EFTA00178967

,I/17/2007 3:)s Ill 
FP.Oli: William L. Richey, F William L. Richey, P.A. TO: 1- 
PAGE: 001 OF 00-
FGJ 07.103 (WPB) 
William Riley and Riley Kiraly ("Riley"). by and through undersigned counsel, hereby 
move to seal the following filings: (I) this Motion; (2) the order granting this Motion; (3) the 
Motion of William Riley and Riley Kiraly for an Extension of Time Num• Pro Tune to File Their 
Reply; (4) the Order Granting the Motion of William Riley and Riley Kiraly for an Extension of 
Time Nunc• Pro nine to File Their Reply (provided that the Court enters that Order); and (5) the 
Reply of William Riley and Riley Kiraly to the Goverrunent's Response to the Motion to 
Intervene and to Quash Grand Jury Subpoenas and Cross Motion to Compel. In support thereof. 
Riley states as follows: 
The above-listed documents contain information relating to an ongoing wand jury 
investigation: thus, pursuant to Fed. R. Crim. P. 6(c)(6), all records and orders related to the 
grand jury proceedings must be kept under seal to the extent and as long as necessary• to prevent 
the unauthorized disclosure of a matter occurring before the grand jury. 
WHEREFORE. William Riley and Riley Kiraly respectfully request that the 
aforementioned documents be sealed until further Order of this Court. 
Respectfully submitted, 
WILLIAM L. RICFIEY, P.A. 
201 South Biscayne Boulevard 
34". Floor, Miami Center 
Miami, Florida 33131 
Tel: 
Fax: 
William L. RI. 
Fla. Bar No. 
William L Richey, P.A. 
201 South Biscayne Boulevard. 34th Floor, Miami Center, Miami, Florida 331314325 •- 
Facbimile 
EFTA00179167

.4/17/::007 
CA(M: William L. RIchry, F W1111.3. L. Richey, F.A. TO: 
PAGE: 00!. CT 007 
FG.107-103 (WPB) 
CERTIFICATE OF SERVICE 
I hereby certify that on August 17. 2007, the foregoing document will be served via 
facsimile and U.S. Mail on counsel, as listed on the attached service list. This document was not 
tiled using CM/ECF because it is being filed under seal. 
liam L. Richey-1-
‘--->
-3-
William L Richey, P.A. 
201 South Biscayne Boulevard, 34th Floor, Miami Center, Miami, Florida 33131-1325 
- Facsimile 
EFTA00179168

a/17/2007 3:3a PH FROM: William L. Richey, P William L. Richey, P.A. TO: I 
PAGE: 996 OF 007 
FGJ 07-103 (WPB) 
Service List 
In re: Grand Jury Subpoenas 
FGJ 07-103 (WPB) 
United States District Court, Southern District of Florida 
Assistant US Attorney 
500 South Australian Avenue, Suite 400 
West Palm Beach F orida 33401 
Fax: 
Roy Black, Esquire 
Black Srebnick Komspan & Stumpf 
201 South Biscayne Boulevard. Suite 1300 
Miami. Florida 33131 
Fax: 
Wlllam 1. Richey. P.A. 
201 South Biscayne Boulevard, 34th Floor, Miami Center, Miami, Florida 33131-4325 • 
• Facsimile 
EFTA00179169

