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

Accordingly, it is a well-recognized principle that courts should not intervene in the grand jury process absent compelling reason. United States v. Dionisio, 410 U.S. 1, 16-18 (1973). A district court also should be mindful of a target's attempts to "saddle a grand jury with mini-trials and preliminary

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

ccordingly, it is a well-recognized principle that courts should not intervene in the grand jury process absent compelling reason. United States v. Dionisio , 410 U.S. 1, 16-18 (1973). A district court also should be mindful of a target's attempts to "saddle a grand jury with mini-trials and preliminary

y had been in his home and/or belonged to him, which would, in turn, at a minimum, implicitly authenticate the contents of the materials. See, e.g., United States v. Stewart, 2003 WL 23024461 at *3 (S.D.N.Y. December 29, 2003) (act of production privileged where government's claimed relevance for requiring the

n in effect until you arc granted leave to depart by the court or by an officer acting • ni behalf of the court. poem) is issued upon application 'Med States of America DATE: March 2, 2007 Name, Address and Phone Number of Assistant U.S. Attorney ssistant U.S. Attorney 500 So. Australian Avenue, Suite 400 West

R. Crim. P. Rule 17(c). See, e.g., R. Enterprises, 498 U.S. at 299 (Rule 17(c) requires that grand jury subpoenas be reasonable); United States v. Dionisio, 410 U.S. 1, 11 (1973) ("[t]he Fourth Amendment provides protection against a grand jury subpoena duces tecum too sweeping in its terms to be regar

e on the Judiciary, US. House of Representatives, For an Qrder Authorizilig the Release of Certain Grand Jury Materials, Committee oh the Judiciary, United States House of Representatives v. US. Department of Justice, No. 19-5288 (D.C. Cir. March 20, 2020) (ordering the Trump administration to provide the Hous

cation of grand jury interests is hot ‘some talisman that dissolves all constitutional protections."'Butterworth, 494 U.S. at 630—31 (quoting U.S, v. Dionisio, 410 U.S. 1, 11 (1973)); see also Landmark Communications, Inc. v. Virginia, 435 U.S, 829, 838 (1978) (balancing state’s interest in preserving confi

in United States v. Gebbie, 294 F.3d 540, 544-52 (3d Cir. 2002), holding that "when a United States Attorney negotiates and contracts on behalf of `the United States' or 'the Government' in a plea agreement for specific crimes, that attorney speaks for and binds all of his or her fellow United States Attorneys wi

nited States v. Cambindo Valencia, 609 F.2d 603 (2d Cir. 1979) 13, 14 United States v. Carter, 454 F.2d 426 (4th Cir. 1972) 10 United States v. Dionisio, 503 F.3d 78 (2d Cir. 2007) 12 United States v. Gebbie, 294 F.3d 540 (3d Cir. 2002) 6, 7, 10 United States v. Gonzalez, 93 F. App'x 268 (2d Ci

y had been in his home and/or belonged to him, which would, in turn, at a minimum, implicitly authenticate the contents of the materials. See, e.g., United States v. Stewart, 2003 WL 23024461 at *3 (S.D.N.Y. December 29, 2003) (act of production privileged where government's claimed relevance for requiring the

R. Crim. P. Rule 17(c). See, e.g., R. Enterprises, 498 U.S. at 299 (Rule 17(c) requires that grand jury subpoenas be reasonable); United States v. Dionisio, 410 U.S. 1, 11 (1973) ("[tjhe Fourth Amendment provides protection against a grand jury subpoena duces tecum too sweeping in its terms to be regar