Epstein Secrets

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 surveillance also showed Sarah Kellen working on that computer. ( Id. at ¶ _.) it

n an area that appears to be the office of Sarah Kellen and another was in the pool cabana. (Recarey Aff.

ocuments, we now rule that it does not." (internal citation and quotations omitted)); United States, Wujkowski , 929 F.2d 981 (4th Cir. 1991); In re Sealed Case , 877 F.2d 83, 84 (D.C. Cir. 1989) (Fifth Amendment privilege "does not cover the contents of any voluntarily prepared records, including personal

ree computers were his private papers. As set forth in the Recarey Declaration, one of the computers was in an area that appears to be the office of Sarah Kellen and another was in the pool cabana. 4. The act of production doctrine would not have protected Epstein from producing the computers if they had rem

n an area that appears to be the office of Sarah Kellen and another was in the pool cabana. 4. The act o

idence stronger than in the context of a valid grand jury subpoena.'" In re Grand Jury Proceedings , 219 F.3d 175, 186 (2d Cir. 2000) (quoting In re Sealed Case , 676 F.2d 793, 806 (D.C. Cir. 1982)). See also In re Grand Jury Subpoena , 223 F.3d 213, 218 (3d Cir. 2000) ("One EFTA00222997 of the most signi

United States hereby opposes Epstein's motion and moves for an order to compel the appearance of witnesses and production of the requested items. 'Sarah is one of Epstein's personal assistants. -5- EFTA00179104 ARGUMENT I. THE UNITED STATES DOES NOT OPPOSE THE MOTION TO INTERVENE, IN PART. The

evidence stronger than in the context of a valid grand jury subpoena.' In re Grand Jury Proceedings, 219 F.3d 175, 186 (2d Cir. 2000) (quoting In re Sealed Case, 676 F.2d 793, 806 (D.C. Cir. 1982)). See also In re Grand Jury Subpoena, 223 F.3d 213, 218 (3d Cir. 2000) ("One of the most significant, if not th