Sent: Montle Ju 16. 2007 12-01 PM oy er Here is the thumbnail version: At the time of the execution of the state search warrant on Epstein's house, they found printers. keyboards. and computer screens. but no CPU's. We thought that the property manager had destroyed the corn ut •rs. He was interviewed pursuant to a Kustigur letter and said that he didn't do anything with them, and a private investigator came and took them away. Based upon his description. we determined that the private investigator was Paul Lavery. We subpoenaed Paul Lavery. who tried to assert a blanket attorney-client privilege/work product immunity. I informed his attorney that he would need to file a Motion to Quash. so he backed down and we did a brief interview with Laver). Lavery stated that he did get the equipment from Epstein's house and he gave it to William Riley, another private investigator. We then subpoenaed Riley. both in his individual capacity and as custodian of records for Riley Kiraly (his private investigator firm). The subpoenas and attachment are attached. The subpoenas ask for the computer equipment removed from Epstein's house and information related to his employment by Epstein (billing records, etc.) so we know when the items were removed from the house. Before I issued the subpoena to Lavery, I talked with the Duty Attorneys at OEO and at the Computer Crimes Section in DC. OEO advised that. as long as the private investigator had a separate office/business (i.e.. was not housed within an attorney's office and did not work exclusively for u particular attorney), OEO approval wasn't required, it should be treated like any other subpoena. This morning I re-reviewed the U.S. Attorney's Manual and it is clearly applicable only to attorneys' offices. I asked Computer Crimes if there was any prohibition on subpoenaing computer equipment. and the duty attorney said that would be fine if we did not believe that the computer evidence would be tampered with.