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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
ses the witness from having to answer questions that call for responses covered by the privilege. See Roe v. Slotnick , 781 F.2d 238 (2d Cir. 1986); McKay v. C.I.R. , 886 F.2d 1237 (9th Cir. 1989). Accordingly, the United States asks the Court to compel the witnesses to appear before the grand jury on
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
uses the witness from having to answer questions that call for answers covered by the privilege. See Roe l. Slotnick , 781 F.2d 238 (2d Cir. 1986); McKay I C.I.R. , 886 F.2d 1237 (9th Cir. 1989). Accordingly, the United States asks the Court to compel the witnesses to appear before the grand jury on t
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
uses the witness from having to answer questions that call for responses covered by the privilege. See Roe I Slotnick , 781 F.2d 238 (2d Cir. 1986); McKay I C.I.R. , 886 F.2d 1237 (9th Cir. 1989). Accordingly, the United States asks the Court to compel the witnesses to appear before the grand jury on t
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
uses the witness from having to answer questions that call for responses covered by the privilege. See Roe v. Slotnick, 781 F.2d 238 (2d Cir. 1986); McKay v. C.I.R., 886 F.2d 1237 (9th Cir. 1989). Accordingly, the United States asks the Court to compel the witnesses to appear before the grand jury on
real- world dinic for practical learning." Report: Global Losses From Cybercrime Expected To Be Just Under $1T For 2020. The Washingtnn Pnct (12/7, Riley, 14.2M) reports, "Estimated global losses from cybercrime are projected to hit just under a record $1 trillion for 2020," according to a study from
rested in delivering something like that as quickly as possible." Reports: Iran's Supreme Leader May Have Transferred Power To Son. Fox News (12/7, McKay, 27.59M) reports that amid speculation "over the declining health of Iran's Supreme Leader, the Grand Ayatollah Ali Khamenei," there were "unconfirm
gton Post <https://www.washingtonpost.com/politics/2020/12/07/cybersecurity-202-global-losses- cybercrime-skyrocketed-nearly-1-trillion-2020/> (12/7, Riley, 14.2M) reports, "Estimated global losses from cybercrime are projected to hit just under a record $1 trillion for 2020," according to a study from
e Transferred Power To Son. Fox News <https://www.foxnews.com/world/is-irans-supreme-leader-preparing-to-designate-his-son-as-the- successor> (12/7, McKay, 27.59M) reports that amid speculation "over the declining health of Iran's Supreme Leader, the Grand Ayatollah Ali Khamenei," there were "unconfirm
real-world clinic for practical learning." Report: Global Losses From Cybercrime Expected To Be Just Under $1T For 2020. The Washington Post (12/7, Riley, 14.2M) reports, "Estimated global losses from cybercrime are projected to hit just under a record $1 trillion for 2020," according to a study from
ested in delivering something like that as quickly as possible." Reports: Iran's Supreme Leader May Have Transferred Power To Son. Fox News (12/7, McKay, 27.59M) reports that amid speculation "over the declining health of Iran's Supreme Leader, the Grand Ayatollah Ali Khamenei," there were "unconfirm
charge Michael Riley, a Capitol Police officer, for seeking to obstruct the investigation into the attack. According to the article, prosecutors say Riley, who didn't know Hiles but shared an interest in fishing, sent Hiles Facebook messages urging him to delete incriminating posts about entering the
dn't be used in vaccinated people, who weren't part of Merck's research and haven't been shown to benefit!' The Wall Street Journal (11/30, Hopkins, McKay) reported that according to a final analysis, the drug was found to be 30% effective at reducing the risk of hospitalization and death in high-risk
Entities connected to both Riley and McKay

Jeffrey Epstein
PERSONLeon Black
PERSON
Donald Trump
PERSON
Joe Biden
PERSON
Scarlett Johansson
PERSON
Ghislaine Maxwell
PERSON
Julie K. Brown
PERSON
Department of Justice
ORGANIZATION
United States
LOCATION
Alfredo Rodriguez
PERSONFBI
ORGANIZATION
Virginia Giuffre
PERSON
USA Today
ORGANIZATION
Prince Andrew
PERSON
Bloomberg L.P.
ORGANIZATION
Alan Dershowitz
PERSON
Michael Jackson
PERSON
Marc Rich
PERSON
Prince Charles
PERSONEmmy Taylor
PERSON