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Reinhart's involvement in and/or awareness of the Government's interest in any witness, subject, or target of the Epstein investigation, including Sarah Kellen, Ghislaine Maxwell, Nadia Marcinkova, Lesley Groff, Haley Robson, Louella Ruboyo, Larry Morrison, Larry Visoki, David Rogers, William Hammond, and
espondence, and other information (including, for example, e- mails) that were sent to, copied to, or sent by Reinhart in which the word "Epstein," "Kellen, "Ruboyo," "Morrison," "Visoki," "Rogers," "Hammond," Roxburgh," "Villafana, " "Florida Science Foundation," "Starr," "Black," "Goldberger," "Jeffr
defense attorneys representing Epstein (including, but not limited to, Roy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein (including, but not limited to former President
Reinhart's involvement in and/or awareness of the Government's interest in any witness, subject, or target of the Epstein investigation, including Sarah Kellen, Ghislaine Maxwell, Nadia Marcinkova, Lesley Groff, Haley Robson, Louella Ruboyo, Larry Morrison, Larry Visoki, David Rogers, William Hammond, and
espondence, and other information (including, for example, e- mails) that were sent to, copied to, or sent by Reinhart in which the word "Epstein," "Kellen, "Ruboyo," "Morrison," "Visoki," "Rogers," "Hammond," Roxburgh," "Villafana, " "Florida Science Foundation," "Starr," "Black," "Goldberger," "Jeffr
defense attorneys representing Epstein (including, but not limited to, Roy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein (including, but not limited to former President
Reinhart's involvement in and/or awareness of the Government's interest in any witness, subject, or target of the Epstein investigation, including Sarah Kellen, Ghislaine Maxwell, Nadia Marcinkova, Lesley Groff, Haley Robson, Louella Ruboyo, Larry Morrison, Larry Visoki, David Rogers, William Hammond, and
espondence, and other information (including, for example, e- mails) that were sent to, copied to, or sent by Reinhart in which the word "Epstein," "Kellen, "Ruboyo," "Morrison," "Visoki," "Rogers," "Hammond," Roxburgh," "Villafana, " "Florida Science Foundation," "Starr," "Black," "Goldberger," "Jeffr
defense attorneys representing Epstein (including, but not limited to, Roy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein (including, but not limited to former President
Reinhart's involvement in and/or awareness of the Government's interest in any witness, subject, or target of the Epstein investigation, including Sarah Kellen, Ghislaine Maxwell, Nadia Marcinkova, Lesley Groff, Haley Robson, Louella Ruboyo, Larry Morrison, Larry Visoki, David Rogers, William Hammond, and
espondence, and other information (including, for example, e- mails) that were sent to, copied to, or sent by Reinhart in which the word "Epstein," "Kellen, "Ruboyo," "Morrison," "Visoki," "Rogers," "Hammond," Roxburgh," "Villafana, " "Florida Science Foundation," "Starr," "Black," "Goldberger," "Jeffr
defense attorneys representing Epstein (including, but not limited to, Roy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein (including, but not limited to former President
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
former Southern District of Florida U.S. Attorney Guy Lewis and former Southern District of Florida Assistant U.S. Attorneys Lilly Ann Sanchez and Michael Tien. FSThe wires and peripheral devices were present but the central processing units ("CPUs") were gone. Sarah Kellen is one of Epstein's personal ass
espondence, and other information (including, for example, e- mails) that were sent to, copied to, or sent by Reinhart in which the word "Epstein," "Kellen, "Ruboyo," "Morrison," "Visoki," "Rogers," "Hammond," Roxburgh," "Villafana, " "Florida Science Foundation," "Starr," "Black," "Goldberger," "Jeffr
defense attorneys representing Epstein (including, but not limited to, Roy Black, Jay Lefkowitz, Jack Goldberger, Martin Weinberg, Gerald Lefcourt, Michael Tien, Guy Lewis, Lilly Ann Sanchez, Ken Starr, Alan Dershowitz) and agents acting in support of Epstein (including, but not limited to former President
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
former Southern District of Florida U.S. Attorney Guy Lewis and former Southern District of Florida Assistant U.S. Attorneys Lilly Ann Sanchez and Michael Tien. SThe wires and peripheral devices were present but the central processing units ("CPUs") were gone. -4- EFTA00179103 home (at Epstein's invitat
Entities connected to both Sarah Kellen and Michael Tien

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Ghislaine Maxwell
PERSONJane Doe
PERSON
Marc Rich
PERSONJack Goldberger
PERSONLarry Visoski
PERSON
Bradley Edwards
PERSONNadia Marcinkova
PERSON
Paul Cassell
PERSON
Alan Dershowitz
PERSON
Kenneth Marra
PERSON
Prince Andrew
PERSONBruce E. Reinhart
PERSON
United States
LOCATIONLeon Black
PERSON
George W. Bush
PERSONRobert C. Josefsberg
PERSONKatherine W. Ezell
PERSON
Salt Lake City
LOCATION