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

articularity that it knows of the existence and location of subpoenaed documents.") (citation EFTA00223006 omitted). In this case, as set forth in the Recarey Affidavit and the two Ex Pane Affidavits, the government already knows that: (1) the computers exist; (2) they are in the custody or control of Riley; and (3)

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

articularity that it knows of the existence and location of subpoenaed documents.") (citation EFTA00211790 omitted). In this case, as set forth in the Recarey Affidavit and the two Ex Pane Affidavits, the government already knows that: (1) the computers exist; (2) they are in the custody or control of Riley; and (3)

THE SUBPOENA FOR THE CONTENTS OF EPSTEIN'S COMPUTERS, EVEN IF CONSIDERED "PURELY PRIVATE PAPERS," DOES NOT VIOLATE EPSTEIN'S FIFTH AMENDMENT PRIVILEGE. Lastly, Epstein argues that the subpoena seeks "purely private papers," and that a subpoena demanding those papers vi

te papers. There has been no showing by Epstein that all of the documents contained on the three computers were his private papers. As set forth in the Recarey Affidavit, one of the computers was in an area that appears to be the office of Sarah Kellen and another was in the pool cabana. (Recarey Aff. at ¶ _.) Video