UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE: GRAND JURY SUBPOENAS DUCES TECUM NUMBERS FGJ 07-103 (WPB) OLY-64 AND OLY-64 MOTION FOR LEAVE TO FILE SUPPLEMENTAL EX PARTE DECLARATION IN SUPPORT OF UNITED STATES' RESPONSE TO MOTION TO QUASH UNDER SEAL UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA IN RE: GRAND JURY SUBPOENAS DUCES TECUM NUMBERS FGJ 07-103 (WPB) OLY-64 AND OLY-64 / UNDER SEAL MOTION FOR LEAVE TO FILE SUPPLEMENTAL EX PARTE DECLARATION 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 a Supplemental ex parte Declaration 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 Declaration contains additional 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 Declaration is 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 importance." In re Grand Jwy Proceedings in Matter of Freeman , 708 F.2d 1571, 1576 (11th Cir. 1983) (extensive citation