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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
m Epstein's home. The Fifth Amendment privilege "protects a person . . . against being incriminated by his own compelled testimonial communication." Fisher v. United States , 425 U.S. 391, 409 (1976). Thus, to receive Fifth Amendment protection, a person's statement or act must be: (1) compelled; (2) t
ney (or his agent) can use the attorney-client privilege to EFTA00211784 assert an act of production immunity on behalf of his client. See, e.g., Fisher , 425 U.S. at 402-04. Those circumstances do not apply here. In Fisher , the Supreme Court determined that a defendant does not suffer a Fifth Amen
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
m Epstein's home. The Fifth Amendment privilege "protects a person . . . against being incriminated by his own compelled testimonial communication." Fisher I United States , 425 U.S. 391, 409 (1976). Thus, to receive Fifth Amendment protection, a person's statement or act must be: (1) compelled; (2) te
ney (or his agent) can use the attorney-client privilege to EFTA00223000 assert an act of production immunity on behalf of his client. See, e.g., Fisher , 425 U.S. at 402-04. Those circumstances do not apply here. In Fisher , the Supreme Court determined that a defendant does not suffer a Fifth Amen
THE GOVERNMENT'S RESPONSE TO THE MOTION TO INTERVENE AND TO QUASH GRAND JURY SUBPOENAS AND CROSS MOTION TO COMPEL William Riley and Riley Kiraly ("Riley"). by and through undersigned counsel, file this Reply to the Response of the United States to the Motion of Jeffrey Epstein to Intervene and to Qu
Motion of Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross Motion to Compel to respond to the Government's assertions that Riley failed to appear before the grand jury.' The Government is mistaken. Riley's appearance before the grand jury was originally scheduled for July 10.
, Komspan & Stum 201 S. Biscayne Boulevard, Suite 1300 • Miami, Florida 33131. Phone: Fax • www.RoyBlack.com EFTA00178998 under the teaching of Fisher v. United States, 425 U.S. 391, 398 (1976), result in compelling testimony from Mr. Epstein himself, in violation of his right against self incrimi
Florida 33131 • Phone: • Fax: • vwov.RoyBlack.com EFTA00179002 incriminating effect". United States v. Doe, 465 U.S. 605, 612 (1984); see also Fisher, 425 U.S. at 410 ("the act of producing evidence in response to a subpoena . . . has communicative aspects of its own, wholly aside from the content
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
rom Epstein's home. The Fifth Amendment privilege "protects a person ... against being incriminated by his own compelled testimonial communication." Fisher v. United States, 425 U.S. 391, 409 (1976). Thus, to receive Fifth Amendment protection, a person's statement or act must be: (1) compelled; (2) te
ances, an attorney (or his agent) can use the attorney-client privilege to assert an act of production immunity on behalf of his client. See, e.g., Fisher, 425 U.S. at 402-04. Those circumstances do not apply here. In Fisher, the Supreme Court determined that a defendant does not suffer a Fifth Amendme
"he quickly found it for a price." According to the Plain Dealer, "The owner met City Councilman Tyrone Riley in a restaurant parking lot and handed Riley $5,000 in cash, money the FBI says was used to bribe Riley for his support," but "it was hardly a smooth transaction. Some of the bills fell during
he bills fell during the exchange, causing Riley to scramble to pick up the cash, the FBI said. Fearing a parking-lot camera might capture the deal, Riley returned the money and drove away, the agency said." The Plain Dealer adds that the FBI's "portrayal of Riley...underscored how he and his colleagu
f the US was "a muted celebration by people who are frustrated and strained, yet intriguingly, persistently hopeful about the future." According to Fisher, "A triple whammy of deadly disease, wholesale economic paralysis and a searing reckoning with racial inequality has largely canceled the nation's
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
from the EFTA00222987 Fifth Amendment, which "protects a person . . . again being incriminated by his own compelled testimonial communication." Fisher I United States , 425 U.S. 391, 409 (1976). Thus, to receive Fifth Amendment protection, the person's statement or act must be: (1) compelled; (2) t
ite model, still at large, to infiltrate the Hollywood party scene: "She would befriend the men, get the security codes to their homes and then send Riley in." Just before the 2004 Golden Globes, Francis returned to his Bel Air home as it was being robbed. The intruder Francis recently identified as R
custody and charged with burglary, robbery, and home invasion. This is an ongoing investigation." Asked if the cops were looking into whether or not Riley had pulled the heists at the homes of Hilton, Johnson and the others, Coleman said, "That's fair to say." Wacky lackeys AND you thought P. Diddy f
cMahan filed to divorce his fifth wife, and Linda moved out of the home she shared with her husband. McMahan began spending more time at the plush Fisher Island retreat he'd built for his hedge-fund clients. Linda moved into a nearby condo, leaving behind her career as a psychologist. Linda enjoyed
e Washington Post <https://www.washingtonpost.com/politics/2020/11/12/cybersecurity-202-biden- administration-could-mean-reset-us-war-tiktokk (11/12, Riley, 14.2M) reports that TikTok is "waiting on a federal judge to grant a 30-day extension on the sale as it awaits a government green light on the deal
r Ink Link (NH) <hftps://manchesterinklink.com/lawyer-pleads-guilty-to-taking-2-4-million-from- clients-through-money-laundering-wire-fraud/> (11/12, Fisher) reports from Concord, New Hampshire, "Former Manchester attorney John Allen pleaded guilty Thursday to charges of money laundering and wire fraud f
, the agency "said that the order `has been enjoined, and will not go into effect, pending further legal developments.' The Washington Post (11/12, Riley, 14.2M) reports that TikTok is "waiting on a federal judge to grant a 30-day extension on the sale as it awaits a government green light on the deal
sease Control and Prevention's guidelines.' New Hampshire Attorney Pleads Guilty To Money Laundering, Wire Fraud. Manchester Ink Link (NH) (11/12, Fisher) reports from Concord, New Hampshire, "Former Manchester attorney John Allen pleaded guilty Thursday to charges of money laundering and wire fraud
, the agency "said that the order `has been enjoined, and will not go into effect, pending further legal developments.' The Washington Post (11/12, Riley, 14.2M) reports that TikTok is "waiting on a federal judge to grant a 30-day extension on the sale as it awaits a government green light on the deal
sease Control and Prevention's guidelines:" New Hampshire Attorney Pleads Guilty To Money Laundering, Wire Fraud. Manchester Ink Link (NH) (11/12, Fisher) reports from Concord, New Hampshire, "Former Manchester attorney John Allen pleaded guilty Thursday to charges of money laundering and wire fraud
Entities connected to both Riley and Fisher

Jeffrey Epstein
PERSONLeon Black
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
Julie K. Brown
PERSON
Donald Trump
PERSON
Alan Dershowitz
PERSON
Scarlett Johansson
PERSON
Department of Justice
ORGANIZATION
Prince Andrew
PERSON
Joe Biden
PERSON
Eric Trump
PERSON
Alexander Acosta
PERSON
Supreme Court
ORGANIZATION
Wilbur Ross
PERSONJack Goldberger
PERSON
Marc Rich
PERSONMaria Farmer
PERSON
Virginia Giuffre
PERSON