x/17/:;007 5:7F PH PAW: Vallun L. Richey, P WilliAA L. Richey, P.A. TO: 1 
PAGE: OT: OF 04-
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
FGJ 07-103 (WPB) 
IN RE GRAND JURY SUBPOENAS 
I)UCES TECUM NUMBERS 
FILED UNDER SEAL 
OLY-63 & OLY-64 
ORDER GRANTING MOTION OF WILLIAM RILEY AND RILEY KIRALY 
TO FILE DOCUMENTS UNDER SEAL 
THIS CAUSE came before the Court on the Motion of William Riley and Riley Kiraly to File 
Documents Under Seal. 
Upon review of the Motion. it is hereby ORDERED AND ADJUDGED that good cause has been 
shown and the Motion is GRANTED. The following documents SHALL BE FILED UNDER SEAL 
until further Order of the Court: 
I. 
Motion of William Riley and Riley Kiraly to File Documents Under Seal: 
2. 
This Order: 
3. 
The Motion of William Riley and Riley Kiraly for an Extension of Time Nunc Pro Tune 
to File Their Reply; 
4. 
The Order Granting the Motion of William Riley and Riley Kiraly for an Extension of 
Timc Nunc Pro Tune to File Their Reply (if subsequently entered): and 
5. 
The Reply of William Riley and Riley Kiraly to the Government's Response to the 
Motion to Intervene and to Quash Grand Jury Subpoenas and Cross Motion to Compel. 
DONE AND ORDERED in chambers this 
day of 
, 2007: at West 
Palm Beach, Florida. 
KENNETH A. MARRA 
UNITED STATES DISTRICT JUDGE 
cc: 
William L. Riches, Esutti c 
Roy Black. Esquire 
EFTA00179170

(Rev. 06/2005)5^Iled Document Tracking Form 
Case Number: 
In to 'Vane, Jury Plaintiff 
bpot ruts Du (Cs 
feat 
Vv) 
0 L.) - Go% and 
OW- 64 
UNITED STATES DISTRICT COURT 
Southern District of Florida 
F6) T 0 q 
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SEALED DOCUMENT TRACKING FORM 
Party Filing Matter Under Seal 
Name:  
R,09 (3 LA CV , e seR • 
Address:  101 S.$isco,ti he, sun) 4*- '200 M t avvit 33/3
Telephone:  50c - 3 4.! - C042.1 
On behalf of (select one): 
hevitnit„.nOY-O Plaintiff 
42—Defetulent. 
Jef-f rec.' e psi° rl 
Date sealed document filed:  
g -• ILE — 0 '4 
If sealed pursuant to statute, cite statute:  
If sealed pursuant to previously entered protective order, date of order and docket entry number:  
The matter should remain sealed until: 
O Conclusion of Trial 
O Arrest of First Defendant 
O Case Closing 
O Conclusion of Direct Appeal 
arOther:  Y,t)1nC(USIO In DE petn eld JUrtj p vocted yui 
r -f no inotithenai 
fir'Permanently. Specify the authorizing law, rule, court order 
is affunettoli pleachols-lortmem4 gem led ixierrctocn-l-ti please 
The moving party requests that when the sealing period expires, the filed matter should be (select one): 
O Unsealed and placed in the public portion of the court file 
O Destroyed 
O Returned to the party or counsel for the party, as identified above 
'FOY' lAni BIZ 
for:Skate , Salon 
VSYMpail 
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StiA m pa( , PA. 
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EFTA00179171

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
IN RE GRAND JURY SUBPOENAS 
) 
DUCES TECUM NUMBERS 
) 
CASE No. FGJ 07-103(WPB) 
OLY-63 and OLY-64 
) 
 
) 
UNDER SEAL 
EFTA00179172

UNDER SEAL 
NOTICE OF UNAVAILABILITY OF COUNSEL FOR INTERVENOR 
Jeffrey Epstein has moved to intervene in this matter and to quash grand jury 
subpoenas to investigator William Riley and his firm, Riley Kiraly. Mr. Epstein is 
represented by undersigned counsel Roy Black. 
The issues raised by the motions to intervene and to quash have been briefed 
and the parties await a hearing date from the Court. Undersigned counsel would like 
to inform the Court that he is out of the jurisdiction on a family vacation until 
September 1, 2007. We respectfully request that any hearing the Court may 
scheduled in this matter be scheduled after September 1, 2007, at the Court's 
discretion. Undersigned counsel spoke with the prosecutor, who indicated that the 
government objects. 
Respectfully Submitted, 
BLACK, SREBNICK, KORNSPAN & STUMPF, PA. 
201 South Biscayne Boulevard 
Suite 1300 
Miami, Florida 33131 
Ph: 
— Fax: 
E-Mail: 
By: 
.Fve_
R 
BLACK, 
Florida Bar No. 
Counsel for Jeffrey Epstein 
2 
Black. Srebnick, Kornspan 
2015. Biscayne Boulevard, Suite 1300 • Miami, Florida 33131. Phone: 
• Fax 
• ,Auw.RoyBlaciccom 
EFTA00179173

CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on  fruti • lg. zoo*  a true and correct copy of the 
forging motion was furnished by email and by U.S. mail to: 
United States Attorney's Office, 500 South 
Australian Avenue, Suite 400, West Palm Beach, FL 33401. 
This pleading was not filed using the CM/ECF system because it pertains to a 
grand jury investigation and therefore it has been filed under seal. 
By: 
 
)S1401146, Foie. 
ROY BLACK, ESQ. 
Counsel for Jeffrey Epstein 
3 
Black. Srebnick, Kornspan 8
 O1
201 S. Biscayne Boulevard. Suite 1300 • Miami. Florida 33131. Phone: 
• Fax: 
• www.RoyBlack.com 
EFTA00179174

(Rev. 06/2005)Sealed Document Tracking Form 
UNITED STATES DISTRICT COURT 
Southern District of Florida 
Case Number: 
FGJ07-103 (WPB) OLY-63 & OLY-64 
IN RE GRAND JURY 
SUBPOENA DUCES TECUM 
ISSUED TO WILLIAM RILEY 
v. 
Plaintiff 
Defendant 
Party Filing Matter Under Seal 
On behalf of (select one): 
SEALED DOCUMENT TRACKING FORM 
Name: JEFFREY EPSTEIN, INTERVENOR 
Address:  ROY BLACK, 201 S BISCAYNE BLVD, STE 1300, MIAMI, FL 33131 
Telephone: 
Date sealed document filed: 
9/12/2007 
K Plaintiff 
K Defendant 
If sealed pursuant to statute, cite statute: GRAND JURY PROCEEDING 
If scaled pursuant to previously entered protective order, date of order and docket entry number: 
The matter should remain scaled until: 
K Conclusion of Trial 
K Arrest of First Defendant 
K Case Closing 
K Conclusion of Direct Appeal 
0 
Other: 
GRAND JURY MATTER IS CONCLUDED 
K Permanently. Specify the authorizing law, rule, court order: 
The moving party requests that when the sealing period expires, the filed matter should be (select one): 
K Unsealed and placed in the public portion of the court file 
K Destroyed 
K Returned to the party or counsel for the party, as identified above 
EFTA00179175

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
FILED UNDER SEAL 
IN RE GRAND JURY SUBPOENA 
DUCES TECUM ISSUED TO 
WILLIAM RILEY 
FGJ 07-103 (WPB) 
OLY-63 & OLY-64 
M.B.D. No. 
SURREPLY OF JEFFREY EPSTEIN TO UNITED STATES' SURREPLY TO REPLIES 
FILED BY WITNESS WILLIAM RILEY AND INTERVENOR JEFFREY EPSTEIN 
RE: MOTION TO QUASH GRAND JURY SUBPOENAS 
I. 
In its Surreply, the government, for the first time, after the parties have filed numerous 
pleadings directed to the enforceability of the challenged subpoena, announced that it was in fact 
seeking only physical possession of the computers at issue and that it thereafter intended to 
obtain a search warrant to search the contents of the computers. This Court should not permit the 
government to substitute a secret ex parte process for the adversarial litigation process between 
the parties which has been ongoing. Instead of leaving the government free to rummage at will 
through the contents of the computers based upon the ex parte issuance of a search warrant, the 
Court should require the government to particularize the subpoena to identify the documents 
which it is seeking. The government's doing so would enable movants to provide it with the 
documents falling within the particularized categories so identified, in the same manner as one 
responding to a particularized document subpoena would do. The process should be no different 
because the documents are contained within a computer than it is with respect to hard copy 
documents in the hands of the subpoenaed party. 
Black. Srebnick, Komspan & Stum 
201 S. Biscayne Boulevard. Suite 1300 • Miami. Florida 33131- Phone: 
• Fax: 
• www.RoyBlack.com 
EFTA00179176

