Epstein Secrets

d States respectfully requests that the Court deny the Motion to Quash and order the prompt compliance with the subpoenas. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: A. Assistant United States Attorney Florida Bar 500 South Australian Avenue, Suite 400 West Palm Beach, FL 33401 T

subpoenas. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: A. Assistant Unite

allow Court to conduct in camera inspection to determine whether act of production privilege applied); United States v. Bell ,a 217 F.R.D. 335, 339 (M.D. Pa. 2003) (Although voluntarily created documents are not protected by the Fifth Amendment, an act of production privilege can be asserted, but only when "i

verly burdensome, and Riley Kiraly is the owner of those documents and is best suited to make such a claim, if warranted. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: CERTIFICATE OF SERVICE 6 EFTA00234919 I HEREBY CERTIFY that on July 2007, the foregoing document will be served v

warranted. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: CERTIFICATE OF SERV

allow Court to conduct in camera inspection to determine whether act of production privilege applied); United States I. Be11,3 217 F.R.D. 335, 339 (M.D. Pa. 2003) (Although voluntarily created documents are not protected by the Fifth Amendment, an act of production privilege can be asserted, but only when "i

d States respectfully requests that the Court deny the Motion to Quash and order the prompt compliance with the subpoenas. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: Assistant United States Attorney ou u an venue, Suite 400 West Palm Beach, FL 33401 Telephone: Facsimile: E-mail

subpoenas. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: Assistant United St

allow Court to conduct in camera inspection to determine whether act of production privilege applied); United States v. Be11,3 217 F.R.D. 335, 339 (M.D. Pa. 2003) (Although voluntarily created documents are not protected by the Fifth Amendment, an act of production privilege can be asserted, but only when "it

by Ms. Sanchez prior to Mr. Richey's appearance as counsel for Mr...I cc: , Esq. William Richey, Esq. Lilly Ann Sanchez, Esq. B Sincerely, R. Alexander Acosta Assistant United States Attorney EFTA00178979 U.S. Department of Justice United States Attorney Southern District of Florida 500 South Austral

ly Ann Sanchez, Esq. B Sincerely, R. Alexander Acosta Assistant United States Attorney EFTA00178979

[defendant] from his files; [c]learly such an act of production is testimonial, and may not be compelled"); United States v. Bell, 217 F.R.D. 335 (M.D. Pa. 2003) (where government lacks knowledge of specific documents, party's production of the subpoenaed documents would testify to their existence and his p

Ile...LeneA nein Black srcbmck. Kornsparl & Stumpf EFTA00179082 U.S. Department Justice United States Attorney Southern District of Florida R. ALEXANDER ACOSTA UNITED STATES ATTORNEY VIA FACSIMILE Lilly Ann Sanchez, Esq. Fowler White Burnett 1395 Brickell Ave Fl 14 Miami Florida 33131-3300 Re: Jeffre

ANN SANCHEZ, ESQ. AUGUST 3, 2007 PAGE 2 Please let us know your client's decision by no later than August 17. I have conferred with U.S. Attorney Acosta who has asked me to communicate that the two-year term of incarceration is a non-negotiable minimum to vindicate a federal interest, and, at this ti

allow Court to conduct in camera inspection to determine whether act of production privilege applied); United States v. Bell; 217 F.R.D. 335, 339 (M.D. Pa. 2003) (Although voluntarily created documents are not protected by the Fifth Amendment, an act of production privilege can.be asserted, but only when "it