EFTA00178967

Even if the act of production were testimonial for purposes ofDoe, production can be refused 
only if the act of production also is incriminating. Butcher, 753 F.2d at 469-70. In other words, the 
act of authentication is incriminating only if the documents are incriminating. As explained above, 
Epstein has failed to make the slightest showing that the computers' contents are incriminating. 
Where a party fails to provide "sufficient facts to state with reasonable certainty that the privilege 
applies, the burden is not met." United States v. Blackburn, 538 F. Supp. 1376, 1382 (M.D. Fl. 
1982) (citing Federal Trade Commission v. TRW, Inc., 628 F.2d 207, 213 (D.C. Cir. 1980); In re 
Katz, 623 F.2d 122, 125 (2d Cir. 1980); United States v. Landof, 591 F.2d 36, 38 (9th Cir. 1978); 
In re Grand Jury Proceedings, 73 F.R.D. 647, 651 (M.D. Fl. 1977)). 
In Blackburn, the Middle District of Florida applied the act of production privilege under the 
premise that Boyd was still binding precedent. Even applying Boyd, the court found that the 
vicarious assertion of act of production immunity via the attorney-client privilege required a 
showing that the subpoenaed documents were transferred by the target for purposes of obtaining 
legal advice and that the documents were exclusively prepared by the target or under the target's 
immediate supervision and that they were confidential. When the target failed to provide adequate 
evidence of any one of these elements, the court held that the documents were not privileged. 
Epstein has made none of these showings. 
Thus, because Riley's compliance with the subpoenas' demand for the production of the 
computers would not be testimonial and neither Riley nor Epstein has shown that the computers' 
contents incriminate either of them, the Court should enforce the subpoenas. 
-28-
EFTA00179127

V. 
THE ITEMS SOUGHT IN REQUEST NUMBER THREE ARE NOT 
COVERED BY THE ATTORNEY-CLIENT PRIVILEGE OR THE WORK 
PRODUCT DOCTRINE. 
The third request contained in the subpoenas to Riley and Riley Kiraly seeks: 
3. 
All documents and information related to the nature of the relationship between Mr. 
William Riley and/or Riley Kiraly and Mr. Jeffrey Epstein, including, but not limited 
to, retainer agreements; employment agreements; billing statements (whether 
submitted directly to Mr. Epstein or to a third party for reimbursement); records of 
the dates when services were performed and the hours worked; telephone logs or 
records of dates of communications with Mr. Epstein (or with a third party on Mr. 
Epstein's behalf); appointment calendars/datebooks and the like (whether in hard 
copy or electronic form) for any period when work was performed on behalf of Mr. 
Epstein or when any communication was had with Mr. Epstein (or with a third party 
on Mr. Epstein's behalf); and records of fee arrangements and payments received for 
work performed on Mr. Epstein's behalf." 
Although not clear from Epstein's motion, he does not appear to assert the act-of-production 
privilege as to the billing records, nor could he, since: (I ) he did not create or possess the documents 
and, therefore, could not authenticate them; and (2) since the Affidavit filed by Epstein's counsel 
admits that William Riley and Riley Kiraly were hired to assist Epstein's defense, the existence of 
the documents is not contested. 
Instead, Epstein makes a blanket assertion that all of the billing records are either work 
product or attorney-client communications that need not be produced. This assertion fails both 
procedurally and legally. 
A. 
Epstein's Claim of Privilege Is Waived by His Failure to Carry His 
Burden of Proving Its Applicability. 
Procedurally, the person asserting the privilege bears the burden of establishing its 
applicability. See, e.g., United States v. Schaltenbrand, 930 F.2d 1554 (11th Cir. 1991); United 
'8For purposes of this discussion, the requested documents will be jointly referred to as 
"billing records." 
-29-
EFTA00179128

