Epstein Secrets

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

Accordingly, it is a well-recognized principle that courts should not intervene in the grand jury process absent compelling reason. United States v. Dionisio, 410 U.S. 1, 16-18 (1973). A district court also should be mindful of a target's attempts to "saddle a grand jury with mini-trials and preliminary

PBPD brought the case to the FBI’s attention because of a concern that the State Attorney’s Office had succumbed to “pressure” from defense counsel. Villafana informed both Acosta and Sloman of this when she met with them at the start of the federal investigation. Acosta confirmed that he was aware that the

cation of grand jury interests is hot ‘some talisman that dissolves all constitutional protections."'Butterworth, 494 U.S. at 630—31 (quoting U.S, v. Dionisio, 410 U.S. 1, 11 (1973)); see also Landmark Communications, Inc. v. Virginia, 435 U.S, 829, 838 (1978) (balancing state’s interest in preserving confi

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

R. Crim. P. Rule 17(c). See, e.g., R. Enterprises, 498 U.S. at 299 (Rule 17(c) requires that grand jury subpoenas be reasonable); United States v. Dionisio, 410 U.S. 1, 11 (1973) ("[tjhe Fourth Amendment provides protection against a grand jury subpoena duces tecum too sweeping in its terms to be regar