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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
le plea negotiations is dramatically changed upon the return of an indictment. Once an indictment is returned, the Office does not intend to file a Superseding Information containing a lesser charge or to dismiss the case in favor of state prosecution. EFTA00179083 LILLY ANN SANCHEZ, ESQ. AUGUST 3, 2007 PAGE 2 Pl
izes travel for the purpose of knowingly engaging in unlawful sexual activity with minors. United States Hayward, 359 F.3d 631, 638 (3d Cir. 2004); United Stales v Tykarsky, 446 F.3d 458, 471 (3d Cir. 2006). This is the highest level of culpability in the four tier hierarchy of culpability that the Model Pen
ternational travel, left untouched the,standard for domestic travel, and thus underscores the strict standard needed for a prosecution in this area. See United States I Clark, 435 F.3d 1100, 1104- 05 (9°' Cir. 2006). 08-80736-CV-MARRA RFP WPB 000735 EFTA00184609 Case 9:08-cv-80736-KAM Document 361-43 Entered o
thern District of Florida February 1, 2007 Page 22 Clause imposes real limitations on Congress's power to criminalize essentially local behavior. See United States' Morrison, 529 U.S. 598 (2000) (Violence Against Women Act exceeded Congressional power under the Commerce Clause or § 5 of the Fourteenth Amendment)
Whoever, using the mail or any facility or means of interstate or foreign commerce, or within the special maritime and territorial jurisdiction of the United States knowingly persuades, induces, entices or coerces any individual who has not attained the age of 18 years, to engage in prostitution or any sexual
le plea negotiations is dramatically changed up6n the return of an indictmeht. Once an indictment is returned, the Office does not intend to file a Superseding Information containing a lesser charge or to dismiss the case in favor of state prosecution. 08-80736-CV-MARRA RFP WPB 001479 EFTA00184665 Case 9:08-cv-807
10T1 GEN I l OFFICE OF TH£ SOLICITOR GENERAL OFFICE SOLICI GEN OFFICE OF JUSTICE PROGRAMS OFfl, JUSTJ, PROGi EXEWTIVE O"ICE FOil THE UNITED STATB EXEWTI1 O"ICEF UNITED OFFICE OF DISPUTE RESOLUTION OFH DISPI RESOLI ASSOCIATE ATTORNEY GENERAL COMMUNITY OIIIENTED CIVIL RIGKTS -- DMS
RAL -- CRIMINAL IIUUAUOI' IN\lfSTlGATlON DIVISION DRUG BUREAU OF tNFCRClMENT -- AOMlfflSTRATION PRISONS EXEQITlVE UNITfD STATB Ol'RCEFOR -- UNITED STATl'S MARSHALS SERVICE ATTOIINEYS UNITED U.S.NATIONAL STATES -- CENTIIAL BUREAU ATTORNEYS INT1'RPOI. IUIIIAU OF OfFKEOl' THE Al.<Oo<OI., -- FED
fice for the Northern District of Georgia. 7 United States Attorney First Assistant United States Attorney Criminal Chief Managing Assistant United Stales Attorney West Palm Beach Office Assistant United States Attorney - - - -- May 23, 2006 i"' USAO opens federal • '-)~i:t~·tt:ier~~: F1IIiia U
e plea negotiations is drnmatically changed upon the return of an indictment. Once an indictment is returned, the Office does ttot intend to file a Superseding Information containing a lesser charge or to dismiss the case in favor of state prosecution. 58 Menchel told OPR that in his view, the two-year sentence esta
at issue here is traditional ly a4 state concern because the activity is entirely local, and that the typical prosecution under federal policy that a United States Attomey’s Office should not pursue a prosecution. We do not think Simply, the commercial sexual exploitation of children is a federal concern, even
court. ; DATE: (BY) DEAUTY CLERK apenas, SCE This subpoena is issued upon application Name, Address and Phone Number of Assistant U.S. “Attomey of the United Statcs.of America Ann Marie C. Villafata, Assistant U.S. Attomey Ya P\f yy. fy 500 So. Australian Avenue, Suite 400 West Palm Beach, FL 33401-6235 Tel: (S61) 820-8711
ible plea negotiations is dramatically changed upon the return of an indictment. Once an indictment is returned, the Office does not intend to file a Superseding Information containing a lesser charge or to dismiss the case in favor of state prosecution. Please let us know your client’s decision by no later than August 1
Entities connected to both United States and Superseding Information

Jeffrey Epstein
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George W. Bush
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Department of Justice
ORGANIZATIONthe Southern District
LOCATIONLeon Black
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Prince Andrew
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Alan Dershowitz
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Alexander Acosta
PERSONJane Doe
PERSONFBI
ORGANIZATION
Kenneth Marra
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Marc Rich
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Bill Clinton
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Scarlett Johansson
PERSONJack Goldberger
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Julie K. Brown
PERSONSouthern District
LOCATION
New York City
LOCATIONMartin Weinberg
PERSON
Jay Lefkowitz
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