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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
to society's compelling interest in finding, convicting, and punishing those who violate the law. Id. at 172-73 (quoting McNeil, 501 U.S. at 181). Two Courts of Appeals have addressed Cobb in the context of persons charged by state prosecutors who are later interrogated by federal agents. In those cases, the courts
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
to society's compelling interest in finding, convicting, and punishing those who violate the law. Id. at 172-73 (quoting McNeil, 501 U.S. at 181). Two Courts of Appeals have addressed Cobb in the context of persons charged by state "In Cobb, the Court went on to decide that Texas police officers did not violate Cobb
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
to society's compelling interest in finding, convicting, and punishing those who violate the law. Id. at 172-73 (quoting McNeil, 501 U.S. at 181). Two Courts of Appeals have addressed Cobb in the context of persons charged by state prosecutors who are later interrogated by federal agents. In those cases, the courts
Entities connected to both Jeffrey Epstein and Two Courts of Appeals
Leon Black
PERSON
Alan Dershowitz
PERSON
United States
LOCATIONJack Goldberger
PERSON
Sarah Kellen
PERSON
FedEx
ORGANIZATIONSouthern District
LOCATION
Julie K. Brown
PERSON
Alexander Acosta
PERSONFBI
ORGANIZATION
Scarlett Johansson
PERSONEmmy Taylor
PERSONRoy Black
PERSONBarrett
PERSONGerald Lefcourt
PERSON
United States District Court
ORGANIZATION
Palm Beach Police Department
ORGANIZATION
Supreme Court
ORGANIZATION
Tony Blair
PERSONSecond Circuit
ORGANIZATION