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This is an FBI investigation document from the Epstein Files collection (FBI VOL00009). Text has been machine-extracted from the original PDF file. Search more documents →

FBI VOL00009

EFTA00086375

143 pages
Pages 1–20 / 143
Page 1 / 143
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
NORTHERN (WEST PALM BEACH) DIVISI 
FGJ NO. 07-103 (WPB) 
IN RE: 
GRAND JURY PROCEEDINGS 
ILED BY 
D.C. 
MAY 3 0 2017 
STEVEN P. LARJp,topE 
C. 
":IS'
SC OF ELI., • woo 
MOTION TO SEAL 
The United States of America, by and through the undersigned Assistant United States 
Attorney, hereby moves to seal its "Sealed Motion for Permission to Disclose Grand Jury Material" 
for the following reasons: 
1. 
The Application contains information regarding proceedings before West Palm 
Beach Federal Grand Jury 07-103, which is subject to the secrecy protections of Fed. R. Crim. P. 
6. 
2. 
Pursuant to Rule 6(eX6), "[r]ecords, orders, and subpoenas relating to 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 a grand jury." 
WHEREFORE, the United States respectfully requests that the Application and any Order 
related to the Application be sealed. 
Dated: May 30, 2017 
Respectfully submitted, 
BENJAMIN G. GREENBERG 
ASSISTANT U.S. ATTORNEY 
Florida Bar No. 
500 South Australian Ave, Suite 400 
West Palm Beach. Florida 33401 
Tel: 
EFTA00086375
Page 2 / 143
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
NORTHERN (WEST PALM BEACH) DIVISION 
FGJ NO. 07-103 (WPB) 
IN RE: 
GRAND JURY PROCEEDINGS 
 
/ 
SEALED ORDER 
It is hereby ordered that the United States' Sealed Motion for Permission to Disclose Grand 
Jury Material and the Order granting same be SEALED until further Order of this Court, except 
that a copy of this Order, the Motion for Permission to Disclose Grand Jury Material and the Order 
granting same shall be provided to counsel for the United States. 
DONE AND ORDERED in chambers this 
day of May, 2017, at West Palm 
Beach, Florida. 
DANIEL T. K. HURLEY 
SENIOR UNITED STATES DISTRICT JUDGE 
cc: 
AUSA 
EFTA00086376
Page 3 / 143
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
FGJ 07-103(WPB) 
IN RE: 
GRAND JURY PROCEEDINGS 
SEALED MOTION FOR PERMISSION TO DISCLOSE GRAND JURY MATERIAL 
The United States of America, by and through the undersigned Assistant United States 
Attorney, hereby moves the Court for permission to disclose certain materials relating to matters 
occurring before West Palm Beach Federal Grand Jury # 07-103. 
In support thereof, the 
Government states: 
1. 
In September 2006, as part of its investigation named "Operation Leap Year," the 
United States served a grand jury subpoena on a witness named 
See Exhibit 1 at P-
003734 thru P-003735. Based upon the investigation, Ms. 
was identified as a potential 
victim of the lead target, Jeffrey Epstein. 
2. 
After service of the subpoena, Ms.= 
retained the services of James Eisenberg, 
Esq. to represent her. Jeffrey Epstein paid for that representation. 
3. 
Mr. Eisenberg communicated to me orally and in writing that Ms. 
would 
assert her Fifth Amendment privilege if she were forced to appear before the grand jury, and that 
the government needed to obtain immunity pursuant to 18 U.S.C. §§ 6001-6003 and a compulsion 
order from the Court to avoid the assertion of the privilege. Exhibit 2. 
4. 
Due to the expiration of the original grand jury, in January 2007, a new grand jury 
subpoena was issued on behalf of West Palm Beach Federal Grand Jury #07-103. Exhibit 1 at P-
003738. 
EFTA00086377
Page 4 / 143
5. 
On January 24, 2007, the undersigned sent a letter to Mr. Eisenberg enclosing the 
subpoena and discussing the investigation and grand jury proceeding. Exhibit 1 at P-003736 thru 
P-003737. 
6. 
On February I, 2007, Mr. Eisenberg responded via letter. His letter discusses the 
grand jury subpoena, the investigation, and Ms. 
likely testimony. Exhibit 1 at P-003732 
thru P-003733. 
