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

tion of criminal evidence that forecloses [the defendant's] attorney-client privilege argument . . ." Id. The district court addressed the cases of Clutchette v. Rushen, 770 F.2d 1469 (9th Cir. 1985), and People v. Meredith, 631 P.2d 46 (Cal. 1981). In Clutchette, the defendant's attorney had sent an inve

ry to the ability of Epstein's counsel to evaluate their significance; copies of the hard drives could have been made. Of course, unlike counsel in Clutchette and Meredith, Epstein's counsel never provided the evidence to law enforcement and, instead, tries to aver that the items may not exist. If that is

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

The district court addressed the cases of Clutchette I Rushen , 770 F.2d 1469 (9th Cir. 1985), and People I Meredith , 631 P.2d 46 (Cal. 1981). In Clutchette , the defendant's attorney had sent an investigator to collect incriminating evidence from a shopkeeper, and the trial court had allowed that eviden

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

tion of criminal evidence that forecloses [the defendant's] attorney-client privilege argument . . ." Id. The district court addressed the cases of Clutchette v. Rushen , 770 F.2d 1469 (9th Cir. 1985), and People v. Meredith , 631 P.2d 46 (Cal. 1981). In Clutchette , the defendant's attorney had sent an in

E WORK PRODUCT DOCTRINE. In asserting that the contents of the computers are covered by the attorney-client privilege or the work product doctrine, Epstein attempts to stretch the privileges beyond its limits. There has been no assertion that the computers themselves were communications or that the comp

The district court addressed the cases of Clutchette I Rushen , 770 F.2d 1469 (9th Cir. 1985), and People I Meredith , 631 P.2d 46 (Cal. 1981). In Clutchette , the defendant's attorney had sent an investigator to collect incriminating evidence from a shopkeeper, and the trial court had allowed that eviden