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

rand Jury Subpoena Duces Tecum , 1 F.3d 87, 90 (2d Cir. 1993) (defendant's personal calendar not protected because voluntarily prepared); Barrett v. Acevedo , 169 F.3d 1155, 1168 (8th Cir. 1999) (defendant's journal not protected because voluntarily written); United States v. Witylcowski , 929 F.2d 981,

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

Grand Jury Subpoena Duces Tecum , 1 F.3d 87, 90 (2d Cir. 1993) (defendant's personal calendar not protected because voluntarily prepared); Barrett I Acevedo , 169 F.3d 1155, 1168 (8th Cir. 1999) (defendant's journal not protected because voluntarily written); United States I Wuykowski , 929 F.2d 981, 983

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

Grand Jury Subpoena Duces Tecum , 1 F.3d 87, 90 (2d Cir. 1993) (defendant's personal calendar not protected because voluntarily prepared); Barrett I Acevedo , 169 F.3d 1155, 1168 (8th Cir. 1999) (defendant's journal not protected because voluntarily written); United States I Wirykowski , 929 F.2d 981, 98

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.

d vitality of Boyd with respect to personal documents. In re Grand Jury Investigation, 921 F.2d 1184, 1187 n.6 (11th Cir. 1991). And see Barrett v. Acevedo, 169 F.3d 1155, 1167 58th Cir. 1999) ("whether Doe's rationale extends to purely personal papers in a defendant's possession is still open to some d

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

and Jury Subpoena Duces Tecutn, 1 F.3d 87, 90 (2d Cir. 1993) (defendant's personal calendar not protected because voluntarily prepared); Barrett v. Acevedo, 169 F.3d 1155, 1168 (8th Cir. 1999) (defendant's journal not protected because voluntarily written); United States v. Wuykowski, 929 F.2d 981, 983