Contrary to the suggestion of the government, see United States' Surreply at 2, the 
overbreadth and particularity protections embodied in the Fourth Amendment reasonableness 
command with respect to subpoenas do not recognize an exception which permits the 
government to utilize an unlimited, overbroad, and unparticularized grand jury subpoena to 
obtain custody of a container which it wishes thereafter to search pursuant to a warrant. The 
particularity and overbreadth arguments which have been advanced by Epstein cannot be mooted 
by the government's now contending that the purpose of the subpoena is only the seizure of the 
computers and not their search. The commands of the Fourth Amendment and Rule 17 remain 
the same: the subpoenaed items must be relevant to the grand jury's investigation, and the items 
sought must be particularized in the subpoena. Just as the government could not simply serve a 
subpoena on a business directing that it produce all its file cabinets to the grand jury, neither can 
it use a grand jury subpoena to compel a citizen to turn over the entire contents of his computers 
to the grand jury. As has been stressed in prior pleadings directed to this issue, computers contain 
vast realms of personal documents, information, and data which are simply none of the 
government's business and should not be exposed to its inspection absent a particularized 
description of the categories of documents and other information which the government believes 
relevant to the grand jury's investigation.' 
The court in In re Grand Jury Subpoena Duces Tecum Dated November 15, 1993, 846 
F.Supp. 11 (S.D.N.Y. 1994), was confronted with a similar issue in the context of a grand jury 
subpoena for the production of all hard drives of computers supplied by X Corporation to certain 
officers and employees, as well as all computer-accessible data, including all floppy disks, 
created by the specified officers or employees or their assistants. The Court, drawing upon the 
See Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Incorporated Memorandum of 
Law at 19-26. 
2 
Black. Srebnick. Komspan & Stum 
201 S. Biscayne Boulevard. Suite 1300 • Miami. Florida 33131. Phone: 
• Fax: 
• www.RoyBlack.com 
EFTA00179177

Second Circuit's narrowing of a subpoena demanding the production of the entire contents of 
three file cabinets to exclude categories of documents with no conceivable relevance to any 
legitimate object of investigation in In re Horowitz, 482 F.2d 72, 79-80 (2d Cir. 1973),2
concluded that the subpoena should be interpreted as seeking categories of documents, not 
categories of computers, and that it was the former category — the documents sought by the 
government — which was required to be particularly described. 846 F.Supp. at 13. The Court 
held that, because there were ways in which the government could have narrowed the subpoena 
to relevant documents, such as documents containing certain key words, the subpoena at issue 
unnecessarily demanded documents irrelevant to the grand jury inquiry and was, therefore, 
unreasonably broad under Rule 17. Because the government opposed modification of the 
subpoena, the Court quashed the subpoena in its entirety, without prejudice to the grand jury's 
ability to issue a properly narrowed subpoena. Id. at 13-14. See also In re Amato, 2005 WL 
1429743 at *11-1'12 (D.Me. June 17, 2005)(granting motion to quash with respect to paragraph 
of subpoena requesting production of all computers and computer related equipment: "Inasmuch 
as Category 10 . . . in essence requests the turnover of all computers (and related objects) of both 
corporations with no express safeguard against a subsequent rummaging through, and seizure of, 
2 In Horowitz, the government initially served a grand jury subpoena on the target's accountant, requiring the 
production of seven categories of documents. Learning from the accountant's grand jury testimony that the target 
had had three file cabinets of documents removed from his corporate offices and stored at another location, the 
government issued another grand jury subpoena to the accountant requiring the production of the three file cabinets. 
The accountant turned the file cabinets over to the United States Attorney's office subject to the agreement that the 
cabinets would remain unopened until the litigation of a motion to quash. The accountant inventoried the contents of 
the file cabinets and then moved to quash the subpoena, as later did the targets. Id. at 74-75. On appeal, the Second 
Circuit noted that the alleged fraud began in 1966, but the file cabinets contained documents dating back to 1951, 
and therefore limited the enforcement of the subpoena to documents beginning in 1966, with the proviso that earlier-
dated documents would be producible if the government made a showing of relevance. The Court also left it open to 
the targets to demonstrate that a particular category of documents could have no conceivable relevance to any 
legitimate investigative object. Id. at 79-80. 
3 
Black. Srebnick, Kornspan 8
 mt.1
201S. Biscayne Boulevard. Suite 1300 • Miami. Florida 33131- Phone: 
• Fax: 
• m4m.RoyBlack.com 
EFTA00179178

