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

rimes that are `factually related' to a charged offense. Several of these courts have interpreted Brewer. Williams , 430 U.S. 387 (1977) and Maine. Moulton , 474 U.S. 159 — both of which were decided well before McNeil — to support this view, which respondent now invites us to approve. We decline to do

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

es that are 'factually related' to a charged offense. Several of these courts have interpreted Brewer v. Williams, 430 U.S. 387 (1977) and Maine v. Moulton, 474 U.S. 159 —both of which were decided well before McNeil — to support this view, which respondent now invites us to approve. We decline to do s

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

s that are `factually related' to a charged offense. Several of these courts have interpreted Brewer v. Williams , 430 U.S. 387 (1977) and Maine v. Moulton , 474 U.S. 159 — both of which were decided well before McNeil — to support this view, which respondent now invites us to approve. We decline to do

eloimore, MD 21203 THE HAZE TRUST UAD 02/09/99 JEFFREY EPSTEIN & DARREN K INDYKE TTEES 6100 RED HOOK QUARTER B

, MD 21203 THE HAZE TRUST UAD 02/09/99 JEFFREY EPSTEIN & DARREN K INDYKE TTEES 6100 RED HOOK QUARTER B

eloimore, MD 21203 THE HAZE TRUST UAD 02/09/99 JEFFREY EPSTEIN & DARREN K INDYKE TTEES 6100 RED HOOK Q

Deutsche Asset & Wealth Management P.O. Box 1776. Beloimore, MD 21203 THE HAZE TRUST UAD 02/09/99 JEFFREY EPSTEIN & DARREN K INDYKE TTEES 6100 RED HOOK QUARTER B3 ST THOMAS VI 00802 Your Client Advisor: DANIEL SABBA Devtvc le Ran. Peraile *tan lavutenale Yen

,670.21 663,261521.00 $63,171,329.53 100.00% See the Asset Allocation Discbsure and Footnotes section for important demotion regandrig your Asset Moulton. Go palx'rless -4" Please review your allocation penocrically with your Client Advaor. Page 1 of 11 c. perm etyma,: Pwawa • .....— CONFIDENTIA

to your brokerage account. page 36 of 36 CONFIDENTIAL SDNY_GM_00011725 EFTA 00122376 EFTA01267855 1D Ameritrade SOUTHERN FINANCIAL LLC ATTN: JEFFREY EPSTEIN 6100 RED HOOK QTRS STE B-3 ST THOMAS, VI 00802-1348 At the end of your September statement you'll find a copy of our Privacy Policy, which we pro

Ameritrade SOUTHERN FINANCIAL LLC ATTN: JEFFREY EPSTEIN 6100 RED HOOK QTRS STE B-3 ST THOMAS, VI 00802-

55 1D Ameritrade SOUTHERN FINANCIAL LLC ATTN: JEFFREY EPSTEIN 6100 RED HOOK QTRS STE B-3 ST THOMAS, V

D0111010 as 01 the regal dale and compares n to pie prior ~Ma The allsel lineation irdC81.34 your pOrd010 diveninCalion by investment type M.Mple Moulton under 5% me be groused into ~category el "Ctrs" in the pee chart. Margin Earn, - Told Amount Emiblimed Ming larvginable Value • Taal Shan Value) Ac

rade Clearing. Inc.. Member SIPC Statement Reporting Period: 03/01/15 - 03/31/15 Statement for Account # 867-730320 SOUTHERN FINANCIAL LLC ATTN: JEFFREY EPSTEIN 6100 RED HOOK OTRS STE 8-3 ST THOMAS. VI 00802.1348 Portfolio Summa Current Prior Period Estimated Investment Value Value Change Change

867-730320 SOUTHERN FINANCIAL LLC ATTN: JEFFREY EPSTEIN 6100 RED HOOK OTRS STE 8-3 ST THOMAS. VI 00802.

count # 867-730320 SOUTHERN FINANCIAL LLC ATTN: JEFFREY EPSTEIN 6100 RED HOOK OTRS STE 8-3 ST THOMAS. V

D0111010 as 01 the regal dale and compares n to pie prior ~Ma The allsel lineation irdC81.34 your pOrd010 diveninCalion by investment type M.Mple Moulton under 5% me be groused into ~category el "Ctrs" in the pee chart. Margin Earn, - Told Amount Emiblimed Ming larvginable Value • Taal Shan Value) Ac

91.23 51,591.65 page 2 of 2 CONFIDENTIAL SDNY_GM_00011909 $51,591.65 EFTA_00122560 EFTA01268039 1D Ameritrade SOUTHERN FINANCIAL LLC ATTN: JEFFREY EPSTEIN 6100 RED HOOK OTRS STE B-3 ST THOMAS, VI 00802-1348 CONFIDENTIAL SDNY_GM_00011910 EFTA 00122561 EFTA01268040 Terms and Conditions STATEMENT

Ameritrade SOUTHERN FINANCIAL LLC ATTN: JEFFREY EPSTEIN 6100 RED HOOK OTRS STE B-3 ST THOMAS, VI 00802-

39 1D Ameritrade SOUTHERN FINANCIAL LLC ATTN: JEFFREY EPSTEIN 6100 RED HOOK OTRS STE B-3 ST THOMAS, V

D0111010 as 01 the regal dale and compares n to pie prior ~Ma The allsel lineation irdC81.34 your pOrd010 diveninCalion by investment type M.Mple Moulton under 5% me be groused into ~category el "Ctrs" in the pee chart. Margin Earn, - Told Amount EmihriTmed Ming larvginable Value • Taal Shan Value) A

December 07,2001 - December 31,2001 Page 3 of 3 EPSTEIN INTERESTS Primary Account Number. JPMorgan Priv

tronic Fonds Transfers (personal accounts only! Telephone or ante to the. Bank if you think your striatum( or receipt is wrong. or it you need more 'Moulton/in about an electronic transaction on a statement or receipt The phone number for inquiries is pruned on the front of this statement. The address fo