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r the witnesses to appear on July 10, 2007, but pursuant to an agreement between the parties, the appearance was moved to July 17, 2007. Neither Mr. Riley nor the records custodian appeared, and counsel for Jeffrey Epstein filed the instant motion on July 17, 2007, shortly before the 4:00 p.m. appeara
ises six arguments against the enforceability of the two grand jury subpoenas: first, that Epstein Fifth Amendment privilege bars the subpoenas to Riley and Riley Kiraly; second, that the subpoenas violate Epstein's Fourth, Fifth, and Sixth Amendment rights; third, that the subpoenas are unreasonable
s reasoning applies even when the documents or information are classified as "personal papers" rather than business documents. See United States v. Feldman , 83 F.3d 9, 14 (1st Cir. 1996) (defendant's letters of apology not protected because voluntarily prepared); In re Grand Jury Subpoena Duces Tecum ,
ww.washingtonpost.com/politics/2021/05/05kybersecurity-202-lawmakers- want-greater-resources-authorities-cisa-protect-critical-infrastructure/> (5/5, Riley, 10.52M) reports in its Cybersecurity 202 column that leading voices in Congress "say the nation's top cybersecurity agency needs better resources
akes/story? id=77505898> (5/5, 2.44M) reports after Kevin Fox of Wilmington, Illinois, was exonerated in the killing of his three-year-old daughter Riley, and five years after the murder, the FBI began investigating the case. FBI Special Agent Lori Warren "said the FBI started the investigation from s
://wwvv.nydailynews.com/news/nationaUny- texas-lawyer-dwi-balagia-fraud-cocaine-20210505-bt7uh4i6qzc2vc3zxq3mbxg5fi-stoty.html?outputType=amp> (5/5, Feldman, 2.51M) and the iHeartRadio <https://www.iheart.corn/content/2021-05-05-austins-dwi-dude- sentenced-to-prison-for-ripping-off-colombian-narcos/> (5/5
nch a 120-day review of cybersecurity challenges under her leadership." Lawmakers Seek More Funds, Authorities For CISA. The Washington Post (5/5, Riley, 10.52M) reports in its Cybersecurity 202 column that leading EFTA00135921 voices in Congress "say the nation's top cybersecurity agency needs bet
Investigation. ABC News (5/5, 2.44M) reports after Kevin Fox of Wilmington, Illinois, was exonerated in the killing of his three-year-old daughter Riley, and five years after the murder, the FBI began investigating the case. FBI Special Agent Lori Warren "said the FBI started the investigation from
and his associates held inside a Colombian prison with Segundo Villota Segura, who was facing extradition to Texas." The New Ynrk ['ally News (5/5, Feldman, 2.51M) and the jHeartRadin (5/5, 5.47M) website also cover Balagia's sentence. Drug Investigation Leads To Decade In Prison For Florida Man. The
Investigation. ABC News (5/5, 2.44M) reports after Kevin Fox of Wilmington, Illinois, was exonerated in the killing of his three-year-old daughter Riley, and five years after the murder, the FBI began investigating the case. FBI Special Agent Lori Warren "said the FBI started the investigation from
unch a 120-day review of cybersecurity challenges under her leadership." Lawmakers Seek More Funds, Authorities For CISA. The Washington Post (5/5, Riley, 10.52M) reports in its Cybersecurity 202 column that leading voices in Congress "say the nation's top cybersecurity agency needs better resources t
a and his associates held inside a Colombian prison with Segundo Villota Segura, who was facing extradition to Texas." The New York Daily News (5/5, Feldman, 2.51M) and the iHeartRadio (5/5, 5.47M) website also cover Balagia's sentence. Drug Investigation Leads To Decade In Prison For Florida Man. The
r the witnesses to appear on July 10, 2007, but pursuant to an agreement between the parties, the appearance was moved to July 17, 2007. Neither Mr. Riley nor the records custodian appeared, and counsel for Jeffrey Epstein filed the instant motion on July 17, 2007, shortly before the 4:00 appearance t
six arguments against the enforceability of the two grand jury subpoenas: first, that Epstein's act-of-production privilege bars the subpoenas to Riley and Riley Kiraly; second, that the subpoenas violate Epstein's Fourth, Fifth, and Sixth Amendment rights; third, that the subpoenas are unreasonable
is reasoning applies even when the documents or information are classified as "personal papers" rather than business documents. See United States I Feldman , 83 F.3d 9, 14 (1st Cir. 1996) (defendant's letters of apology not protected because voluntarily prepared); In re Grand Jury Subpoena Duces Tecum ,
r the witnesses to appear on July 10, 2007, but pursuant to an agreement between the parties, the appearance was moved to July 17, 2007. Neither Mr. Riley nor the records custodian appeared, and counsel for Jeffrey Epstein filed the instant motion on July 17, 2007, shortly before the 4:00 p.m. appeara
ses six arguments against the enforceability of the two grand jury subpoenas: first, that Epstein's Fifth Amendment privilege bars the subpoenas to Riley and Riley Kiraly; second, that the subpoenas violate Epstein's Fourth, Fifth, and Sixth Amendment rights; third, that the subpoenas are unreasonable
is reasoning applies even when the documents or information are classified as "personal papers" rather than business documents. See United States I Feldman , 83 F.3d 9, 14 (1st Cir. 1996) (defendant's letters of apology not protected because voluntarily prepared); In re Grand Jury Subpoena Duces Tecum ,
t is to these portions of the response to which this reply is directed. I. The first area which requires reply is the government's assertions that Riley simply failed, without notice and without excuse, to appear at the time scheduled for his grand jury appearance. See Response at 1, 5, 6 n.6. This
nued from July 10, 2007, until July 17, 2007, by agreement of the parties. On July 16, 2007, counsel for Epstein were informed by Deputy Chief that Riley did not have to appear physically before the grand jury if a motion to quash the subpoena was filed by Epstein before the end of the day on July 17
s reasoning applies even when the documents or information are classified as "personal papers" rather than business documents. See United States v. Feldman, 83 F.3d 9, 14 (1st Cir. 1996) (defendant's letters of apology not protected because voluntarily prepared); In re Grand Jury Subpoena Duces Tecutn,
Entities connected to both Riley and Feldman

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONLeon Black
PERSON
Scarlett Johansson
PERSON
United States
LOCATION
Donald Trump
PERSON
Alan Dershowitz
PERSON
Prince Andrew
PERSON
Department of Justice
ORGANIZATION
Joe Biden
PERSON
Julie K. Brown
PERSON
Alfredo Rodriguez
PERSON
George W. Bush
PERSON
Marc Rich
PERSONFBI
ORGANIZATION
Virginia Giuffre
PERSONEmmy Taylor
PERSONJack Goldberger
PERSON
Palm Beach Police Department
ORGANIZATION
New York
LOCATION