Assistant United States Attorney, and files this response to the Court's Order requesting the position of the United States on Defendant Jeffrey Epstein's Motion to Stay Proceedings [DE 99]. For the reasons set forth below, it is the United States' position that a stay of the proceedings is not necessa

oceedings in the "interests of justice" until the "expiration" of the Non-Prosecution EFTA00222799 Agreement ["NPA"] between the United States and Epstein? By filing this response, the United States does not make itself a party to this litigation and takes no position with respect to the outcome of an

es the United States take any position regarding Defendant Epstein's performance of his obligations pursuant to the

NO.: 08-CV-80119-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. / JANE DOE NO. 3, CASE N

oceeding does not rise to the level of an unconstitutional infringement.' Id. (quoting Shell Oil Co. I Altina Assocs., Inc. , 866 F. Supp. 536, 540 (M.D. Fl. 1994)). As this Court has previously explained: The law regarding stays of civil actions is well-settled in the Eleventh Circuit. In United Stat