Epstein Secrets

and placed in the public portion of the court file O Destroyed 0 Returned to the party or counsel for the party, as identified above A`tancy for: United Stales of Vifierica EFTA00179092 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE: GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY-64 AND

ry on September 18, 2007. However, 'Witness William Riley did not file an initial motion to quash the grand jury subpoenas, but did file a Reply to the United States' Response to the Intervenor's Motion to Quash. Accordingly, the United States has not previously had the opportunity to respond to the issue raised b

vestigation of these crimes involving the sexual exploitation of minors. The Supreme Court has routinely recognized the grand jury's unique role in the United States' criminal justice system. The grand jury "belongs to no branch of the institutional Government, serving as a kind of buffer or referee between the Go

FLORIDA IN RE GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY-63 and OLY-64 FGJ 07-103(WPB) UNDER SEAL ORDER THIS CAUSE came before the Court on the United States of America's Motion for Permission to File a supplemental Ex Parte Affidavit in support of its Response to the Motion to Quash. Upon review of the motion, it i

84 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY-63 and OLY-64 FGJ 07-103(WPB) UNITED STATES' SURREPLY TO REPLIES FILED BY WITNESS WILLIAM RILEY AND INTERVENOR JEFFREY EPSTEIN RE: MOTION TO OUASH GRAND JURY SUBPOENAS UNDER SEAL EFTA0017908

(1991) that the "Sixth Amendment right to counsel is offense specific. It cannot be invoked once for all future prosecutions." Id. at 167 (quoting McNeil at 175). The Cobb Court noted that some -34- EFTA00179133 other courts: have read into McNeil's offense-specific definition an exception for crim

nsel have had access to the subpoenaed computers since at least October 2005, when they were removed from Epstein's home, and they have known about the United States' attempts to locate those computers for at least two months, when a subpoena for the same items was served upon Paul Lavery, another private investig

n had standing to assert these challenges, the subpoenas are not unreasonable and do not violate any act of production privilege. For these reasons, the United States asks the Court to deny the Motion to Quash and to order the prompt production of the requested items and the witnesses' appearances before the Grand

papers of any kind. The notion that the Fifth Amendment rotects the privacy of papers originated in Boyd I United States , . . but our decision in Fisher United States , . .. sounded the death knell for Boyd . Several of Boyd 's express or implicit declarations [had] not stood the test of time, . . . and its privac

ction with prosecution by one sovereign do not carry over to prosecution by another sovereign. In Cobb , the Supreme Court clarified its holding in McNeil. Wisconsin , 501 U.S. 171 (1991) that the "Sixth Amendment right to counsel is offense specific. It cannot be invoked once for all future prosecutio

(1991) that the "Sixth Amendment right to counsel is offense specific. It cannot be invoked once for all future prosecutions." Id. at 167 (quoting McNeil at 175). The Cobb Court noted that some other courts: have read into McNeil 's offense-specific definition an exception for crimes that are `factual

until, at the earliest, a suspect's initial appearance before a judicial officer. U.S. Const. Amend. 6. *1246 On Petition for Writ of Mandamus to the United States District Court for the Southern District of Florida, D.C. Docket No. 9:08-cv-80736-KAM Attorneys and Law Firms Paul Cassell, University of Utah Co

words of the statute as they are commonly and ordinarily understood and must construe the statute so each of its provisions is given full effect." P United States it McLymont, 45 F.3d 400, 401 (I I th Cir. 1995). Therefore, "[w]e do not look at one word or term in isolation, but instead we look to the entire

nt Venture, 245 F.3d 1217, 1222 (11th Cir. 2001). We are bound to "presume that Congress said what it meant and meant what it said." Id. (quoting P. United States it Steele, 147 F.3d 1316, 1318 (11th Cir. 1998) (en bane)); see alsol° Keene Corp., 508 U.S. at 208, 113 S.Ct. 2035. Therefore, under the plain la

the Majority, Judge Tjoflat's concurring opinion, and I agree that the Executive has exclusive and complete authority over charging decisions. See? li United States v. Nixon, 418 U.S. 683, 693, 94 S.Ct. 3090, 41 L.Ed.2d 1039 (1974) ("[T]he Executive Branch has exclusive authority and absolute discretion to deci

