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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
would effectively insulate discoverable acts merely because they were enacted in the presence of an attorney.") (emphasis added). Just a month ago, the Second Circuit addressed this issue when a defendant tried to disqualify prosecutors who had seen four documents that the defense alleged were privileged. United
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
would effectively insulate discoverable acts merely because they were enacted in the presence of an attorney.") (emphasis added). Just a month ago, the Second Circuit addressed this issue when a defendant tried to disqualify prosecutors who had seen four documents that the defense alleged were privileged. United
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
ould effectively insulate discoverable acts merely because they were enacted in the presence of an attorney.") (emphasis added). Just a month ago, the Second Circuit addressed this issue when a defendant tried to disqualify prosecutors who had seen four documents that the defense alleged were privileged. -19- EF
from availability. Prosecutors Indict Leaders of Church With North Carolina Ties, Accused of Preying on Military The Fayetteville Observer (10/27, Riley) reported that leaders of the House of Prayer Church, including Rony Denis, Anthony Oloans, and others, have been indicted on charges of conspiracy
is attorneys plan to challenge parts of the grand jury process. Additional reporting was provided by the Las Vegas Review- Journal (10/27, Dillon). Second Circuit Upholds Keith Raniere Sex Cult Abuse Conviction Courthouse News Service (10/27, Stapley) reported that the Second Circuit Court of Appeals upheld NX
Entities connected to both Riley and Second Circuit

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
Julie K. Brown
PERSONthe Southern District
LOCATION
Donald Trump
PERSON
Michael Cohen
PERSONJane Doe
PERSONLeon Black
PERSON
Bradley Edwards
PERSON
Alan Dershowitz
PERSON
Supreme Court
ORGANIZATION
Virginia Giuffre
PERSON
George W. Bush
PERSON
New York
LOCATION
Scarlett Johansson
PERSON
Michael Jackson
PERSON
Southern District of New York
ORGANIZATION