7. 
On February 5, 2007, I provided Mr. Eisenberg with two proposed Kastigar letters 
that, again, discuss the grand jury's investigation. Exhibit 1 at P-003739 thru P-003743, P-003745. 
8. 
In response to a complaint from Mr. Eisenberg (see Exhibit 3), I prepared an 
"Authorization for Reimbursement of Unusual Expenses of Fact Witnesses" to pay for 
Suring 
Ms. 
grand jury testimony. Exhibit 1 at P-003744. 
9. 
On February 12, 2007, Mr. Eisenberg sent a letter detailing the reasons for Ms. 
refusal to testify without a compulsion order. This letter, again, discusses the grand jury's 
investigation and matters occurring before the grand jury. Exhibit 1 at P-003730 thru P-003731. 
10. 
Based upon Mr. Eisenberg's letter and representations, the U.S. Attorney's Office 
applied to the Justice Department for authorization to grant immunity pursuant to 18 U.S.C. §§ 
6001-6003. After receiving that authorization, in April 2007, the United States filed a Sealed 
Motion for an Order compelling the testimony of == 
Exhibit 1 at P-003714 thru P-
003721. 
11. 
On April 16, 2007, the Court granted the government's Sealed Motion in a Sealed 
Order. Exhibit 3. Judge Middlebrooks was the judge who empaneled Federal Grand Jury 07-103. 
The Sealed Order states, in part, that the "Order shall be SEALED in accordance with Fed. R. 
2 
EFTA00086378
Page 5 / 143
Crim. P. 6(e)(6), except that a copy of this Order shall be provided to counsel for the United States, 
who may disclose the existence of the Order [to a list of persons]. Those persons may review the 
Order, but may not retain a copy of the Order, nor may they disclose the existence of the Order to 
any others." 
12. 
In 2008, Ms. 
became a petitioner in the matter of Jane Doe 1 and Jane Doe 
2 v. United States, S.D. Fla. Case No. 08-80736-Civ-Marra ("the Jane Doe suit"). Ms. 
was 
allowed to proceed, at her request, via the pseudonym "Jane Doe 2" because she was a minor 
during the criminal activity committed by Jeffrey Epstein. Ms. 
was an adult during all 
proceedings related to the grand jury subpoena. 
13. 
In her suit against the United States, Ms. 
avers, in part, that her "right to 
confer with the attorney for the Government in the case" and her "right to be treated with fairness 
and with respect for the victim's dignity and privacy," 18 U.S.C. § 3771(a)(5), (a)(7), were 
violated. I was the "attorney for the Government," although there was no "case" because the U.S. 
Attorney's Office never filed charges against Jeffrey Epstein or any other person involved in 
criminal activity with Ms.M. 
14. 
In the Jane Doe suit, U.S. District Judge Kenneth A. Marra allowed limited 
discovery. Exhibits 1 and 2 were listed on a privilege log and provided to Judge Marra in camera 
for review. The United States asserted that the items should not be produced because they were 
governed by Fed. R. Crim. P. 6(e) and included "[d]ocuments under seal pursuant to court order." 
Exhibit 4 at DE212-1 pp. 1, 6. 
15. 
There was extensive litigation regarding the privilege log, including the assertion 
of the confidentiality of grand jury materials. Judge Marra agreed with the government's assertion 
3 
EFTA00086379
Page 6 / 143
that Exhibit I involved matters occurring before the grand jury and ordered that they need not be 
produced. Exhibit 5 at pp. 5-10, 26, 28. 
16. 
In the Jane Doe suit, Ms. 
has filed a motion for summary judgment, asserting 
that there is no issue of material fact regarding her claim that her rights to confer and to be treated 
with respect were violated. In support of that motion, Ms. 
filed a Declaration. Exhibit 6. 
17. 
In the declaration, Ms. 
makes a number of assertions, including that "there 
could not have been any doubt in anyone's mind .. . that Epstein sexually molested me as a minor"; 
"I believed that if I told the truth about what happened at Epstein's house, the police 
"; "I had been greatly intimidated, which is why I could not be truthful initially 
and I wanted to end the threat of the possibility of 
"; and "I wanted to assist 
the prosecutors in the investigation." Id. 
18. 
