Document Mentions (3 shared documents)

EFTA00222963

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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.

f any voluntarily prepared records, including personal ones"); In re Grand Jury Proceedings , 759 F.2d 1418, 1419 (9th Cir. 1985); United States I Bedell & Co. , 2006 WL 3813792, ■1 (E.D.N.Y Oct. 30, 2006) ("It is well settled that the Fifth Amendment `does not protect the contents of voluntarily prepared d

EFTA00222992

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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

EFTA00178967_sub_002 - EFTA00178967_200

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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

of any voluntarily prepared records, including personal ones"); In re Grand Jury Proceedings, 759 F.2d 1418, 1419 (9th Cir. 1985); United States v. Bedell & Co., 2006 WL 3813792, *1 (E.D.N.Y Oct. 30, 2006) ("It is well settled that the Fifth Amendment 'does not protect the contents of voluntarily prepared d