irrelevant as well as relevant data, it cannot withstand Fourth Amendment reasonableness 
scrutiny"). 
In the context of the seizure for off-site review of intermingled computerized evidence 
pursuant to a search warrant, the Ninth Circuit recently stated: 
In the case of a lawful and reasonable seizure of intermingled computer records for off-
site review, . . . our precedents and the general reasonableness mandate of the Fourth 
Amendment require the supervision of a magistrate. It is not reasonable to allow the 
government 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 the computer data through seizure pursuant to a warrant rather than through a grand 
jury subpoena, the Court did not hesitate to condemn a governmental fishing expedition through the 
acquired computer data. Here, where the process was initiated by subpoena, it is only appropriate 
and proper that the party whose privacy interests are at stake should be able to respond to a 
determinate, particularized subpoena rather than to an open-ended, limitless subpoena such as the 
one presently at issue in this case. Movants should not be required to turn over the entire computers 
to the government for its unfettered rummaging but instead only the particularized relevant 
documents called for in a properly tailored subpoena. 
Another peril of the warrant alternative would be the myriad new issues requiring resolution: at 
issue would be not simply whether there was probable cause for the search of the computers, see 
United States' Surreply at 2, but also the Fourth Amendment's particularity and overbreadth 
protections. It does not suffice that, should Epstein be indicted, he would have the opportunity to 
challenge the probable cause for the search on a motion to suppress. No motion to suppress can ever 
4 
Black. Srebnick. Kornspan 8
ro
rm 
201 S. Biscayne Boulevard. Suite 1300 • Miami. Florida 33131 • Phone: 
• Fax: 
• www.RoyBlack.com 
EFTA00179179

cure an unwarranted intrusion on personal privacy which lays bare before the government a citizen's 
private life for its unguided scrutiny and permits government agents to read private materials to 
which they never should have had access in the first place. The Court must act now to prevent such 
wholesale intrusion from taking place. 
The government's overbroad and unparticularized subpoena should be quashed. The government 
should not be permitted to substitute secret proceedings for participatory ones or review of the 
computers' contents by F.B.I. agents for the more orderly process triggered by a valid subpoena. 
H. 
The government's act-of-production privilege argument, United States' Surreply at 2-3, is 
facially inconsistent with its contention that it intends, once it has the computers in its custody, to 
seek a warrant to search their contents. Obtaining such a warrant would require the government 
to demonstrate probable cause to believe that evidence of the alleged offenses under 
investigation would be found on the computers, evidence which the government seeks for the 
purpose of using it against Mr. Epstein if it exists.3 Production of the computers would constitute 
a testimonial communication that they were in fact the computers which were removed from Mr. 
Epstein's home, a necessary step in the authentication of any contents found therein which the 
government might seek to use against Mr. Epstein. It is not the subpoenaed item itself which 
must be potentially incriminating, but the act of producing that item. See United States v. Ponds, 
454 F.3d 313 (D.C.Cir. 2006); see also Reply of Jeffrey Epstein to United States' Response to 
His Motion to Intervene and to Quash 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 
production would constitute a compelled testimonial communication as to which the subpoenaed party would have 
the right to assert a Fifth Amendment act-of-production privilege. 
Black. Srebnick, Komspan & Stumpf 
201S. Biscayne Boulevard. Suite 1300 • Miami. Florida 33131 - drone: -• 
Fax: 
• www.RoyBlack.com 
EFTA00179180