These statements are contradicted by Exhibits 1, 2, and 3, and, accordingly, the 
U.S. Attorney's Office now respectfully requests that the Court unseal redacted versions of 
Exhibits I, 2, and 3. 
19. 
This matter relates to issues occurring before the grand jury and, accordingly, is 
governed by Fed. R. Crim. P. 6(e). Under that Rule, the "court may authorize disclosure — at a 
time, in a manner, and subject to any other conditions that it directs — of a grand-jury matter: (i) 
preliminarily to or in connection with a judicial proceeding." 
Federal Rule of Criminal Procedure 6(e) provides that the traditional rule of grand 
jury secrecy may be placed aside under certain circumstances to allow for 
disclosure. 
Specifically, Rule 6(e)(3)(E)(i) states that a district court "may 
authorize disclosure—at a time, in a manner, and subject to any other conditions 
that it directs—of a grand jury matter ... preliminary to or in connection with a 
judicial proceeding." The Supreme Court has explained that a party seeking 
disclosure of grand jury materials must make a showing of a "particularized need" 
by demonstrating that (1) the materials are needed to avoid an injustice in another 
4 
EFTA00086380
Page 7 / 143
proceeding; (2) the need for disclosure is greater than the need for continued 
secrecy; and (3) the request is structured to cover only needed materials. 
United States v. Moussaoui, 483 F.3d 220, 235 (4th Cir. 2007) (citing Douglas Oil Co. v. Petrol 
Stops Northwest, 441 U.S. 211, 222 (1979)). 
20. 
Portions of Exhibits 1, 2, and 3 are relevant to a judicial proceeding, that is, the 
Jane Doe suit. The portions that the U.S. Attorney's Office wishes to disclose are attached hereto 
as Exhibit 7. Disclosure of these portions of the documents are necessary to avoid injustice in the 
Jane Doe suit, that is, to properly inform Judge Marra that Ms. 
did not, in fact, wish to 
confer with an attorney for the Government during the relevant time frame and she was treated 
with respect by the U.S. Attorney's Office and the investigative team. Given that Jane Doe 2 
herself has made these materials relevant to the Jane Doe suit, the need to disclose Exhibit 7 
outweighs the need for secrecy, and Exhibit 7, which is a redacted version of Exhibits 1, 2, and 3, 
properly limits the disclosure of the grand jury materials only to what is needed. 
21. 
Prior to filing this Motion, I inquired of Judge Marra's courtroom deputy whether 
the motion should be filed with Judge Marra. After speaking with the Clerk's Office, Judge 
Marra's courtroom deputy informed me that, because this related to the grand jury, the motion 
should be directed to the District Judge on duty. Pursuant to the Court's website, Senior U.S. 
District Judge Daniel T. K. Hurley is on duty for the month of May 2017. 
//I 
//I 
//I 
5 
EFTA00086381
Page 8 / 143
CONCLUSION 
For the foregoing reasons, the United States respectfully requests that it be permitted to 
disclose Exhibit 7 and file it in support of its Response to Ms. 
summary judgment motion. 
The United States further respectfully requests that the Court's Order make clear that, by filing 
Exhibits 4, 5, and 6 in support of this motion, it does not seek to have them sealed in the Jane Doe 
suit, and that they remain part of the public record in that matter. 
Respectfully submitted, 
BENJAMIN G. GREENBERG 
ACTING UNITED STATES ATTORNEY 
By: 
Assistant United States Attome 
Florida Bar No. 
500 South Australian Avenue, Suite 400 
West Palm Beach, FL 33401
Telephone: 
Facsimile: I 
6 
EFTA00086382
Page 9 / 143
GOVERNMENT 
EXHIBIT 
Case No. 08-80736-CV-MARRA 
P-001713 
EFTA00086383
Page 10 / 143
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
FCII 07-103 (WPB) 
IN RE: 
GRAND JURY PROCEEDINGS 
Party Filing Matter Under Seal 
ORDER RE: SEALED FILING 
Name: 
UNITED STATES OF AMERICA 
Addreas: 
AUSA 
S0CI S. Australian Ave, Ste 400 
Telephone' 
West Palm Bach, FL. 33401 
On behalf of (select one): 
• 
THE APPLICANT 
RESPONDENT 
Date sealed document filed: 
04/16/07 
If sealed pursuant to statute, cite statute: 
Fed. R. Crim. P. 6 
If sealed pursuant to previously enteral protective order, dale of order and docket entry.  