States v. Mutioz, 233 F.3d 1117 (9th Cir. 2000); Hawkins v. Stables, 148 F.3d 379 (4th Cir. 1998); 
Motley v. Marathon Oil Co., 71 F.3d 1547 (10th Cir. 1995); Christman v. Brauvin Realty AdvisorS, 
Inc., 185 F.R.D. 251 (N.D. III. 1999). In making that showing, blanket assertions of the privilege 
are not proper—the assertion must be made on a question-by-question and document-by-document 
basis. See, e.g., Nguyen v. Excel Corp., 197 F.3d 200 (5th Cir. 1999); Clarke v. American 
Commerce Nat. Bank, 974 F.2d 127 (9th Cir. 1992); United States v. White, 950 F.2d 426, 430 (7th 
Cir. 1991). 
As explained above, a party's failure to provide a privilege log or to otherwise substantiate 
its claims of privilege can act as a waiver of the privilege. That standard should apply here and all 
of the items in Request Number Three should be ordered produced. 
B. 
The Categories of Documents Sought All Fall Outside the Privilege. 
Legally, each of the categories of documents contained in the third request has been 
discussed by courts and determined to be outside the privilege. The Eleventh Circuit holds that the 
"identity of a client and the receipt of attorney's fees normally are not privileged matters." In re 
Grand Jury Matter No. 91-01386, 969 F.2d 995, 997 (11th Cir. 1992) (citation omitted). In United 
States v. Legal Servs. for New York City, 249 F.3d 1077 (D.C. Cir. 2001), the D.C. Circuit stated that 
"[c]ourts have consistently held that the general subject matters of clients' representations are not 
privileged. Nor does the general purpose of a client's representation necessarily divulge a 
confidential professional communication, and therefore that data is not generally privileged." Id. 
at 1081 (citation omitted). See also Nguyen v. Excel Corp., 197 F.3d 200, 206 (5th Cir. 1999) ("the 
general nature of [an attorney's] services is not protected by the privilege."); In re Horn, 976 F.2d 
1314, 1317 (9th Cir. 1992) ("the attorney-client privilege ordinarily protects neither a client's 
-30-
EFTA00179129

identity nor information regarding the fee arrangements reached with that client," including the 
amount paid for legal services and the form of payment) (citation omitted); Clarke v. American 
Commerce Nat'! Bank, 974 F.2d 127, 129 (9th Cir. 1992) ("the identity of the client, the amount of 
the fee, the identification of payment by case file name, and the general purpose of the work 
performed are usually not protected from disclosure by the attorney-client privilege") (citations 
omitted); In re Grand Jury Proceedings in Matter ofFine, 641 F.2d 199, 204 (5th Cir. 1981) (same); 
O'Neal v. United States, 258 F.3d 1265 (11th Cir. 2001) (information regarding the receipt of 
attorney's fees is not protected). 
In Matter of Grand Jury Proceeding, 68 F.3d 193 (7th Cir. 1995), the Seventh Circuit 
discussed specific questions asked of an attorney during his testimony before the grand jury. There, 
unlike here, the attorney properly appeared to testify and then asserted a claim of privilege in 
response to particular questions. The Seventh Circuit found that the following questions did not call 
for privileged communications: 
(1) Whom did you direct [in the search of documents responsive to the subpoena)? 
(2) From whom did you get [the documents you produced in response to the 
subpoena)? 
(3) Did [the person who supplied the documents to you] understand they were given 
in response to a subpoena? (Brackets in original.) 
(4) Did that person understand you were to forward them to the Grand Jury in 
response to a subpoena? 
(5) Did you tell your client . . . you were going to convey them to the government 
pursuant to Grand Jury subpoena? 
-31-
EFTA00179130

