Epstein Secrets

even when the information would incriminate the client "in the very case in which the Firm was engaged to provide criminal defense representation." Gerald B. Lefcourt, P.C. v. United States , 125 F.3d 79, 87 (2d Cir. 1997). In that case, Attorney Lefcourt refused to identify in an IRS reporting form a client who p

aged to provide criminal defense representation." Gerald B. Lefcourt, P.C. v. United States , 125 F.3d 79, 87 (2d Cir. 1997). In that case, Attorney Lefcourt refused to identify in an IRS reporting form a client who paid him more than $10,000 cash, and Lefcourt was fined $25,000. Lefcourt sought to avoid

protected, not the relationship as a whole. McKay v. C.I.R. , 886 F.2d 1237 (9th Cir. 1989). VII. THE SUBPOENAS ARE NOT OPPRESSIVE, OVERBROAD, AND UNPARTICULARIZED. Epstein also asserts that the subpoenas seeking the computer equipment are unreasonable because they are oppressive, overbroad, and unparticulariz

even when the information would incriminate the client "in the very case in which the Firm was engaged to provide criminal defense representation." Gerald B. Lefcourt, P.C. I United States , 125 F.3d 79, 87 (2d Cir. 1997). In that case, Attorney Lefcourt refused to identify in an IRS reporting form a client who pa

gaged to provide criminal defense representation." Gerald B. Lefcourt, P.C. I United States , 125 F.3d 79, 87 (2d Cir. 1997). In that case, Attorney Lefcourt refused to identify in an IRS reporting form a client who paid him more than $10,000 cash, and Lefcourt was fined $25,000. Lefcourt sought to avoid

re protected, not the relationship as a whole. McKay' C.I.R. , 886 F.2d 1237 (9th Cir. 1989). VII. THE SUBPOENAS ARE NOT OPPRESSIVE, OVERBROAD, AND UNPARTICULARIZED. Epstein also asserts that the subpoenas seeking the computer equipment are unreasonable because they are oppressive, overbroad, and unparticulariz

et with counsel for Mr. Epstein. Sincerely, R. Alexander Acosta United States Attorney ...••••••• By: Chief, Criminal Division cc: Roy Black Gerald B. Lefcourt R. Alexander Acosta EFTA00179084 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY

aged to provide criminal defense representation." Gerald B. Lefcourt, P.C. v. United States, 125 F.3d 79, 87 (2d Cir. 1997). In that case, Attorney Lefcourt refused to identify in an IRS reporting form a client who paid him more than $10,000 cash, and Lefcourt was fined $25,000. Lefcourt sought to avoid

protected, not the relationship as a whole. McKay v. C.I.R., 886 F.2d 1237 (9th Cir. 1989). VII. THE SUBPOENAS ARE NOT OPPRESSIVE, OVERBROAD, AND UNPARTICULARIZED. Epstein also asserts that the subpoenas seeking the computer equipment are unreasonable because they are oppressive, overbroad, and unparticulariz

LY ANN SANCHEZ, ESQ. NOveMBat 16, 2006 PAGE 3 oF 3 Thank you for your assistance with this matter, and I look forward to working with you and Mr. Lercourt. Sincerely, Alexander Acosta United States Attorney By: Assistant United States Attorney EFTA00179051 EXHIBIT E EFTA00179052 JUL-09-2007

ERMITTED TO SEIZE THE COMPUTERS ON THE BASIS OF A GRAND JURY SUBPOENA, THE SUBPOENAS MUST BE QUASHED AS UNREASONABLE AND OPPRESSIVE, OVERBROAD AND UNPARTICULARIZED. Paragraphs 1 and 2 of the subpoenas suggest no limitation on the ability of the govemmel ters. Instead, the government purports to be sessi