EFTA00179057¶
07/16/2007 09:46¶
BLACK SREB & KORN¶
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02¶
| ROY BLACK |
| HOWARD M. SREBNICK |
| SCOTT A. KORNSPAN |
| LARRY A. STUMPF |
| MARIA NEYRA |
| JACKIE PERCZEK |
| MARK A.; J. SHAPIRO |
| JARED LOPEZ |
BLACK SREBNICK KORNSPAN & STUMPF P.A.¶
CHRISTINE M. NO¶
JESSICA FONSECA-NADER¶
KATHLEEN P. PHILLIPS¶
AARON ANTHON¶
MARCOS BEATON, JR.¶
MATTHEW P. O’BRIEN¶
July 13, 2007¶
VIA FACSIMILE¶
AND U.S. MAIL¶
Esq.¶
Assistant United States Attorney¶
Office of the United States Attorney¶
Southern District of Florida¶
500 South Australian Avenue, Suite 400¶
West Palm Beach, Florida 33401¶
Re: Grand Jury Subpoena - William Riley¶
Dear Ms. Villifaña:¶
I represent Jeffrey Epstein, the target of a pending Grand Jury investigation. Prior to the initiation of this federal investigation, I represented Mr. Epstein on a Palm Beach Florida State Attorney’s Office investigation and subsequently an Information, the factual basis of which is identical to, and gave rise to, the federal investigation presently underway.¶
In connection with my earlier representation of Mr. Epstein, I hired Mr. William as a private investigator to act under my direction in anticipation of defending Mr. Epstein against possible criminal charges and any litigation which may have followed. All his investigations were done as my agent and thus are covered by the work product privilege, and all communications to him are protected by the attorney client privilege.¶
Though we are not conceding the existence of any computers that would be responsive to the subpoena served upon Mr. to the extent there are any such computers, they would contain documents that are privileged attorney-client communications and attorney work-product. Your subpoena also asks for materials describing the scope of his investigation and thus they are our work product.¶
201 S. Biscayne Boulevard, Suite 1300 • Miami, Florida 33131 • Phone:¶
EFTA00179058¶
07/15/2007 09:46¶
BLACK SREB & KORN¶
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As you know, the United States Attorney’s Office Manual, Guidelines for Issuing Grand Jury and Trial Subpoenas to Attorneys for Information Relating to the Representation of Clients, requires that the attorney client and work-product privileged information sought by the Grand Jury subpoena issued to Mr. Riley must first be authorized by the Assistant Attorney General for the Criminal Division before it may issue.¶
Therefore, please advise me as to whether the applicable sections of the United States Attorney’s Office Manual was complied with prior to the issuance of the Grand Jury subpoena to Mr. Riley. Please also advise as to the preliminary steps taken in advance of the issuance of the subpoena, as required by the Manual. Finally, please provide me with the name of the Assistant Attorney General of the Criminal Division who undertook the evaluation of the request for the Grand Jury subpoena, as required by the same section of the Manual and, if an evaluation was made, the basis upon which the Assistant determined that the information sought in the subpoena was not protected by a valid claim of privilege.¶
Sincerely,¶
RB/wg¶
Black, Srebnick, Kornspan & Stumpf, P.A.¶
EFTA00179059¶