Epstein Secrets

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

t to seize an indeterminately bounded array of computer data only later to set its own standards for review and retention thereof. United States v. Comprehensive Drug Testing, Inc., 473 F.3d 915, 938 (9th Cir. 2006)(emphasis added). Thus, even in the Comprehensive Drug Testing case, in which the government gained possession of

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

ent the government from using a grand jury subpoena to conduct an unfettered general search of the contents of the computers. See United States v. Comprehensive Drug Testing, Inc., 473 F.3d 915, 938-39 (91" Cir. 2006) ("[i]t is not reasonable to allow the government to seize an indeterminately bounded array of computer data o

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

ent the government from using a grand jury subpoena to conduct an unfettered general search of the contents of the computers. See United States v. Comprehensive Drug Testing, Inc., 473 F.3d 915, 938-39 (9th Cir. 2006) ("Mt is not reasonable to allow the government to. seize an indeterminately bounded array of computer data on