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

of Florida U.S. Attorney's Office 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 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, Komspa

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

Office 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Telephone: Facsimile: Attorney for United States -6- William L. Richey, Esq. 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

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

rney U.S. Attorney's Office West Palm Beach, FL 33401 Telephone: Facsimile: Attorney 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 Blac

nd through the undersigned Assistant United States Attorney, hereby files this Surreply to the Replies filed by Witness William Riley and Intervenor Jeffrey Epstein,' and notes the following: I. Both the witness and the intervenor assert that Mr. Riley was excused from appearing before the grand jury and that

ited States has not previously had the opportunity to respond to the issue raised by Mr. Riley. EFTA00222973 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 a

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

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

Attorne U.S. Attorney=s Office 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Telephone: Facsimile: Attorney for United States 5 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

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

strict of Florida ssistant U.S. Attome U.S. Attorney's Office 500 S. Australian Ave, Suite 400 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

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

Office 500 S. Australian Ave, Suite 400 West Palm Beach. FL 33401 Telephone: Facsimile: Attorney for United States -6- William L. Riche , Esq. William L. Richey P.A. 201 S. Biscayne Boulevard, 34th Floor Miami, Florida 33131 Telephone: Facsimile: Attorney for Sub oenaed Parties Service via U. . Mail Black,

oenaed Parties Riley Kiraly and William Riley 11 Black, Black, Srebnick, Kornspan & Stumpf, P.A. Telephone: Facsimile: Attorney for Intervenor Jeffrey Epstein EFTA00222950

y in connection with the investigation of Jeffrey Epstein. 6. The United States respectfully requests per

d fairly in connection with the investigation of Jeffrey Epstein. 6. The United States respectfully requ

nd Jury Subpoenas No. OLY-63 and OLY-64 United States District Court, Southern District of Florida William L. Richey, Esq. Assistant U.S. Attorne William L. Richey P.A. U.S. Attorney's Office 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Telephone: Facsimile: Attorney for United States 4 Telephon

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

fice 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 Parties Riley Kiraly and William Ri

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. 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 Subpoenaed Parties Riley Kiraly and William Riley