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
EFTA00178967
267 pages
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(Rev. 06/2005)Sealcd Document Tracking Forth UNITED STATES DISTRICT COURT Southern District of Florida Number: FGJ 07-103 (WPB) In Re Grand Jury Subpoenas Duces Tecum Numbers OLY-63 and OLY-64 0 UNITED STATES MOTION TO FILE EX PARTE AFFIDAVITS IN SUPPORT OF RESPONSE TO MOTION TO QUAISH Party Filing Matter Under Seal On behalf of (select one): SEALED DOCUMENT TRACKING FORM Name: u.S. Attorneys Office Address: 500 S. Australian Ave, Suite 400, West Palm Beach, FL 33401 Telephone: 0 Plaintiff 0 Defendant Date sealed document filed: 7/31/2007 If sealed pursuant to statute, cite statute: Fed. R. Gam. P. 6(e) (Grand Jury Material) If scaled pursuant to previously entered protective order, date of order and docket entry number: The matter should remain sealed until: O Conclusion of Trial 0 Arrest of First Defendant CI Case Closing 0 Other: O Permanently. Specify the authorizing law, rule, court order: 0 Conclusion of Direct Appeal 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 Cl Destroyed Returned to the party or counsel for the party, as identified above Attorney for: Movant Unit"' Stales of America EFTA00179147
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE: GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY-64 AND OLY-64 FGJ 07-103 (WPB) MOTION FOR LEAVE TO FILE EX PARTE DECLARATIONS IN SUPPORT OF UNITED STATES' RESPONSE TO MOTION TO OUASH UNDER SEAL EFTA00179148
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE: GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY-64 AND OLY-64 FGJ 07-103 (WPB) UNDER SEAL MOTION FOR LEAVE TO FILE EX PARTE DECLARATIONS IN SUPPORT OF UNITED STATES' RESPONSE TO MOTION TO QUASH The United States of America, by and through the undersigned Assistant United States Attorney, hereby asks for permission to file two ex parte Declarations in support of its Response to Jeffrey Epstein's Motion to Intervene and to Quash Subpoenas and Cross- Motion to Compel. In support thereof, the United States states the following: 1. The Declarations contain information relating to an ongoing grand jury investigation; thus, pursuant to Fed. R. Crim. P. 6(e)(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. 2. The Declarations are being filed ex parte because disclosing them to the target would jeopardize the criminal investigation, and undermine the function of the grand jury. 3. As the Supreme Court has held, "[r]equiring the Government to explain in too much detail the particular reasons underlying a subpoena threatens to compromise `the indispensable secrecy of the grand jury proceedings.' United States v. R. Enterprises, Inc., 498 U.S. 292, 299 (1991) (quoting United States v. Johnson, 319 U.S. 503, 513 (1943)). "The need to preserve the secrecy of an ongoing grand jury investigation is of paramount EFTA00179149
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importance." In re Grand Jury Proceedings in Matter of Freeman, 708 F.2d 1571, 1576 (11th Cir. 1983) (extensive citations omitted). 4. The issues raised by Intervenor Epstein's Motion to Quash require the United States to provide information obtained through the Grand Jury's investigation. Due to the pendency of the investigation, and the requirements of Grand Jury secrecy, the United States asks that the Court allow the United States to file two Ex Parte declarations, which address the factual issues raised by Intervenor Epstein, without being forced to disclose the status of the grand jury investigation and the matters occurring before the grand jury to Epstein. Pursuant to the Local Rules, the undersigned has conferred with counsel for Intervenor Epstein, who has advised that he opposes the granting of this motion. WHEREFORE, the United States respectfully requests that it be allowed to file two Declarations Ex Parte in support of its Response to the Motion to Quash. Respectfully submitted, R. ALEXANDER ACOSTA B 500 South Austra ian venue, Suite 400 West Palm Beach. FL 33401 Telephone; Facsimile: EFTA00179150
