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

the [attorney- client] privilege does not bar revelation of the original location or conduction of the evidence in question." Hunter at *3 (quoting Meredith at 54). While the investigator could not testify about the substance of any communications with the attorney, he had to tell the jury where the wall

e defendant in Hunter, the defendant argued that the anomey-client privilege precluded admission of the receipts against him at trial. Similarly, in Meredith, the defense investigator found the murder victim's wallet based on information obtained from the defendant and turned it over to defendant's attorn

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

, the [attorney-client] privilege does not bar revelation of the original location or conduction of the evidence in question." Hunter at *3 (quoting Meredith at 54). While the investigator could not testify about the substance of any communications with the attorney, he had to tell the jury where the wall

n it over to the prosecution. Therefore, introduction of the evidence did not implicate the privilege. Hunter at *2 (citing Clutchette at 1472). In Meredith , a murder suspect informed his attorney that the murder victim's wallet was in the garbage can behind the suspect's house and the attorney sent a p

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

, the [attorney-client] privilege does not bar revelation of the original location or conduction of the evidence in question." Hunter at *3 (quoting Meredith at 54). While the investigator could not testify about the substance of any communications with the attorney, he had to tell the jury where the wall

n it over to the prosecution. Therefore, introduction of the evidence did not implicate the privilege. Hunter at *2 (citing Clutchette at 1472). In Meredith , a murder suspect informed his attorney that the murder victim's wallet was in the garbage can behind the suspect's house and the attorney sent a p

at the computers contain attorney-client communications, nor were the computers or their contents produced in anticipation of litigation. In Upjohn I United States , 449 U.S. 383 (1981), the Supreme Court made clear that an attorney cannot create a "zone of silence" over factual matters. The Court wrote: the at

, the [attorney-client] privilege does not bar revelation of the original location or conduction of the evidence in question." Hunter at *3 (quoting Meredith at 54). While the investigator could not testify about the substance of any communications with the attorney, he had to tell the jury where the wall

n it over to the prosecution. Therefore, introduction of the evidence did not implicate the privilege. Hunter at *2 (citing Clutchette at 1472). In Meredith , a murder suspect informed his attorney that the murder victim's wallet was in the garbage can behind the suspect's house and the attorney sent a p

of other media outlets. CNN (7/7, Cohen, Murray, Atwood, Salama, 83.16M) says on its website, "A State Department official also confirmed that `the United States' notice of withdrawal, effective July 6, 2021, has been submitted to the UN Secretary- General, who is the depository for the WHO." BBC World News (7/

cant steps to confront Iranian-linked militias that have targeted American troops," CENTCOM Commander Gen. Frank McKenzie "said Tuesday, adding that the United States must remain patient as...Kadhimi challenges groups with formidable military and political clout." McKenzie said, "He's negotiating a land mine now.

y ignoring the advice of his own officials, going out on horseback, and hugging children in huge crowds." Along those lines, CNBC (7/7, Breuninger, Meredith, 3.62M) reports on its website that in June, "a judge ordered Bolsonaro to wear a face mask in public, something he has frequently failed to do. Ho

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erica in per-capita income. With an aging, 1.4 billion person population the challenges of distribution nearly guarantee this. Time acts against both the United States and China today. Each depends on global arrangements that are themselves cracking. Each nation needs to adjust her structures for a network world. Bu

012) 139 Even expert progammers: For a good explanation of how a machine’s code can be turned against itself, see Sergey Bratus, Michael E. Locasto, Meredith |. Patterson, Len Sassaman, and Anna Shubina, “Exploit Programming: From Buffer Overflows to ‘Weird Machines’ and Theory of Computation.” ;login Dece