Epstein should not be required to make unprotected assertions that anything in the computers is 
incriminating as a precondition to asserting the act-of-production privilege. See Ohio v. Reiner, 532 
U.S. 17, 21 (2001)("[W]e have emphasized that one of the Fifth Amendment's basic functions . . . is 
to protect innocent men . . . who otherwise might be ensnared by ambiguous circumstances" 
(emphasis in original)); Hoffman v. United States, 341 U.S. 479, 486 (1951)("The privilege . . . not 
only extends to answers that would themselves support a conviction under a federal criminal statute 
but likewise embraces those which would furnish a link in the chain of evidence needed to prosecute 
the claimant for a federal crime"). 
As to the Riley Kiraly billing records, see United States' Surreply at 4, if the subpoena is to be 
enforced, Riley Kiraly will produce them in redacted form, with material encompassed within the 
work product privilege deleted. See Epstein Reply at 10-11. The work product privilege belongs 
jointly to Epstein, and he has rightly asserted that privilege. There can, therefore, be no question of 
waiver here. Clearly, the government wants more from the billing records than simply the numbers; 
it has issued an all-encompassing demand, leading to Mr. Epstein's contention that the request is 
overbroad. 
Lastly, the government complains that Mr. Riley did not appear to testify even though no motion 
to quash his testimony had been filed. See United States' Surreply at 1-2. Had such a motion been 
filed, the government would no doubt have argued that it should be denied as an impermissible 
blanket assertion of privilege. Mr. Riley will assert the attorney-client and/or work product privilege 
as necessary on a question-by-question basis during his grand jury appearance. 
Black. Srebnlck. Kornspan & Stum f 
201 S. Biscayne Boulevard. Suite 1300 • Miami. Florida 33131 • done:
• Fax: 
• www.RoyBlack.com 
EFTA00179181

CONCLUSION 
The government began this process as an adversarial one — one which afforded Mr. Epstein both 
notice and an opportunity to be heard. It should not now be permitted to unilaterally convert that 
process to a secret ex pane search warrant application process and to thereby completely extinguish 
Mr. Epstein's ability to protect his legitimate his privacy interests. Mr. Epstein is entitled to be 
involved in this process before - not after — his interests are irreparably injured. 
Respectfully submitted, 
BLACK, SREBNICK, KORNSPAN & STUMPF, PA. 
201 South Biscayne Boulevard, Suite 1300 
Miami, Florida 33131 
Ph.: 
-- Fax: 
E-Mail: 
By: 
ROY LACK 
Florida Bar No.: 
Counsel for Jeffrey Epstein 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on September 12, 2007, a true and correct copy of the 
forging motion was furnished by facsimile 
and U.S. mail to:=I=, 
Esq., U.S. Attorney's Office, 500 South Australian Avenue, Suite 400, West Palm Beach, FL 
33401. 
By: 
RO k LA K, SQ. 
Counsel for Je ey Epstein 
Black. Srebnick. Komspan & Shim 
201 S. Biscayne Boulevard. Suite 1300 • Miami, Florida 33131 • Phone: 
Fax 
• www.RoyBlack.com 
EFTA00179182

