Epstein Secrets

CE I HEREBY CERTIFY that on July , 2007, the foregoing document and the Declaration of Joseph Recarey will be served via hand delivery on Attorney Roy Black, counsel for Jeffrey Epstein. The same documents will be served on William Richey, counsel for William Riley and Riley Kiraly, via Federal Express.

an attorney does not render everything he does for or with the client privileged." Gutter v. E.I. DuPont de Nemours and Co. , 1998 WL 2017926, *1 (S.D. Fl. May 18, 1998) EFTA00211785 (citations omitted). If an attorney (or his agent) was doing something other than rendering legal advice, neither the

tion, please contact me at my office, or on my cell phone at trU bat Enclosures cc: , AUSA AUSA and Professional Responsibility Officer AUSA Roy Black, Esq., Counsel to the Putative Defendant Michael Tein, Esq., Counsel to the Putative Defendant In addition to the general rules regarding confident

VICTIM [NAME] [DATE] PAGE 3 OF 3 attorney to represent her, that attorney can review the Court's order in the matter of In re Jane Does 1 and 2, S.D. Fl. Court File No. 08-80736-CIV-MAltRA. As I stated in my earlier notification, please understand that neither the U.S. Attorney's Office nor the Fede

CE I HEREBY CERTIFY that on July , 2007, the foregoing document and the Declaration of Joseph Recarey will be served via hand delivery on Attorney Roy Black, counsel for Jeffrey Epstein. The same documents will be served on William Richey, counsel for William Riley and Riley Kiraly, via Federal Express.

s an attorney does not render everything he does for or with the client privileged." Gutter I E.I. DuPont de Nemours and Co. , 1998 WL 2017926, *1 (S.D. Fl. May 18, 1998) EFTA00223001 (citations omitted). If an attorney (or his agent) was doing something other than rendering legal advice, neither the

TE 1300. MIAMI. FL 33131 Telephone: SIM On behalf of (select one): 7eCCrey erste ;71 K Plaintiff K Defendant SEALED DOCUMENT TRACKING FORM Name: ROY BLACK, ESQ. Date sealed document filed: 8/7/2007 If sealed pursuant to statute, cite statute: GRAND JURY PROCEEDING If sealed pursuant to previously en

nited States in evaluating that claim, but Epstein has objected to the production of those documents. -17- EFTA00179116 Co., 1998 WL 2017926, *1 (S.D. Fl. May 18, 1998) (citations omitted). If an attorney (or his agent) was doing something other than rendering legal advice, neither the attorney-client

igation, and this information is confidential pursuant to Federal Rule of Criminal Procedure 6(e). In an abundance of caution, defense team members Roy Black and Martin Weinberg, two of the attorneys who represented Jeffrey Epstein during the investigation, are filing this pleading to provide notice to t

and sealing is appropriate in connection with grand jury proceedings. As explained by Judge Jordan in United States' Steinger, 626 F. Supp. 2d 1231 (S.D. Fl. 2009): "The proper functioning of our grand iury system depends upon the secrecy of grand jury proceedings," Douglas Oil Co. Petrol Stops Northwe