Epstein Secrets

such targeting occurred. EFTA00176487 la OFFICES OF GERALD B. ISEICOURT, P.G. Jeffrey Sloman, Esq. Matthew Menchel, Esq. Andrew Lourie, Esq. A. Marie Villafafia, Esq. Office of the United States Attorney Southern District of Florida June 25, 2007 Page 3 unlikely to be sanctioned by the courts.' To stretc

tthew Menchel, Esq. Andrew Louie, Esq. A. Marie Villafana, Esq. Office of the United States Attorney Sout

q. Matthew Menchel, Esq. Andrew Louie, Esq. A. Marie Villafana, Esq. Office of the United States Attorney Sout

d 84, 87-88 (D.Me. 2003)(warrant to search computers which contained no limitations on the search was unconstitutionally overbroad); United States. Hunter, 13 F.Supp.2d 574, 584 (D.Vt. 1998)(section of warrant which authorized seizure of all computers, all computer storage devices, and all computer so

ANDER ACOSTA UNITED STATES ATTORNEY By: A. MA VILLAFANA on ea Bar o. 500 South Austra ian Avenue, Suite

tates respectfully requests that the aforementioned documents be sealed. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: A. MA VILLAFANA on ea Bar o. 500 South Austra ian Avenue, Suite 400 West Palm Beach. FL 33401 Telephone; Facsimile: U CERTIFICATE OF SERVICE I HEREBY CERTIFY

poena, 204 F.3d 516 (4th Cir. 2000), see Response at 21-22, was simply a claim of privilege with respect to the client's identity. United States v. Hunter, 1995 WI, 12513 (N.D.111. January 6, 1995), does not, as the government would have it. "contain[] facts similar to the ones, at bar." Response at 21

United States Attorney's Office Southern District of Florida 99 NE 4th Street Miami, Florida 33132 Andrew Lourie, Deputy Chief, Northern Region A. Marie Villafatla, Assistant United States Attorney The United States Attorney's Office Southern District of Florida 500 South Australian Avenue, Suite 400 West Pa

rida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey E. Epstein Dear Messrs. Sloman, Menchel and Lourie and Ms. Villafana: LLLLL .R3Nt .2o2I 7370400 FACSIMILE 221/066102 As you are aware, we represent Jeffrey E. Epstein in connection with your ongoing investigation

46111.2d 84, 87-88 (D.Me. 2003Xwarrant to search computers which contained tations on the search was unconstitutionally overbroad); United States Hunter, 13 .2d 574, 584 (D.Vt. I998Xsection of warrant which authorized seizure of all computers, all computer storage devices, and all computer software

I HEREBY CERTIFY that on July 17, 2007, a true and correct copy of the forging motion was furnished by facsimile (561) 802-1787, and U.S. mail to: Maria Villifana, Esq., U.S. Attorney's Office, 500 uth Australian Avenue, Suite 400, West Palm Beach, FL 33401. By: ROY BLACK, ESQ: Counsel for Jeffrey Epstein

ference must have specified -the purpose for which the computers were seized and delineated the limits of their subsequent search". United States v. Hunter, 13 F.Supp.2d 574, 584 (D.Vt. 1998) Given these principles, the Requests contained in ¶'s 1 and 2 of the subpoenas are clearly unreasonable, since

Jury Matter. Pursuant to the Order regarding the disclosure of Grand Jury Information, a copy was not served upon the proposed intervenors. O, -O— Marie Villafatta Assistant United States Attorney SERVICE LIST Jane Does I and 2 v. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Cou

denied, No. 11-85, S. Ct. 2011 WL 3055311 (Nov. 28, 2011) (quoting Mertens v. Hewitt Associates, 508 U.S. 248, 254 (1993)); see United States v. Hunter, 548 F.3d 1308, 1315 (10th Cir. 2008) (declining to "to read additional remedies" into the CVRA beyond those expressly contained in the Act); see al

f Grand Jury Matter. Pursuant to the Order regarding the disclosure of Grand Jury Information, a copy was not served upon the proposed intervenors. Marie Villafafta Assistant United States Attorney SERVICE LIST Jane Does I and 2 v. United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Cou

denied, No. 11-85, S. Ct. 2011 WL 3055311 (Nov. 28, 2011) (quoting Mertens v. Hewitt Associates, 508 U.S. 248, 254 (1993)); see United States v. Hunter, 548 F.3d 1308, 1315 (10th Cir. 2008) (declining to "to read additional remedies" into the CVRA beyond those expressly contained in the Act); see al