The matter will remain soiled until: 
O Conclusion of Trial 
U Anot of First Defendant 
U Case Closing 
O Conclusion of Direct Appeal 
■ Other 
End of Proem:lines 
O Permanently. Specify the authorizing law, Me. court order 
The moving party requests that when the sealing period tapirs, the filed matter should he (select one): 
O Unseakd and placed in 
• Destroyed 
U Returned to the party or counsel for the 
the public portion of the court Me 
party, as identified above 
It is ORDERED and ADJUDGED that the proposed sealed document is hereby: 
O Sealed 
O NOT Sealed 
O Other 
The matter may be unsealed atter. 
O Conclusion of Trial 
Cl Arrest of First Defendant 
O Remain Sealed 
U Case Closing 
U Conclusion of Direct Appeal 
t3 Other 
DONE and ORDERED at West Palm finch Florida this 
 day of 
 2007. 
Uttard.Stalm.Disuic lease 
This documan has been disposed of lo the following manner 
 
 by 
on 
Case No. 08-80736-CV-MARRA 
P-003714 
EFTA00086384
Page 11 / 143
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
NORTHERN (WEST PALM BEACH) DIVISION 
FGJ NO. 07403 (WPB) 
IN RE: 
GRAND JURY PROCEEDINGS 
MOTION TO SEAL 
The United States of America, by and through the undersigned Assistant United States 
Attorney, hereby moves to seal its Application for Order Compelling Witness Testimony before the 
Grand Jury for the following reasons: 
1. 
The Application contains information regarding proceedings before West Palm Beach 
Federal Grand Jury 07-103, which is subject to the secrecy protections of Fed. R. Crim. P. 6. 
2. 
Pursuant to Rule 6(e)(6), "Erjecords, orders, and subpoenas relating to 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 a grand jury." 
WHEREFORE, the United States respectfully requests that the Application and any Order 
related to the Application be sealed. 
Dated: April 16, 2007 
Respectfully submitted, 
R. ALEXANDER ACOSTA 
ASSISTANT UNITED STA1 ES A 
ORNEY 
Florida Bar No. 
500 South Australian Ave, Suite 400 
West Palm Beach, Florida 33401 
Tel:
Fax: 
Case No. 08-80736-CV-MARRA 
P-003715 
EFTA00086385
Page 12 / 143
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
NORTHERN (WEST PALM BEACH) DIVISION 
FGJ NO. 07-103 (WPB) 
IN RE: 
GRAND JURY PROCEEDINGS 
ORDER 
It is hereby ordered that the United States' Application for Order Compelling Witness 
Testimony before the Grand Jury and the Order granting same be SEALED until further Order of 
this Court. 
DONE AND ORDERED in chambers this 
day of April, 2007, at West Palm Beach, 
Florida. 
DONALD M. MIDDLEBROOKS 
UNITED STATES DISTRICT JUDGE 
cc: 
AUSA 
Case No. 08-80736-CV-MARRA 
P-003716 
EFTA00086386
Page 13 / 143
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
NORTHERN (WEST PALM BEACH) DIVISION 
FGJ NO. 07-103 (WPB) 
IN RE: 
GRAND JURY PROCEEDINGS 
/ 
APPLICATION FOR ORDER COMPELLING WITNESS TESTLMONY 
The United States of America, through its undersigned attorney, makes application to this 
Court for an Order pursuant to the provisions of Title 18, United States Code, Section 6001, et seq., 
compelling== 
to give testimony and to provide other information, which she is likely to 
refuse to give or provide, on the matters about which she may be interrogated before the United 
States District Court for the Southern District of Florida, including a Grand Jury impaneled therein, 
as well as subsequent proceedings or trial, and respectfully alleges as follows: 
1. 
That ==. 
has been called to testify and provide other information before the 
United States District Court for the Southern District of Florida, including before a Grand Jury 
impaneled therein. 
2. 
That, in the judgment of the undersigned, the testimony or other information from 
may be necessary to the public interest. 
3. 
That 
is likely to refuse to testify or provide other information on the 
basis of her privilege against self-incrimination. 
4. 
