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.

y. Even if it could not, however, that is not a basis for refusing to produce the items. In United States v. Koubriti , 297 F. Supp. 2d 955, 969-70 (E.D. Mich. 2004), the court ordered the production of the defendant's handwritten notes that were in the possession of defense counsel where the United States knew

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.

ny. Even if it could not, however, that is not a basis for refusing to produce the items. In United States I Koubriti , 297 F. Supp. 2d 955, 969-70 (E.D. Mich. 2004), the court ordered the production of the defendant's handwritten notes that were in the possession of defense counsel where the United States knew

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

privilege on a question-by-question basis and decide whether a witness's silence is justified. United States v. Koubriti, 297 F. Supp. 2d 955, 962 (E.D. Mich. 2004) (citing Hoffinan, 341 U.S. at 53; United States v. Melchor Moreno, 536 F.2d 1042, 1049 (5th Cir. 1976); United States v. Rue, 819 F.2d 1488 (8th C