Epstein Secrets

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

. F2In Bonner v. City of Prichard , 661 F.2d 1206 (11th Cir. 1981) ( en banc), the Eleventh Circuit adopted as precedent all decisions of the prior Fifth Circuit court of Appeals decided prior to October 1, 1981. FIThe Supreme Court called this "a novelty in criminal procedure with which we are wholly unacqu

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

ury. UIn Bonner1 City of Prichard , 661 F.2d 1206 (11th Cir. 1981) ( en banc), the Eleventh Circuit adopted as precedent all decisions of the prior Fifth Circuit court of Appeals decided prior to October 1, 1981. FIThe Supreme Court called this "a novelty in criminal procedure with which we are wholly unacqu

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

974 'In Bonner v. City of Prichard, 661 F.2d 1206 (11th Cir. 1981) (en bane), the Eleventh Circuit adopted as precedent all decisions of the prior Fifth Circuit court of Appeals decided prior to October 1, 1981. -8- EFTA00179107 F.2d 127 (9th Cir. 1992); United States v. White, 950 F.2d 426, 430 (7th Cir.

oes not defeat diversity." Shenkarl. Money Warehouse, Inc., No. 07-20634-CIV, 2007 WL 3023531, at *1 (S.D. Fla. Oct. 15, 2007) (Moreno, J.) (citing Riley'. Merrill Lynch, Pierce, Fenner & Smith, Inc., 292 F.3d 1334, 1337 (11th Cir. 2002)); accord, e.g., Tedder F.M.C. Corp., 590 F.2d 115, 117 (5th Cir

hard, 661 F.2d 1206, 1207 (11th Cir. 1981) (en bane), the Eleventh Circuit Court of Appeals adopted as binding precedent all decisions of the former Fifth Circuit rendered prior to October 1, 1981. On February 20, 2008, the plaintiff was deposed in State of Florida'. Jeffrey Epstein, 502006CF009454 (Fla. 15t

com which also showed various cases in which they assisted. I also located another web site under www.coralspringssparklandrotary.org in which Mr. Riley attended a Miami Rotary meeting and confirmed Atty. Roy Black is among his clientele. air eves and ad telephone contact with either just after

, 661 F.2d 1206, 1207 (11th Cir. 1981) (en banc), the ----E4eventh-Gireuit-Geurt-ef-Appeels-adepted-as-binding-preeedent-aIl dwisiuns of 3ho former Fifth Circuit rendered prior to October 1, 1981. 9 L.exylCrsin FL 3039 Gomm Mout. Sum 340. Coccoon Goon, Fos 33133 1@1311 EFTA00231021 Case 9:08-cv-80804-KA