Id. at 194-95, 196. 
In reaching its decision, the Seventh Circuit relied on In re Feldberg, 862 F.2d 622 (7th Cir. 
1988). In Feldberg, an attorney was subpoenaed to appear before the grand jury after the grand jury 
suspected obstruction of justice based upon the delayed disclosure of certain documents. The 
attorney appeared but asserted the attorney-client privilege in response to several questions. The 
Feldberg court determined that the following questions did not call for privileged information: 
(1) Did you direct someone else to [conduct a search of the files for purposes of 
gathering the information responsive to this subpoena]? 
(4) Did you have a conversation with anyone affiliated with World Sports 
Entertainment in which you told them that you were going to [contact the U.S. 
Attorney's Office and say you represented World Sports and would handle 
compliance with the subpoena]? 
(6) Did you tell [the president of World Sports and an associate] that you were going 
to convey these contracts to the Government, with the representation that they were 
all contracts called for by the subpoena? 
(7) [D] id you direct anyone to produce such a list [of contracts] for disclosure to the 
Government? 
(8) Did you have a conversation in which you asked someone to give those [51 
contracts] to you for disclosure to the Government? 
Fine, 68 F.3d at 196 (quoting Feldberg, 862 F.2d at 624) (brackets in original). In both instances, 
the Seventh Circuit held that questions that "deal with whether the attorney 'directed someone to 
search the files; if so, who and how' were not privileged. Fine at 196 (quoting Feldman at 628). 
-32-
EFTA00179131

Questions that "involve whether the client or the person collecting the documents knew they were 
acting pursuant to a subpoena" likewise did not violate the privilege. Id. While these cases address 
testimonial questions, the information that they seek to elicit is similar to the information contained 
in some of the documents subpoenaed from Riley, including, for example, billing statements, records 
of dates of services performed and dates of communications with Epstein. 
Other cases have held that the scope or objective of an attorney's employment is not 
protected, In re Grand Jury Proceedings-Gordon, 722 F.2d 303 (6th Cir. 1983), nor are telephone 
records and appointment calendars of the attorney. McArthur v. Robinson, 98 F.R.D. 672 (E.D. Ark. 
1983). Thus, the dates on which the client first contacted his attorney, the dates on which services 
were rendered, and the dates that the client communicated with his attorney are not privileged. 
Condon v. Petaque, 90 F.R.D. 53 (N.D. III. 1981). See also Matter of Walsh, 623 F.2d 489 (7th Cir. 
1980) (ledgers, bills, time records, and retainer agreements in the possession of the attorney not 
privileged); Coalition to Save Our Children v. State Bd. of Educ., 143 F.R.D. 61 (D. Del. 1992) 
(time sheets and billing records not privileged). 
One of Epstein's other attorneys, Gerald Lefcourt, is certainly aware that a client's identity, 
his payment of fees, and the method and amount of payment are not privileged, even when the 
information would incriminate the client "in the very case in which the Firm was engaged to provide 
criminal defense representation." Gerald B. Lefcourt, P.C. v. United States, 125 F.3d 79, 87 (2d Cir. 
1997). In that case, Attorney Lefcourt refused to identify in an IRS reporting form a client who paid 
him more than $10,000 cash, and Lefcourt was fined $25,000. Lefcourt sought to avoid the fine, 
claiming that he had an objectively reasonable belief that the information was privileged. The 
Second Circuit determined that he did not, noting its series of cases holding that the attorney-client 
-33-
EFTA00179132

