Epstein Secrets

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

jury. There, unlike here, the attorney properly appeared to testify and then asserted a claim of privilege in response to particular questions. The Seventh Circuit found that the following questions did not call for privileged communications: (1) Whom did you direct [in the search of documents responsive to the

Tapes or transcripts of any and all proceedings before the Grand Jury on Wednesday, July 19, 2006, referring or relating to Jeffrey Epstein and/or Sarah Kellen, including but not limited to witness testimony, statements made by any member of the State Attorney's Office, and instructions given by any member

rring or relating to Jeffrey Epstein and/or Sarah Kellen, including but not limited to witness testimony,

4C rAA 0010V41JOI VaAv tiff, IL, 832 F.2d 554 832 F.2d 554, 24 Fed. R. Evid. Sm. 275 (Cite as: 832 F.2d 554) H United States Court of Appeals, Seventh Circuit. In re GRAND JURY PROCEEDINGS—Subpoena to State Attorney's Office. Thomas H. Greene, Dawson A. McQuaig, Jake Godbold, Don McClure, Intervenors- A

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

2001) (information regarding the receipt of attorney's fees is not protected). In Matter of Grand Jury Proceeding, 68 F.3d 193 (7th Cir. 1995), the Seventh Circuit discussed specific questions asked of an attorney during his testimony before the grand jury. There, unlike here, the attorney properly appeared to