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

Office 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Telephone: Facsimile: Attorney for United States -6- William L. Richey, Esq. 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

the grand jury on September 18, 2007. However, '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. Accordin 1 , the United States has not previously had the opportunity to respond to the issue raised b

DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE GRAND JURY SUBPOENAS DUCES TECUM NUMBERS 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

DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE: GRAND JURY SUBPOENAS MOTION FOR LEAVE TO FILE SUPPLEMENTAL EX PARTE DECLARATION IN SUPPORT OF UNITED STATES' RESPONSE TO MOTION TO OUASH UNDER SEAL EFTA01728796 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE: GRAND JURY SUBPOENAS UNDE

Office 500 S. Australian Ave, Suite 400 West Palm Beach. FL 33401 Telephone: Facsimile: Attorney for United States -6- William L. Riche , Esq. William L. Richey P.A. 201 S. Biscayne Boulevard, 34th Floor Miami, Florida 33131 Telephone: Facsimile: Attorney for Sub oenaed Parties Service via U. . Mail Black,

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

rney U.S. Attorney's Office West Palm Beach, FL 33401 Telephone: Facsimile: Attorney 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 Blac

CT OF FLORIDA FGJ 07-103(WPB) IN RE: GRAND JURY PROCEEDINGS SEALED MOTION The United States of America, by and through the undersigned Assistant United States Attorney, hereby moves the Court for permission to disclose the Court's Sealed Order of April 16, 2007 and a grand jury subpoena related to that sea

y Epstein. 6. The United States respectfully requests permission to disclose redacted versions of the subpoena and Order. in the pub this Motion, the United States' Surreply to the Replies of William Riley and Intervenor Jeffrey Epstein on Motion to Quash Grand Jury Subpoenas, and Supplement to Ex Parte Declara

nd Jury Subpoenas No. OLY-63 and OLY-64 United States District Court, Southern District of Florida William L. Richey, Esq. Assistant U.S. Attorne William L. Richey P.A. U.S. Attorney's Office 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Telephone: Facsimile: Attorney for United States 4 Telephon

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 EFTA0022297

grand jury on September 18, 2007. '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

Attorne U.S. Attorney=s Office 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Telephone: Facsimile: Attorney for United States 5 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

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. 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 Subpoenaed Parties Riley Kiraly and William Riley

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

of Florida U.S. Attorney's Office 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 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, Komspa

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

strict of Florida ssistant U.S. Attome U.S. Attorney's Office 500 S. Australian Ave, Suite 400 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

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

fice 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 Parties Riley Kiraly and William Ri