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

y have known about the United States' attempts to locate those computers for at least two months, when a subpoena for the same items was served upon Paul Lavery, another private investigator who worked with Riley. This is not a situation where failure to abide by the Court's rules should be tolerated. III.

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

have known about the United States' attempts to locate those computers for at least two months, when a subpoena for the same items was served upon Paul Lavery, another private investigator who worked with Riley. This is not a situation where failure to abide by the Court's rules should be tolerated. III.

8 summarize briefly your previous testimony about her. 9 A Jane Doe number 3 is z and she first 10 started, we have first phone contact with Kellen 11 starting in December of 2004, would have been 16 12 or 17 at that time, let me do the math real quick, she 13 would have been 16 sorry, I

pstein's home, they found computer monitors and equipment, but no CPUs. From the continued investi ,ation we know that the computers were removed by Paul Lavery, a private investigator, with the help of one of our targets. Now that we know that Lavery removed the computers, I would like to subpoena the comp