privilege did not bar the disclosure of fee information, even where that information could 
incriminate the client. Id. Epstein's attempt to assert similar arguments here should also fail. 
VI. 
EPSTEIN DOES NOT HAVE ANY SIXTH AMENDMENT RIGHTS IN 
CONNECTION WITH THE GRAND JURY'S INVESTIGATION. 
Epstein spends several pages arguing that the grand jury subpoenas violate his Sixth 
Amendment right to counsel and to the effective assistance of counsel. Yet Epstein has no rights 
under the Sixth Amendment in connection with this investigation. The right to effective assistance 
of counsel does not attach until adversary judicial proceedings have been initiated against a 
defendant. Kirby v. Illinois, 406 U.S. 682 (1972). For this reason, the Sixth Amendment does not 
apply to a grand jury investigation, and a demand for information related to the attorney-client 
relationship prior to that time does not violate the client's right to counsel or interfere with his future 
right to counsel. In re Special September 1978 Grand Jury (IV, 640 F.2d 49, 64 (7th Cir. 1980); 
Tornay v. United States, 840 F.2d 1424 (9th Cir. 1988). 
Adversary judicial proceedings have yet to begin in the federal system and also had not 
begun in the state system at the time the computers were removed; thus, the Sixth Amendment is 
not implicated. Epstein tries to avoid this conclusion by dropping a footnote asserting that, pursuant 
to Texas v. Cobb, 532 U.S. 162 (2001), his Sixth Amendment rights attached at the time he was 
charged in the state system. This misstates Cobb and its progeny which hold that a defendant's 
Sixth Amendment right to counsel is charge-specific, and that Sixth Amendment rights in 
connection with prosecution by one sovereign do not carry over to prosecution by another sovereign. 
In Cobb, the Supreme Court clarified its holding in McNeil v. Wisconsin, 501 U.S. 171 
(1991) that the "Sixth Amendment right to counsel is offense specific. It cannot be invoked once 
for all future prosecutions." Id. at 167 (quoting McNeil at 175). The Cobb Court noted that some 
-34-
EFTA00179133

other courts: 
have read into McNeil's offense-specific definition an exception for crimes that are 
'factually related' to a charged offense. Several of these courts have interpreted 
Brewer v. Williams, 430 U.S. 387 (1977) and Maine v. Moulton, 474 U.S. 159 —both 
of which were decided well before McNeil — to support this view, which respondent 
now invites us to approve. We decline to do so. 
Cobb at 168 (emphasis added). 
Instead, the Cobb Court made clear that the Sixth Amendment right is truly offense-specific, 
meaning limited to the same offense for purposes of the Double Jeopardy Clause. Id. at 172-173 
("We see no constitutional difference between the meaning of the term 'offense' in the contexts of 
double jeopardy and of the right to counsel. Accordingly, we hold that when the Sixth Amendment 
right to counsel attaches, it does encompass offenses that, even if not formally charged, would be 
considered the same offense under the Blockburger test.") The Supreme Court also noted that 
"offense-specific" is synonymous with "prosecution specific." Id. at n.3.1' 
The Supreme Court chose to clearly delineate the scope of those interrogations subject to 
suppression because: 
it is critical to recognize that the Constitution does not negate society's interest in the 
ability of police to talk to witnesses and suspects, even those who have been charged 
with other offenses. "Since the ready ability to obtain uncoerced confessions is not 
an evil but an unmitigated good, society would be the loser. Admissions of guilt 
resulting from valid Miranda waivers are more than merely desirable" they are 
essential to society's compelling interest in finding, convicting, and punishing those 
who violate the law. 
Id. at 172-73 (quoting McNeil, 501 U.S. at 181). 
Two Courts of Appeals have addressed Cobb in the context of persons charged by state 
"In Cobb, the Court went on to decide that Texas police officers did not violate Cobb's Sixth 
Amendment rights when they questioned him regarding murders that occurred during a burglary 
even though the defendant was already represented in connection with the pending burglary charge. 
-35-
EFTA00179134