540 F.3d 1253, 1262 (11th Cir. 2008) (en bane). That right attaches, for the purposes of the Sixth Amendment, when "a prosecution is commenced."? a McNeil v. Wisconsin, 501 U.S. 171, 175, III S. Ct. 2204, 2207, 115 L.Ed.2d 158 (1991). In other words, a criminal defendant is entitled to counsel "at or

nsel have had access to the subpoenaed computers since at least October 2005, when they were removed from Epstein's home, and they have known about the United States' attempts to locate those computers for at least two months, when a subpoena for the same items was served upon Paul Lavery, another private investig

n had standing to assert these challenges, the subpoenas are not unreasonable and do not violate any act of production privilege. For these reasons, the United States asks the Court to deny the Motion to Quash and to order the prompt production of the requested items and the witnesses' appearances before the Grand

(1991) that the "Sixth Amendment right to counsel is offense specific. It cannot be invoked once for all future prosecutions." Id. at 167 (quoting McNeil at 175). The Cobb Court noted that some other courts: have read into McNeil 's offense-specific definition an exception for crimes that are `factual

cording to a Pentagon IG report last week. The report's findings, which discussed "counterterrorism operations in Africa," are "likely to complicate the United States' close relationship with the Gulf state." This marks the "first public, official assessment of the arrangement" in which "the UAE may be using Russia

BioNTech." In a 2,700-word article, the New York Times <https://www.nytimes.com/2020/11/30/health/coronavirus- vaccines-treatments.html> (11/30, Al, McNeil, 18.61M) says that while "good news about vaccines or antibody treatments surfaces" every week, "offering hope that an end to the pandemic is at han

had repeatedly spoken of having all American soldiers out of the country by the end of the year. That prospect may become even more likely now that the United States' continuing presence in EFTA00148644 Afghanistan has badly stung a president who lost patience with the American mission there long ago." WPost A

ulation data suggests the country's death toll could exceed 50,000. In an analysis considering the coronavirus death toll, the New York Times (7/4, McNeil, 18.61M) highlights that after the WHO last week "held a two-day online meeting of 1,300 scientists from around the world, the agency's chief scien

ording to a Pentagon IG report last week. The report's findings, which discussed "counterterrorism operations in Africa," are "likely to complicate the United States' close relationship with the Gulf state." This marks the "first public, official assessment of the arrangement" in which "the UAE may be using Russia

hose of another candidate that is about a week ahead from Pfizer and German firm BioNTech." In a 2,700-word article, the New York Times (11/30, Al, McNeil, 18.61M) says that while "good news about vaccines or antibody treatments surfaces" every week, "offering hope that an end to the pandemic is at ha

xcept that this information is not required for U.S. citizens, lawful permanent residents (LPR), or persons who are in transit to a location outside the United States; • Passenger Name Record (PNR) locator, if available; • International Air Transport Association (IATA) code of foreign port/place where transportat

From: "McNeil. John (CRM)" <John.McNeil[email protected]> To: a' USANIalr) II Cc: "Cole, Taylor (CRM)" [email protected]> Subject: Maxwell 182-73090 Date: Tue, 0

t groups across =he Middle East. President Barack Obama's approach consisted of trusting unchecked CIA drone strikes and NSA eavesdropping to secure the United States. Republicans used the region's instability as a cudgel to beat the president with. Here are three of 2013's most troubling development= in the Middl

rly white woman sitting at the counter got up and left. As she passed the four students, sh= put her right hand on McCain's shoulder and her left on McNeil's. McCain would recall a half-century later. "But then she said, 'Boys, I am so proud of you. I only wish you'd done this 10 years ago.' " The fou

Distinguished Life Fellow, 2007-present Consultant, Task Force on the Right to Treatment, 1974-1977 Committee on Misuse and Abuse of Psychiatry in the United States, 1979-1980 Committee on Abuse and Misuse of Psychiatry and Psychiatrists in the United States, 1980-1987 (Chairman, 1984-1986) Advisory Committee

at trial, 11/90 and 12/90 U.S. v. Walter Leroy Moody (Birmingham, Alabama; Atlanta, Georgia; and Savannah, Georgia) Testified at trial, 12/13/90 McNeil v. P.F.I. (New York, New York) Testified at deposition, 1/15/91 U.S. v. Keith Gordon Ham, et al. (Wheeling, West Virginia) Testified at trial, 3/1