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CERTIFICATE OF SERVICE I HEREBY CERTIFY that on July 31 , 2007, the foregoing document will be served via Federal Express on Attorney William Richey and will be served by hand delivery on Attorney Roy Black. This document was not filed using CM/ECF because it is being filed under seal. ssistant U.S. Attorney SERVICE LIST In re Federal Grand Jury Subpoenas No. OLY-63 and OLY-64 United States District Court, Southern District of Florida ssistant U S Attorney U.S. Attorney's Office 500 S. Australian Ave, Suite 400 West Palm Beach. FL 33401 Telephone; Facsimile: Attorney for United States William I, Richey Fsq. William L. Richey P.A. 201 S. Biscayne Boulevard, 34th Floor Miami, Flo ' Telephone; Facsimile: Attorney or u poenaed Parties Riley Kiraly and William Riley ov Black. Esa. Black, Srebnick, Kornspan & Stumpf, P.A. 201 S. Biscayne Boulevard, Suite 1300 Miami, FL 1 Telephone; Facsimile: Attorney or ntervenor Jeffrey Epstein EFTA00179151
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE: GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY-64 AND OLY-64 UNDER SEAL ORDER GRANTING UNITED STATES' MOTION TO FILE Ex PARTE DECLARATIONS This matter comes before the Court upon the United States' Motion to File two Ex Parte Declarations in support of its Response to the pending Motion to Quash. The Court being fully apprised in the premises, orders that the motion is hereby GRANTED. DONE AND ORDERED in chambers, in West Palm Beach, Florida, this day of July, 2007. cc: , AUSA Roy Black, Esq. William Richey, Esq. FGJ 07-103 (WPB) KENNETH A. MARRA UNITED STATES DISTRICT JUDGE EFTA00179152
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY-63 and OLY-64 I FGJ 07-103(WPB) MOTION TO FILE DOCUMENTS UNDER SEAL FILED UNDER SEAL EFTA00179153
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE: GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY-64 AND OLY-64 FGJ 07-103 (WPB) MOTION TO FILE DOCUMENTS UNDER SEAL The United States of America, by and through the undersigned Assistant United States Attorney, hereby moves to seal this Motion, the United States' Motion ofJeffity Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross-Motion to Compel, the United States' Motion for Permission to File Ex Parte Affidavits, the Order on the United States' Motion for Permission to File Ex Pante Affidavits, the United States' Unopposed Motion for Permission to File Oversized Response to Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross- Motion to Compel, Ex Parte Declaration Number One in Support of United States' Response to Motion to Quash Subpoenas, the Declaration of , and the Ex Parte Declaration Number Two in Support of United States' Response to Motion to Quash Subpoenas for the following reasons: 1. The attached documents contain information relating to an ongoing grand jury investigation; thus, pursuant to Fed. R. Crim. P. 6(e)(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. 2. Public disclosure of this matter would jeopardize the criminal investigation, notify potential subjects and/or targets and undermine the public interest and the function of the grand jury. 3. EFTA00179154
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WHEREFORE, the United States 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 that on July.4 , 2007, the foregoing document will be served via Federal Express on Attorney William Richey and will be served by hand delivery on Attorney Roy Black. This document was not filed using CM/ECF because it is being filed under seal. . Mari illafafia Assistant U.S. Attorney 2 EFTA00179155
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SERVICE LIST In re Federal Grand Jury Subpoenas No. OLY-63 and OLY-64 United States District Court, Southern District of Florida sistant U.S. Attorney U.S. Attorney's Office 500 S. Australian Ave, Suite 400 West Palm 33401 Telephone: Facsimile: Attorney for United States 3 William 1.. Richey. Fsq. William L. Richey P.A. 201 S. Biscayne Boulevard, 34th Floor Miami, Flo Telephone; Facsimile: Attorney for Subpoenaed Parties Riley Kiraly and William Riley ov Black. Rca. Black, Srebnick, Komspan & Stumpf, P.A. 201 S. Biscayne Boulevard, Suite 1300 Miami, FL Telephone; Facsimile: Attorney for Intervenor Jeffrey Epstein EFTA00179156