prosecutors who are later interrogated by federal agents. In those cases, the courts have found that, 
so long as the state charge and the federal charge contain different elements under the Blockburger 
test, there is no Sixth Amendment violation, even if the charges arise from the same act. See United 
States v. Avants, 278 F.3d 510, 512-13 (5th Cir. 2002) ("[T]he federal and state murder prosecutions 
in this case, although identical in their respective elements, are separate offenses for purposes of the 
Sixth Amendment because they were violations of the laws of two separate sovereigns—specifically 
the State of Mississippi and the United States. Therefore, because the Sixth Amendment is offense-
specific, Avants's statements during the 1967 interview, when he was represented by counsel only 
in the state proceeding, are not barred in this federal proceeding."); United States v. Coker, 433 F.3d 
39 (1st Cir. 2005) (same). See alio United States v. Lall, 
F. Supp. 2d 
, 2007 WL 1521487, 
*7 (M.D. Fl. May 23, 2007) ("Lall's state and her federal charges, although pertaining to the same 
criminal episode, are separate offenses for Sixth Amendment purposes. The reason is that each 
prosecution involves separate sovereigns."); United States v. McCloud, 
F. Supp. 2d 
, 2007 
WL 1706353 (S.D. Ga. June 11, 2007) (same). 
Even if Epstein could assert a Sixth Amendment violation based upon the issuance of the 
subpoenas, his assertion that the subpoenas should be quashed because "his entire attorney-client 
relationship would be endangered [fails,) for it is confidential communications that are protected, 
not the relationship as a whole. McKay v. C.I.R., 886 F.2d 1237 (9th Cir. 1989). 
VII. 
THE SUBPOENAS ARE NOT OPPRESSIVE, OVERBROAD, AND 
UNPARTICULARIZED. 
Epstein also asserts that the subpoenas seeking the computer equipment are unreasonable 
because they are oppressive, overbroad, and unparticularized. Epstein has failed to cite any legal 
authority that allows him to intervene to assert these challenges. "In the absence of a claim of 
-36-
EFTA00179135

privilege, a party usually does not have standing to a subpoena directed to a non-party witness." 
Langford v. Chyrsler Motors Corp., 513 F.2d 1121, 1126 (2d Cir. 1975). For example, in United 
States v. Wells, 2006 WL 3203905 (E.D. Mich. Nov. 3, 2006), a party sought to quash a subpoena 
issued to his bank, objecting that he was "unsure of what information the United States [sought] to 
gain from [the bank's] records." Id. at *2. The district court denied the motion, noting the party's 
lack of standing in the absence of the assertion of a privilege. As set forth above, the United States 
does not object to Epstein's intervention to assert his Fifth Amendment, attorney-client, and work 
product privileges, but there is no basis for him to intervene to assert that the subpoenas are 
burdensome when he is not the person who will bear that burden, and the subpoenaed parties have 
not raised a complaint. 
If the Court finds that Epstein has standing to assert these challenges, he also bears the 
burden of establishing his allegation that the subpoenas are oppressive or overbroad. A "grand jury 
subpoena is presumed reasonable unless its recipient demonstrates otherwise. Fed. R. Crim. P. 17(c) 
permits judicial oversight only when 'compliance would be unreasonable or oppressive.' Thus the 
Court held trial courts can not place an initial burden on the government to prove a grand jury 
subpoena is necessary and relevant." In re Impounded, 241 F.3d 308, 314 (3d Cir. 2001) (quoting 
R. Enter., supra, 498 U.S. at 298-99). See also Blair v. United States, 250 U.S. 273, 282 (1919) (a 
grand jury witness cannot refuse to respond to a subpoena on the grounds that the information 
sought by the grand jury is not relevant to its investigation). 
The burden of showing 
unreasonableness rests with the person seeking to avoid compliance. R. Enterprises, 498 U.S. at 
301. 
The Supreme Court has noted the grand jury's broad powers to issue subpoenas: "the grand 
-37-
EFTA00179136

