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S DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA GRAND JURY MATTER FILED UNDER SEAL IN RE GRAND JURY SUBPOENAS ) DUCES TECUM IS D TO ) MOTION OF JEFFREY EPSTEIN TO INTERVENE AND TO QUASH GRAND JURY SUBPOENAS AND INCORPORATED MEMORANDUM OF LAW Now comes Jeffrey Epstein and respectfully moves this Honorable
Mr. Jeffrey Epstein, including, but not ling to, retainer agreements; employment agreements; billing statements (whether submitted directly to Mr. Epstein or to a third party for reimbursement); records of the dates when services were performed and the hours worked; ••••••r telephone logs or records
Y SUBPOENAS ) DUCES TECUM IS D TO ) MOTION OF JEFFREY EPSTEIN TO INTERVENE AND TO QUASH GRAND JURY SUB
illing statements (whether submitted directly to Mr. Epstein or to a third party for reimbursement); records
levant and irrelevant material — but to a heightened degree"). Recently, the Ninth Circuit expressly applied the principles of in United States v. Tamura, 694 F.2d 591 (9th Cir. 1982), a leading case on the Fourth Amendment issues presented by intermingled documents in the traditional paper document
computer context, noting that because "the computer era adds riew complexity, to the test of reasonableness under the Fourth Amendment", it viewed Tamura "as especially important in the computer context". United States v. Comprehensive Drug Testing, Inc., 473 F.3d 915, 939 (9th Cir. 2006). The review
eement of the parties. that appearance was rescheduled for July 17, 2007. The day before that scheduled appearance, i.e.. July 16. 2007. counsel for Jeffrey Epstein, who seeks to intervene in this matter, was informed by Deputy Chief that Riley did not have to appear physically before the grand jury if a motio
nformed by Deputy Chief that Riley did not have to appear physically before the grand jury if a motion to quash the subpoena at issue was filed by Epstein before the end of the day on July 17. 2007. As the Government's Response states. Epstein's motion to quash was filed on July 17, 2007 before the clo
he Response of the United States to the Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Sub
d jury subpoenas to investigator and his firm, Mr. Epstein is represented by undersigned counsel Roy Black.
levant and irrelevant material — but to a heightened degree"). Recently, the Ninth Circuit expressly applied the principles of in United States v. Tamura, 694 F.2d 591 (9th Cir. 1982), a leading case on the Fourth Amendment issues presented by intermingled documents in the traditional paper document
e computer context, noting that because "the computer era adds new complexity, to the test of reasonableness under the Fourth Amendment", it viewed Tamura "as especially important in the computer context". United States v. Comprehensive Drug Testing, Inc., 473 F.3d 915, 939 (9t1 Cir. 2006). The review
sted Item Number: Amount: Record Type: 7 January 02, 2015 9990020094806 January 02, 2015 4787843 50,000.00 Debit PAY 707HE ORDER CF MEMO Jeffrey E. Epstein G100 Rod Hock Cumlora. lit-3 S. Thomas, VI 00802.1348 (340) 7752525 FFISIOANK PUER7ORCO - ST. 1I-ICHAS.NOCOOt le1.728$7210 . :1 29. i7 2, -
t Date: February 27, 2020 First Bank JEFFREY E EPSTEIN 6100 RED HOOK QTRS STE 63 ST THOMAS VI 00802-1
9 Current Date: February 27, 2020 First Bank JEFFREY E EPSTEIN 6100 RED HOOK QTRS STE 63 ST THOMAS VI
843 50,000.00 Debit PAY 707HE ORDER CF MEMO Jeffrey E. Epstein G100 Rod Hock Cumlora. lit-3 S. Thomas,
statement, and we may cominue to charge You elver on that amount. But, if we determine that we made a mistake, you will not hereto pry tint .amount Tamura or any interim ante, lees related to that amours!. • What you do not hese to pay tne amount in question, you are (enamel. for the remainder Of yOur