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(Rev. 06/2005)Sealml Document Inciting Fonn UNITED STATES DISTRICT COURT Southern District of Florida Number: FGJ 07-103 (WPB) In Re Grand Jury Subpocnas Duces Tccum Numbers OLY-63 and OLY-64 UNITED STATES MOTION TO FILE DOCUMENTS UNDER SEAL SEALED DOCUMENT TRACKING FORM Party Filing Matter Under Seal On behalf of (select one): Name: U.S. Attorneys Office Address: NO S. Australian Ave, Suite 400. West Palm Beach. FL 33401 Telephone: K Plaintiff K Defendant Date sealed document filed: 6131/2007 If scaled pursuant to statute, cite statute: Fed. R. Cam. P. 6(e) (Grand Jury Material) If sealed pursuant to previously entered protective order, date of order and docket entry number: The matter should remain sealed until: 0 Conclusion of Trial O Arrest of First Defendant Case Closing O Conclusion of Direct Appeal K Other: O 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): O Unsealed and placed in the public portion of the court file D Destroyed El Returned to the party or counsel for the party, as identified above Attorney for: Unita...Slat+ America EFTA00179157
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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) MOTION TO FILE DOCUMENTS UNDER SEAL FILED UNDER SEAL EFTA00179158
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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) MOTION TO FILE DOCUMENTS UNDER SEAL The United States of America, by and through the undersigned Assistant United States Attorney, hereby moves to seal this Motion, the United States' Surreply to the Replies of . William Riley and Intervenor Jeffrey Epstein on Motion to Quash Grand Jury Subpoenas, and Supplement to Ex Parte Declaration Number One in Support of United States' Response to Motion to Quash Subpoenas, for the following reasons: 1. The attached documents contain information relating to an ongoing grand jury investigation; thus, pursuant to Fed. R. Crim. P. 6(e)(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. 2. Public disclosure of this matter would jeopardize the criminal investigation, notify potential subjects and/or targets and undermine the public interest and the function of the grand jury. 1 EFTA00179159
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WHEREFORE, the United States respectfully requests that the aforementioned documents be sealed. Respectfully submitted, R. ALEXANDER ACOSTA UNITED STATES ATTORNEY By: Assistant United States Attorne Florida Bar No. 500 South Australian Avenue, Suite 400 West Palm Beach, FL 33401 Telephone: Facsimile: CERTIFICATE OF SERVICE I HEREBY CERTIFY that on August 30, 2007, the foregoing document was served via Federal Express on Attorneys William Richey and Roy Black. This document was not filed using CM/ECF because it is being filed under seal. Assistant U.S. Attorney 2 EFTA00179160
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SERVICE LIST In re Federal Grand Jury Subpoenas No. OLY-63 and OLY-64 United States District Court, Southern District of Florida Assistant U.S. Attorney U.S. Attorney's Office 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Telephone: Facsimile: Attorney for United States 3 William L. Richey, Esq. William L. Richey P.A. 201 S. Biscayne Boulevard, 34th Floor Miami, Florida 33131 Telephone: Facsimile: Attorney for Subpoenaed Parties Riley Kiraly and William Riley Roy Black, Esq. Black, Srebnick, Komspan & Stumpf, P.A. 201 S. Biscayne Boulevard, Suite 1300 Miami, FL 33131 Telephone: Facsimile: Attorney for Intervenor Jeffrey Epstein EFTA00179161
