Epstein Secrets

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

o. OLY-63 and OLY-64 United States District Court, Southern District of Florida Assistant U.S. Attorney Attorney for United States EFTA00223014 William L. Richey, Esq. Attorney for Subpoenaed Parties Riley Kiraly and William Riley Service via Federal Express Roy Black, Esq. Attorney for Intervenor Jeffrey

S DUCES TECUM NUMBERS FGJ 07-103 (WPB) OLY-64 AND OLY-64 / UNDER SEAL MOTION FOR LEAVE TO FILE SUPPLEMENTAL EX PARTE DECLARATION IN SUPPORT OF UNITED STATES' RESPONSE TO MOTION TO QUASH The United States of America, by and through the undersigned Assistant United States Attorney, hereby asks for permissi

on. Due to the pendency of the investigation, EFTA00222981 and the requirements of Grand Jury secrecy, the United States asks that the Court allow the United States to file a Supplemental Ex Parte declaration, which further addresses the factual issues raised by Intervenor Epstein, without being forced to disclo

.S. Attorne U.S. Attorney's Office 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Telephone: Facsimile: Attorney for United States William L. Richey, Esq. EFTA00222982 William L. Richey P.A. 201 S. Biscayne Boulevard, 34th Floor Miami, Florida 33131 Telephone Facsimile: Attorney for Subpoe

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

Biscayne Boulevard, 34th Floor, Miami Center, Miami, Florida 331314325 •---- Facsimile EFTA00178967 x/17/.:007 PH FRCII: VI: 1 ar L. Richey, P William L. Richey, P.A. TO:, ' • PAGE: 00"; of FGJ 07-103 (WPB) Therefore, contrary to the Government's claim. Riley did not flout the subpoena. Rather. Riley's n

of caution, the undersigned's general policy is to seek a search warrant for the contents of a computer once it is securely in custody, and that is the United States' intended approach in this case, as well. This procedure will allow the Court to decide whether adequate probable cause exists for the search of the

211804 U.S. Attorney 5 s Office 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Telephonel Facsimile: I Attorney for United States William L. Richey, Esq. William L. Richey P.A Miami, Fl Telephon Facsimile: Attorney for Subpoenaed Parties Riley Kiraly and William Riley Service via U.S. Mail

CUMENTS UNDER SEAL The United States of America, by and through the undersigned Assistant United States Attorney, hereby moves to seal this Motion, the United States' Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel , the United States' Motion for Permission to Fi

usdoj.gov U.S. Attorney's Office 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Telephone: Facsimile: Attorney for United States William L. Richey, Esq. .com William L. Richey P.A. 201 S. Biscayne Boulevard, 34th Floor Miami, Florida 33131 Telephone: (=1 Facsimile: Attorney for Subpoenaed

stain the government's standing objection as to 'Witness 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

7 EFTA00234920 SERVICE LIST In re Federal Grand Jury Subpoenas No. OLY-63 and OLY-64 United States District Court, Southern District of Florida William L. Richey, Esq. 8 EFTA00234921