f Contents IN THE NEWS • U.S. Violent Crime Fell 4.5% in 2024, Down for Second Year Running, FBI Says • House Oversight Chair Issues Subpoenas for Epstein Files • FBI Urged to Locate or Arrest Texas Democrats Who Fled State to Stall Redistricting Vote • What's Known and Not Yet Known About the DOJ's S
s lawyers have asked a Manhattan federal judge to deny the government's request to unseal grand jury transcripts from the investigation into her and Jeffrey Epstein. The request to unseal the transcripts was made by the Trump Justice Department, citing public interest in the case, but Maxwell's lawyers argue tha
stigation into the case of convicted sex offender Jeffrey Epstein. The subpoenas, which were approved by R
(08/05, Morphet) reported that police visited the home of gunman Shane Tamura, 27, twice in recent years due to concerns he was armed and suicidal. Tamura was subject to two mental health crisis interventions by Las Vegas police in 2022 and 2024. He was arrested for trespassing at a Las Vegas casino in
Lybrand), USA Today (08/05, Palmer), and Center for American Progress (08/05, Hall, Wilson, Eisenberg). House Oversight Chair Issues Subpoenas for Epstein Files CBS News (08/05, Quinn) reported that the House Oversight Committee has issued subpoenas to several former high•ranking government officials,
ing former President Bill Clinton and former Secretary of State Hillary Clinton, as part of an investigation into the case of convicted sex offender Jeffrey Epstein. The subpoenas, which were approved by Republicans and Democrats on a House Oversight subcommittee last month, also target former attorneys general
tigation into the case of convicted sex offender Jeffrey Epstein. The subpoenas, which were approved by Re
(08/05, Morphet) reported that police visited the home of gunman Shane Tamura, 27, twice in recent years due to concerns he was armed and suicidal. Tamura was subject to two mental health crisis interventions by Las Vegas police in 2022 and 2024. He was arrested for trespassing at a Las Vegas casino in
Lybrand), USA Today (08/05, Palmer), and Center for American Progress (08/OS, Hall, Wilson, Eisenberg). House Oversight Chair Issues Subpoenas for Epstein Files CBS News (08/05, Quinn) reported that the House Oversight Committee has issued subpoenas to several former high•ranking government officials,
ing former President Bill Clinton and former Secretary of State Hillary Clinton, as part of an investigation into the case of convicted sex offender Jeffrey Epstein. The subpoenas, which were approved by Republicans and Democrats on a House Oversight subcommittee last month, also target former attorneys general
tigation into the case of convicted sex offender Jeffrey Epstein. The subpoenas, which were approved by Re
(08/05, Morphet) reported that police visited the home of gunman Shane Tamura, 27, twice in recent years due to concerns he was armed and suicidal. Tamura was subject to two mental health crisis interventions by Las Vegas police in 2022 and 2024. He was arrested for trespassing at a Las Vegas casino in
sw.bearsteams.com What's In This Statement Ilmll...I..1,1I I I Financial Summary 3 FINANCIAL TRUST CO INC You' Portfolio Holdings 4 C/0 JEFFREY EPSTEIN Transaction Detail 7 6100 RED HOOK QUARTER Trades Not Yet Settled 13 STE 83 ST THOMAS VI 00802 Your Portfolio at a Glance Market Value
O INC You' Portfolio Holdings 4 C/0 JEFFREY EPSTEIN Transaction Detail 7 6100 RED HOOK QUARTER
TRUST CO INC You' Portfolio Holdings 4 C/0 JEFFREY EPSTEIN Transaction Detail 7 6100 RED HOOK
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Entities connected to both Jeffrey Epstein and Tamura
Leon Black
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Joi Ito
PERSON
Eric Trump
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
United States
LOCATION
Stephen Hawking
PERSON
Joe Biden
PERSON
Prince Charles
PERSON
Martha Stewart
PERSON
Michael Cohen
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
Bill Clinton
PERSONthe Southern District
LOCATIONFBI
ORGANIZATION
Sarah Ferguson
PERSONEmmy Taylor
PERSON