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE: GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY-64 AND OLY-64 FGJ 07-103 (WPB) UNDER SEAL ORDER GRANTING UNITED STATES' MOTION TO SEAL This matter comes before the Court upon the United States' Motion to Seal the documents related to its Surreply regarding the pending Motion to Quash Grand Jury Subpoenas. The Court being fully apprised in the premises, orders that the motion is hereby GRANTED. DONE AND ORDERED in chambers, in West Palm Beach, Florida, this day of , 2007. cc: AUSA Roy Black, Esq. William Richey, Esq. KENNETH A. MARRA UNITED STATES DISTRICT JUDGE EFTA00179162
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(Rev. 06/2005)Seakd Document 'nuking Fonn UNITED STATES DISTRICT COURT Southern District of Florida Number: FG.i 07-103 (WPB) In Re Grand Jury Subpoenas Duces Tecum Numbers OLY-63 and OLY-M UNITED STATES' SURREPLY TO REPLIES FILED BY WITNESS AND INTERVENOR JEFFREY EPSTEIN RE MOTION TO QUASH GRAND JURY SUBPOENAS SEALED DOCUMENT TRACKING FORM Party Filing Matter Under Seal Name: U.S. Attorney's Office Address: 500 S. Austranan Ave, Stile 400, West Palm Beach, FL 33401 On behalf of (select one): Telephone: K Plaintiff K Defendant Date sealed document filed: 8/3112007 If sealed pursuant to statute, cite statute: Fed. R. Crim. P. 6(e) (Grand Jury Material) If sealed pursuant to previously entered protective order, date of order and docket entry number: The matter should remain sealed until: K Conclusion of Trial K Arrest of First Defendant Case Closing K Conclusion of Direct Appeal K Other: 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 Returned to the party or counsel for the party, as identified above ‘....ev Attorney for: United Si8414ATegial EFTA00179163
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FEeth William L. Richey, P William L. Richly, P.A. TO: PAGE: 001 OM 007 William L. Richey, Y.A. Facsimile transmittal 201 South Biscayne Boulevard 34th Floor, Miami Center Miami, Florida 33131-4325 Phone: Fax: MIS To: Esq. From: Danise Townsend Fax: 1- Date: 8/17/2007 3:38:50 PM Re: Grand Jury Subpoena - Jeffrey Pages: 7 .. . Attached is a Sealed Document Tracking Form, Motion to File Documents Under Seal and an Order Granting Same. This transmittal is intended only for the use of the addressee and may contain information that is privileged, confidential and exempt from disclosure by law. If the reader of this transmittal is not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify us immediately by telephone and return the original transmittal to us by mail. Thank you for your cooperation. If you have not received a dear and legible transmission or if there are any problems with this transmission, please telephone us immediately at EFTA00179164
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m/17/2007 ):34 P11 PAM: William L. fachey, P William L. kicky, P.A. TO: 1 PAGE: 002 CF 007 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA FGJ 07-103 (WPB) IN RE GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY-63 & OLY-64 I SEALED DOCUMENT TRACKING FORM Pally fling Maner Under Seal Name: William L. Richey Address: 201 South Biscayne Boulevard. 346 Floor sat 33131 Telephone: On behalf of (select one): o Plaintiff a Defendant N Subpoenaed Parties Date sealed document filed: August 17, 2007 If sealed pursuant to statute, cite statute: The matter should remain sealed until: o Conclusion of Trial o Arrest of First Defendant o Case Closing a Conclusion of Direct Appeal Other: Until further Order of the Court o 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): o Unsealed and placed in the public portion of the court file Destroyed o Returned to the party or counsel for the party, as identified above Respectfully submitted. WILLIAM L. RICHEY, P.A. 201 South Biscayne Boulevard, 34th Floor 1 William L. Ha. Bar No. EFTA00179165
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MP:: Walls. L. Ple1.*y, P V1111 am L. Fuch..y, P.A. TO: 1-S.G1-.02-17.7 PAGE: 00', OF 0' UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA FGJ 07-103 (WPB) IN RE GRAND JURY SUBPOENAS DUCES TECUM NUMBERS OLY-63 & OLY-64 MOTION OF WILLIAM RILEY AND RILEY KIRALY TO FILE DOCUMENTS UNDER SEAL FILED UNDER SEAL leilliam L. Richey, P.A. 201 South Ois,,,yne Boulevard. 34th Floor, Miami Center, Miami, Florida 33131—B25 •— —• Fac»nrile EFTA00179166