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

ing; instead, a witness' claims of attorney-client privilege are tested by refusing to answer specific questions. Davis , 636 F.2d at 1039. See also Nguyen I Excel Corp. , 197 F.3d 200 (5th Cir. 1999); Clarke I American Commerce Nat. Bank , 974 F.2d 127 (9th Cir. 1992); United States I White , 950 F.2d 426, 430 (7th

de whether a witness's silence is justified. United States I Koubriti , 297 F. Supp. 2d 955, 962 (E.D. Mich. 2004) (citing Hoffman , 341 U.S. at 53; United States I Melchor Moreno , 536 F.2d 1042, 1049 (5th Cir. 1976); United States I Rue , 819 F.2d 1488 (8th Cir. 1987); In re Morganroth , 718 F.2d 161, 167 (6

unsel 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

ing; instead, a witness' claims of attorney-client privilege are tested by refusing to answer specific questions. Davis , 636 F.2d at 1039. See also Nguyen I Excel Corp. , 197 F.3d 200 (5th Cir. 1999); Clarke I EFTA00222938 American Commerce Nat. Bank , 974 F.2d 127 (9th Cir. 1992); United States I White , 950 F.2d

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

, blanket assertions of the privilege are not proper—the assertion must be made on a question-by-question and document-by-document basis. See, e.g., Nguyen I Excel Corp. , 197 F.3d 200 (5th Cir. 1999); Clarke' American Commerce Nat. Bank , 974 F.2d 127 (9th Cir. 1992); United StatesI White , 950 F.2d 426, 430 (7th C