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

" In re Grand Jury Proceedings in Matter of Freeman, 708 F.2d 1571, 1576 (1 1 th Cir. 1983) (extensive citations omitted). 4. The issues raised by Intervenor Epstein's Motion to Quash require the United States to provide information obtained through the Grand Jury's investigation. Due to the pendency of the investigation, and the

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

e." In re Grand Jury Proceedings in Matter of Freeman; 708 F.2d 1571, 1576 (11th Cir. 1983) (extensive citations omitted). 4. The issues raised by Intervenor Epstein's Motion to Quash require the United States to provide information obtained through the Grand Jury's investigation. Due to the pendency of the investigation, and the

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

e." In re Grand Jwy Proceedings in Matter of Freeman , 708 F.2d 1571, 1576 (11th Cir. 1983) (extensive citations omitted). 4. The issues raised by Intervenor Epstein's Motion to Quash require the United States to provide information obtained through the Grand Jury's investigation. Due to the pendency of the investigation, EFTA002