That this Application is made with the approval of the Assistant Attorney General 
in charge of the Criminal Division of the Department of Justice or a duly designated Acting 
Case No. 08-80736-CV-MARRA 
P-003717 
EFTA00086387
Page 14 / 143
Assistant Attorney General, pursuant to the authority vested in him by Title 18, United States Code, 
Section 6003, and Title 28, Code of Federal Regulations, Sections 0.175 and 0.132(e). A copy of 
the letter from said Assistant Attorney General or his designee expressing such approval is attached 
hereto. 
5. 
That a Subpoena to Testify before Grand Jury 07-103 (WPB) has been served upon 
counsel for 
=, 
who has informed the undersigned that an Order compelling testimony 
is required before 
will appear and testify. Upon receipt of the Court's Order 
compelling such testimony, a new Grand Jury Subpoena will be issued commanding "•==l 
appearance on Tuesday, April 24, 2007 at 1:00 p.m. 
Respectfully submitted, 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
By: 
ASSISTANT UNITED STATES ATTORNEY 
Florida Bar No. 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33132 
FAX S M
2 
Case No. 08-80736-CV-MARRA 
P-003718 
EFTA00086388
Page 15 / 143
IO'd ild101 
11111111*. 
0 fox ..//as Au ay.:Asa" Cooed 
Wasespren AC 2efillalet 
APR 13 2007 
The Honorably R. Alexander Acosta 
Unitcd States Attorney 
• 
' " •SouthemliittriciofFlorida 
West Palm Beach, Florida 33401 
Attention: 
Asstetantlinited States Attorney 
Re: 
Grand Jury Investigpuion, 
terfrey Epstein, et al. 
Dcar Mr. Acosta: 
Pursuant to the authority vested in me by 18 U.S.C. § 6003(h) and 28 C.P.R., § 0.175(a), 
I hereby approve ycur request for authority to apply to °milt:Med States District Court for 
the Southern District of Florida for an order pursinuu to 1811.5 C. §§ 6002-6003 requiring 
to give testimony of provide other information in the above malt, and in any 
further proceedings resulting therefrom or ancillary thereto. 
Sincerely, 
Assistant Attorney Genera] 
V 
!KW; 
ir 
• 
Case No. 08-80736-CV-MARRA 
to./TO'd 
11
P-003719 ;57
-$)
6 :?T Mi0e-9I-OdU 
EFTA00086389
Page 16 / 143
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
NORTHERN (WEST PALM BEACH) DIVISION 
FGJ 07-103(WPB) 
LN RE: 
GRAND JURY PROCEEDINGS 
SEALED ORDER 
On Application of the United States Attorney for the Southern District of Florida, and it 
appearing to the satisfaction of the Court: 
1. 
That 
has been called to testify and to provide other information before 
the United States District Court for the Southern District of Florida, including a Grand Jury 
impanelled therein; and 
2. 
That in the judgment of the said United States Attorney, 
has refused 
to testify and provide other information on the basis of her privilege against self-incrimination; and 
3. 
That in the judgment of the said United States Attorney, the testimony and other 
information from 
may be necessary to the public interest; and 
4. 
That the aforesaid Application has been made with the approval of the Assistant 
Attorney General in charge of the Criminal Division of the Department of Justice or a duly 
designated Acting Assistant Attorney General, pursuant to the authority vested in him by Title 18, 
United States Code, Section 6003, and Title 28, Code of Federal Regulations, Sections 0.175 and 
0.132(e). 
NOW, THEREFORE, it is ordered pursuant to Title 18, United States Code, Section 6002, 
that 
give testimony and provide other information which she refuses to give or to 
Case No. 08-80736-CV-MARRA 
P-003720 
EFTA00086390
Page 17 / 143
provide on the basis of her privilege against self-incrimination, as to all matters about which she may 
be interrogated before said United States District Court, including a Grand Jury impaneled therein, 
as well as any subsequent proceeding or trial. 
However, no testimony or other information compelled under this Order (or any information 
directly or indirectly derived from such testimony or other information) may be used against 
in any criminal case, except a prosecution for perjury, giving a false statement, or otherwise 
failing to comply with this Order. 
IT IS FURTHER ORDERED the this Order shall be SEALED in accordance with Fed. 
