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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
an attorney does not render everything he does for or with the client privileged." Gutter v. E.I. DuPont de Nemours and Co. , 1998 WL 2017926, *1 (S.D. Fl. May 18, 1998) EFTA00211785 (citations omitted). If an attorney (or his agent) was doing something other than rendering legal advice, neither 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 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
s an attorney does not render everything he does for or with the client privileged." Gutter I E.I. DuPont de Nemours and Co. , 1998 WL 2017926, *1 (S.D. Fl. May 18, 1998) EFTA00223001 (citations omitted). If an attorney (or his agent) was doing something other than rendering legal advice, neither the
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
nited States in evaluating that claim, but Epstein has objected to the production of those documents. -17- EFTA00179116 Co., 1998 WL 2017926, *1 (S.D. Fl. May 18, 1998) (citations omitted). If an attorney (or his agent) was doing something other than rendering legal advice, neither the attorney-client
Entities connected to both Riley and S.D. Fl

Jeffrey Epstein
PERSON
United States
LOCATION
Kenneth Marra
PERSON
Department of Justice
ORGANIZATIONJack Goldberger
PERSONFBI
ORGANIZATIONLeon Black
PERSON
Alexander Acosta
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATIONRobert C. Josefsberg
PERSON
Southern District of New York
ORGANIZATIONWeiss
PERSON
Alan Dershowitz
PERSONRoy Black
PERSON
Palm Beach Police Department
ORGANIZATION
George W. Bush
PERSON
Michael Douglas
PERSON
Marc Rich
PERSON
West Palm Beach
LOCATION