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

case, be served upon it at the address set forth below. Respectfully submitted, WILLIAM L. RICHEY, P.A. 201 South Biscayne Boulevard 34th Floor, Miami Center Miami, Flori Telephon Facsim. E-Mail: ILL AM L. RICH Fla. Bar No. EFTA00179067 CERTIFICATE OF SERVICE I hereby certify that a true and corre

CT OF FLORIDA IN RE GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY-63 and OLY-64 / FGJ 07-103(WPB) EX PARTE DECLARATION NUMBER TWO IN SUPPORT OF UNITED STATES' RESPONSE TO MOTION TO OUASH SUBPOENAS FILED UNDER SEAL EFTA00179184 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE GRAND JURY

uash Grand Jury Subpoenas and Cross-Motion to Compel ("Epstein Reply") at 5-8. 3 The government's effort at reductio ad absurdum is not well-taken. See United States' Surreply at 2 n.2. If the subpoenaed party's act ofproducing his mother's coffee cake recipe were potentially incriminating, then the act of produc

ny_info.Man 7/30/2007 EFTA00179203 Company Info Page 2 of 2 around the world. Mr. Kiraly works with numerous law firms and corporations within the United States and internationally on high profile, complicated litigation matters involving fraud, internal theft, asset location, and recovery as well as a broad

documents be sealed until further Order of this Court. Respectfully submitted, WILLIAM L. RICFIEY, P.A. 201 South Biscayne Boulevard 34". Floor, Miami Center Miami, Florida 33131 Tel: Fax: William L. RI. Fla. Bar No. William L Richey, P.A. 201 South Biscayne Boulevard. 34th Floor, Miami Center, Miam

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

ly returned. Accordingly, this Reply has been prepared within days of his return. William L Richey, P.A. 301 South 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";