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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
e 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
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
re a party fails to provide "sufficient facts to state with reasonable certainty that the privilege applies, the burden is not met." United States I Blackburn , 538 F. Supp. 1376, 1382 (M.D. Fl. 1982) (citing Federal Trade Commission I TRW Inc. , 628 F.2d 207, 213 (D.C. Cir. 1980); In re Katz , 623 F.2d 1
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
e 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 12
efend US-based public and private computer networks." Study Finds Cybercrime Rose As More Workers Went Virtual In 2020. The Washington Post (2/22, Riley, 10.52M) reports in its Cybersecurity 202 column that a new study from CrowdStrike found that "intrusions threatening organizations' cybersecurity a
kburn (R- TN) "cited remarks from former Director of National Intelligence John Ratcliffe...that China `poses the greatest threat to America today.' Blackburn asked Garland if he considered the Chinese Communist Party an `enemy' of the United States. `Well, I don't have the same familiarity with the intel
e's expected to lay out the department's cyber priorities." Lawmakers Seek Details Hackers Accessing Chad Wolf's Emails. The Washington Post (3/30, Riley, 10.52M) reports in its Cybersecurity 202 column that new details on the hacking of emails at DHS "emerge as Congress weighs legislation to address
r." The Hill (3/30, 5.69M) provides similar coverage of Warren's comments. Kentucky Lawmakers Pass Partial Ban On No-Knock Warrants. The AP (3/30, Blackburn) reports that the Kentucky state legislature on Tuesday "passed a partial ban on no-knock warrants...more than a year after the death of Breonna Tay
Entities connected to both Riley and Blackburn

Jeffrey Epstein
PERSONLeon Black
PERSON
Donald Trump
PERSON
Joe Biden
PERSON
Scarlett Johansson
PERSON
Ghislaine Maxwell
PERSON
Alfredo Rodriguez
PERSON
Julie K. Brown
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United States
LOCATION
Department of Justice
ORGANIZATION
Alan Dershowitz
PERSON
Marc Rich
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Bloomberg L.P.
ORGANIZATION
Prince Andrew
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Virginia Giuffre
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USA Today
ORGANIZATIONFBI
ORGANIZATIONJack Goldberger
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Eric Trump
PERSONThe New York Post
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