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

strict 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 Epstein Service via Hand Delivery aRi

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

torney for United States EFTA00211798 William L. Richey, Esq. William L. Richey P.A. Miami, Florida 33131 Telephone l Facsimile: Attorney for Subpoenaed Parties Riley Kiraly and William Riley Service via Federal Express Roy Black, Esq. Black Srebnick, Koms an & Stum f, P.A. Miami, FL 33131 Telephone l F

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

Richey, Esq. EFTA00222982 William L. Richey P.A. 201 S. Biscayne Boulevard, 34th Floor Miami, Florida 33131 Telephone Facsimile: Attorney for Subpoenaed Parties Riley Kiraly and William Riley Roy Black, Esq. Black, Srebnick, Komspan & Stumpf, P.A. 201 S. Biscayne Boulevard, Suite 1300 Miami, FL 33131 Tel

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

requested testimony would not incriminate either William Riley or Riley Kiraly, as evidenced by the fact that neither has moved to quash. In Couch I United States , 409 U.S. 22 (1973), the IRS issued a summons to the defendant's accountant for the defendant's receipts and other tax materials. After receiving t

Attorney for United States William L. Richey. Esq. William L. Richey P.A. 201 S. Biscayne Boulevard, 34th Floor Miami, Florida 33131 Attorney for Subpoenaed Parties Riley Kiraly and William Riley Black, Srebnick, Komspan & Stumpf, P.A. 201 S. Biscayne Boulevard, Suite 1300 Miami, FL 33131 Attorney for Interve

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

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 Black, Srebnick, Koms an & Stum f, P.A. Miami, FL 33131 Telephon Facsimile Attorney or n e

ed from Mr. Epstein's home. The grand jury probably has the authority to subpoena the contents of those computers, but, in an abundance of caution, the United States' intention is to seek a search warrant for the contents of those computers once the computers are securely in custody. This procedure will allow the

Attorney for United States William L. Riche Esq. William L. Richey P.A. 201 S. Biscayne Boulevard, 34th Floor Miami, Florida 33131 Attorney for Subpoenaed Parties Riley Kiraly and William Riley Service via U.S. Mail I Roy Black, Esq. EFTA00222978 Black, Srebnick, Komspan & Stumpf, P.A. 201 S. Biscayne Bou

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

L. Richey, Esq. .com William L. Richey P.A. 201 S. Biscayne Boulevard, 34th Floor Miami, Florida 33131 Telephone: (=1 Facsimile: Attorney for Subpoenaed Parties Riley Kiraly and William Riley Roy Black, Esq. .com Black, Srebnick, Komspan & Stumpf, P.A. 201 S. Biscayne Boulevard, Suite 1300 Miami, FL 3313