R. Crim. P. 6(e)(6), except that a copy of this Order shall be provided to counsel for the United 
States, who may disclose the existence of the Order to members of the Grand Jury, to the witness, 
to counsel for the witness, and to law enforcement officers engaged in the investigation pending 
before the Grand Jury. Those persons may review the Order, but may not retain a copy of the Order, 
nor may they disclose the existence of the Order to any others. 
DONE and ORDERED this 
day of April, 2007, at West Palm Beach, Florida. 
DONALD M. MIDDLEBROOKS 
UNITED STATES DISTRICT JUDGE 
cc: 
AUSA 
2 
Case No. 08-80736-CV-MARRA 
P-003721 
EFTA00086391
Page 18 / 143
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
FGJ 07.103 (WPB) 
IN RE: 
GRAND JURY PROCEEDINGS 
ORDER RE: SEALED FILING 
Party Filing Matter Under Seal 
Name: 
UNITED STATES OP AMERICA 
Address: 
AUSA 
SOO S. Australian Are, Ste 400 
Telephone: 
Wan Pam Back FL 33401 
CM behalf of {select one): 
• 'rim Appucwr 
RESPONDENT 
Date sealed document filed: 
04116/07 
If sealed pursuant to statute, cite statute: 
Fed. It Crisis. P.6 
If sealed pursuant to previously entered protective other, date of order and docket emery:  
The room will remain sealed until: 
0 Conclusion of Trial 
fa Arrest of First Defendant 
O Case Closing 
0 Conclusion of Direct Appeal 
• Other 
End of Promedines 
U Permanently. Specify the authorizing law, nile, 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 coun file 
party, as identified above 
• Destroyed 
0 Returned to the party or counsel for the 
It is ORDERED and ADJUDGED that the proposed sealed document is hereby: 
Sealed 
3 NOT Scaled 
The matter may be unsealed after. 
O Conclusion of Trial 
0 Arrest of Pint Defendant 
CI Case Closing 
0 Conclusion of Direct Appeal 
DONE sod ORDERED at West Palm Beach. Florida this 
 
day of 
This document has been disposed of in the following manner 
on 
0 Other 
U Remain Sealed 
U Other 
2007. 
linked Stales District Judge 
by 
Case No. 08-80736-CV-MARRA 
P-003722 
EFTA00086392
Page 19 / 143
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
NORTHERN (WEST PALM BEACH) DIVISION 
FGJ NO. 07-103 (WPB) 
IN RE: 
GRAND JURY PROCEEDINGS 
MOTION TO SEAL 
The United States of America, by and through the undersigned Assistant United States 
Attorney, hereby moves to seal its Application for Order Compelling Witness Testimony before the 
Grand Jury for the following reasons: 
1. 
The Application contains information regarding proceedings before West Palm Beach 
Federal Grand Jury 07-103, which is subject to the secrecy protections of Fed. R. Crim. P. 6. 
2. 
Pursuant to Rule 6(6)(6), "[r]ecords, orders, and subpoenas relating to 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 a grand jury." 
WHEREFORE, the United States respectfully requests that the Application and any Order 
related to the Application be sealed. 
Dated: April 16, 2007 
Respectfully submitted, 
R. ALEXANDER ACOSTA 
UNITJ.,DATATES ATTORWY 
ASSISTANT UNITED STATES ATTORNEY 
Florida Bar No. 
500 South Australian Ave, Suite 400 
West Palm Beach, Florida 33401 
Tel: 
Fax: 
Case No. 08-80736-CV-MARRA 
P-003723 
EFTA00086393
Page 20 / 143
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
NORTHERN (WEST PALM BEACH) DIVISION 
FGJ NO. 07-103 (WPB) 
IN RE: 
GRAND JURY PROCEEDINGS 
SaWER 
It is hereby ordered that the United States' Application for Order Compelling Witness 
Testimony before the Grand Jury and the Order granting same be SEALED until further Order of 
this Court. 
DONE AND ORDERED in chambers this 
day of April, 2007, at West Palm Beach, 
Florida. 
DONALD M. MIDDLEBROOKS 
UNITED STATES DISTRICT JUDGE 
cc: 
EMI
, AUSA 
Case No. 08-80736-CV-MARRA 
P-003724 
EFTA00086394
Pages 1–20 / 143