jury's authority to subpoena witnesses is not only historic . . . but essential to its task. . . . The 
"longstanding principle that 'the public . . has a right to every man's evidence,' except for those 
persons protected by a constitutional, common-law or statutory privilege, . . . is particularly 
applicable to grand jury proceedings." Branzburg v. Hayes, 408 U.S. 665, 688 (1972) (citations 
omitted). In R. Enterprises, the Supreme Court held that subpoenas cannot be quashed on the basis 
of irrelevance if there is a reasonable possibility that the materials sought by the government will 
produce information relevant to the grand jury investigation. R. Enter., 498 U.S. at 300. 
Despite these broad powers, Epstein objects to the subpoenas that specifically call for and 
describe three computers, arguing that they are "unparticularized" and "oppressive." A grand July 
subpoena must be reasonable, and, in making that determination, "what is reasonable depends on 
the context." New Jersey v. T.L.O., 469 U.S. 325, 337 (1985). Likewise, whether a subpoena is 
oppressive depends on the context. In re August, 1993 Regular Grand Jury, 854 F. Supp. 1392, 
1401 (S.D. Ind. 1993). The context here is the wholesale removal of these computers just days 
before a court authorized a warrant for their seizure. The context of this investigation is Epstein's 
sexual exploitation of numerous girls from local high schools; the known existence of surveillance 
video equipment in the home; computer printouts showing electronic messages for "appointments" 
with the minors; and printouts showing payments made to girls. 
In determining the reasonableness of a subpoena, the most important facts are whether the 
subpoena commands the production of items relevant to the grand July's investigation, the 
particularity with which the items sought are described, and the burden involved in compliance. See 
R. Enterprises, 498 U.S. at 300. Since the investigation's subject is secret, Epstein must persuade 
the Court that the subpoena could serve no legitimate purpose that the grand jury could possibly 
-38-
EFTA00179137

investigate. Id. Epstein has failed to do so. 
A claim of oppressiveness requires a showing that compliance is excessively difficult. See 
In re Grand Jury Proceedings, 115 F.3d 1240, 1244 (5th Cir. 1997). Oppression is difficult to 
establish, even if the cost of compliance is "crippling." In re August, 1993 Regular Grand Jury, 854 
F. Supp. at 1402. With respect to the particularity and oppressiveness, the Riley subpoenas 
specifically describe the items to be produced, and, as written, impose a minimal burden, they 
simply call for Riley to return the equipment that was removed.2°
CONCLUSION 
For the foregoing reasons, the United States respectfully requests that the Court deny the 
Motion to Quash filed by Jeffrey Epstein and order the subpoenaed parties, William Riley and Riley 
Kiraly, to appear and provide testimony and evidence in accordance with the issued subpoenas at 
the next meeting of the Grand Jury. 
Respectfully submitted, 
R. ALEXANDER ACOSTA 
By: 
Assistant United States Attorney 
Florida Bar No. 
500 South Australian Avenue, Suite 400 
West Palm Beach, FL 33401 
Telephone: 
Facsimile: 
"It would be more burdensome to attempt to craft a list of computer files for Riley to 
produce, which would require Riley to conduct a manual search of the computer equipment himself. 
-39-
EFTA00179138

CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on July3/ 
 , 2007, the foregoing document and the Declaration 
of 
will be served via hand delivery on Attorney Roy Black, counsel for Jeffrey 
Epstein. The same documents will be sewed on William Richey, counsel for William Riley and 
Riley Kiraly, via Federal Express. This doc 
filed under seal. 
Assistant 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 
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 
-40-
William L. Richey, Esq. 
William L. Richey P.A. 
201 S. Biscayne Boulevard, 34th Floor 
Miami, Florida 33131 
Telephone: 
Facsimile: 
Attorney for Sub enaed Parties 
and 
Service via Federal Express 
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 
Service via Hand Delivery 
EFTA00179139