(Rev. 06/2005)Scakd Document Tracking F-
In Re 
Grand Jury Subpoenas Duces Tecum 
Numbers OLY-63 and OLY-64 
UNITED STATES DISTRICT COURT 
Southern District of Florida 
Number: FGJ 07.103 (WPB) 
c.' 
4/S I 
EX PARTE DECLARATION #2 IN SUPPORT OF UNITED STATES' RESPONSE TO MOTION TO QUASH 
Party Filing Matter Under Seal 
On behalf of (select one): 
SEALED DOCUMENT TRACKING FORM 
Name: lea
 u.S. Attorney's Ono 
Address: 500 S. Australian Ave. Suite 400, WestPalm Beach, FL 33401 
Telephone:' 
ID Plaintiff 
K 
Defendant 
Date sealed document filed: 7/31/2007 
If sealed pursuant to statute, cite statute: Fed. R. Grim. P. 6(e) (Grand Jury Material) 
If sealed pursuant to previously entered protective ogler, date of order and docket entry number:  
The matter should remain sealed until: 
K Conclusion of Trial 
K 
Arrest of First Defendant 
CI Case Closing 
0 
Conclusion of Direct Appeal 
K Other:  
ID Permanently. Specify the authorizing law, rule, court order: 
The moving party requests that when the sealing period expires, the filed matter should be (select one): 
0 
Unsealed and placed in the public portion of the court file 
0 
Destroyed 
0 
Returned to the party or counsel for the party, as identified above 
Attorney for: Movant Unit(Vttates of America 
EFTA00179183

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) 
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 SUBPOENAS 
DUCES TECUM NUMBERS 
OLY-63 and OLY-64 
FGJ 07-103(WPB) 
UNDER SEAL 
,EX PARTE DECLARATION NUMBER TWO 
IN SUPPORT OF UNITED STATES' RESPONSE 
TO MOTION TO OUASH SUBPOENAS 
I, Patrick Paige, state that the following is true and correct to the best of my 
information and belief: 
1. 
I am a duly appointed Deputy Sheriff for Palm Beach County, and have all the 
powers and duties of a law enforcement officer in and for Palm Beach County, Florida. I 
have been a Law Enforcement Officer since 1986, after completing training in the Law 
Enforcement Academy. From 1986 to 1989, I served with the Delray Beach Police 
Department as a Patrol Officer. From 1989 to present, I have been serving with the Palm 
Beach County Sheriff's Office. Since 2000, I have been working in the Computer Crimes 
Unit as a Detective, working as a computer forensic analyst and investigator. Most of my 
investigations involve child exploitation. I am an instructor for Guidance Software Inc., the 
creators of EnCase® computer forensic software, and am an EnCase® Certified Examiner 
(EnCE). I have instructed other law enforcement officers with the local, state and federal 
governments in the area of computer forensics as an instructor for Guidance Software. 
Page 1 of 3 
EFTA00179185

2. 
I received a phone call from David Kleiman on the morning of July 25, 2007. 
Mr. Kleiman advised me that he was hired by attorney Roy Black to make three bit-stream 
copies and one EnCase® image for each of three computers. Mr. Kleiman asked me if he 
would be able to use one of the Sheriff's Office's hard drive duplication devices. It may be 
noted that Mr. Kleiman is former law enforcement and has assisted the Sheriffs Office in 
computer related examinations and seizures in the past. Mr. Kleiman further stated that he 
was told the job needed to be done as soon as possible. Mr. Kleiman was meeting with a 
private investigator who worked with Mr. Black on July 26, 2007 in the morning at Mr. 
Kleiman's place of employment in Boca Raton. Mr. Kleiman described the investigator as 
an "old-time New York cop-type." Mr. Kleiman was told the computers had not been used 
since 2005 so he was trying to determine the size of the hard drives that were in the 
computers. Mr. Kleiman told me he was going to purchase several 120GB hard drives to do 
the job. I told Mr. Kleiman that the Logicube machine he wanted to use was not reliable. 
Mr. Kleiman made the decision to purchase a hard drive duplication device online from a 
company named Digital Intelligence and have it shipped overnight to his place of 
employment in Boca Raton. Mr. Kleiman was told someone would be standing by while the 
process was being completed. Mr. Kleiman advised the private investigator it would take at 
least 10 hours or more to complete the process. 
3. 
I have not been involved in the investigation of Jeffrey Epstein, but have 
worked on other cases with Special Agent 
Special Agent 
Page 2 of 3 
EFTA00179186