(Rev. 06/2005)Seated Document Trackit, 
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 
UNITED STATES' MOTION TO FILE OVERSIZED RESPONSE TO MOTION TO QUASH 
Party Filing Matter Under Seal 
On behalf of (select one): 
SEALED DOCUMENT TRACKING FORM 
Name: 
U.S. Attorney's OlSee 
C.71 
-r1 
rn 
O 
w 
Address: 500 S. Australian Ave. Suite 400, West Palm Beach, FL 33401 
Telephone: 
0 Plaintiff 
El Defendant 
Date sealed document filed: 7/31 /2007 
If sealed pursuant to statute, cite statute: Fed. R Grin. 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 
0 Arrest of First Defendant 
O Case Closing 
0 Conclusion of Direct Appeal 
ID Other:  
El 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 
0 
Destroyed 
Returned to the party or counsel for the party, as identified above 
Attorney for: Movant UnitUStates of America 
EFTA00179140

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) 
UNITED STATES' UNOPPOSED MOTION FOR PERMISSION TO FILE 
OVERSIZED RESPONSE TO MOTION OF JEFFREY EPSTEIN 
TO INTERVENE AND TO OUASH GRAND JURY SUBPOENAS 
AND CROSS-MOTION TO COMPEL 
UNDER SEAL 
EFTA00179141

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 
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 
The United States, by and through the undersigned Assistant United States Attorney, hereby 
files this Motion for Permission to File an Oversized Response, and, in support thereof, states: 
1. 
Movant Jeffrey Epstein, by and through counsel, filed a Motion to Intervene and to 
Quash two grand jury subpoenas duces tecum on July 17, 2007. 
2. 
The Motion is thirty-nine (39) pages long and raises significant legal issues related 
to the enforceability of two grand jury subpoenas. 
3. 
The Response to the Motion is forty (40) pages long, which exceeds the page limit 
set forth in Local Rule 7.1(C)(2). 
4. 
For the foregoing reasons, the United States respectfully requests that the Court grant 
permission for the United States to file an oversized Response. 
5. 
Certification: Pursuant to Local Rule 88.9, the United States has conferred with 
EFTA00179142

counsel for Movant, who states that he has no objection to the granting of this motion. 
Respectfully submitted, 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
By 
Assistant Unitedlittorney 
Florida Bar No. 
500 South Australian Avenue, Suite 400 
West Palm Beach. FL 33401 
Telephone: 
Facsimile: 
E-mail: 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on July9/ , 2007, the foregoing document will be served via 
hand delivery on Attorney Roy Black, counsel for Jeffrey Epstein. The same document will be 
served on William Richey, counsel for William Riley and Riley Kiraly, via Federal Express. This 
document was not filed using CM/ECF because it is.beine filed under seal. 
3 
Assistant U.S. Attorney 
EFTA00179143

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 
4 
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 
Service via Federal Express 
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 
Service via Hand Delivery 
EFTA00179144

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
IN RE GRAND JURY SUBPOENAS 
FGJ 07-103(WPB) 
DUCES TECUM NUMBERS 
OLY-63 and OLY-64 
UNDER SEAL 
ORDER 
THIS CAUSE came before the Court on the United States of America's Motion for 
Permission to File Oversized Response. 
Upon review of the motion, it is hereby ORDERED AND ADJUDGED that good cause has 
been shown and the United States of America's motion is GRANTED. 
DONE AND ORDERED in chambers this 
day of , 2007, at West Palm Beach, 
Florida. 
KENNETH A. MARRA 
UNITED STATES DISTRICT JUDGE 
cc: 
AUSA 
Roy Black, Esq. 
William Richey, Esq. 
, West Palm Beach 
EFTA00179145

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 
ORDER 
THIS CAUSE came before the Court on the United States of America's Motion for 
Permission to File Ex Pane Affidavits in support of its Response to the Motion to Quash. 
Upon review of the motion, it is hereby ORDERED AND ADJUDGED that good cause has 
been shown and the United States of America's motion is GRANTED. 
DONE AND ORDERED in chambers this 
day of , 2007, at West Palm Beach, 
Florida. 
cc: 
AUSA 
Roy Black, Esq. 
William Richey, Esq. 
KENNETH A. MARRA 
UNITED STATES DISTRICT JUDGE 
West Palm Beach 
EFTA00179146