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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
noz , 233 F.3d 1117 (9th Cir. 2000); Hawkins v. Stables , 148 F.3d 379 (4th Cir. 1998); Motley v. Marathon Oil Co. , 71 F.3d 1547 (10th Cir. 1995); Christman v. Brauvin Realty Advisors, Inc. , 185 F.R.D. 251 (N.D. III. 1999). In making that showing, blanket assertions of the privilege are not proper—the a
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
ulloz , 233 F.3d 1117 (9th Cir. 2000); Hawkins I Stables , 148 F.3d 379 (4th Cir. 1998); Motley I Marathon Oil Co. , 71 F.3d 1547 (10th Cir. 1995); Christman I Brauvin Realty Advisors, Inc. , 185 F.R.D. 251 (N.D. III. 1999). In making that showing, blanket assertions of the privilege are not proper—the as
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
Mutioz, 233 F.3d 1117 (9th Cir. 2000); Hawkins v. Stables, 148 F.3d 379 (4th Cir. 1998); Motley v. Marathon Oil Co., 71 F.3d 1547 (10th Cir. 1995); Christman v. Brauvin Realty AdvisorS, Inc., 185 F.R.D. 251 (N.D. III. 1999). In making that showing, blanket assertions of the privilege are not proper—the a
Entities connected to both Riley and Christman

Jeffrey Epstein
PERSONLeon Black
PERSON
Donald Trump
PERSON
Scarlett Johansson
PERSON
Ghislaine Maxwell
PERSON
Joe Biden
PERSON
United States
LOCATION
Julie K. Brown
PERSONRoy Black
PERSON
Alan Dershowitz
PERSON
Marc Rich
PERSON
Department of Justice
ORGANIZATIONJack Goldberger
PERSON
Palm Beach Police Department
ORGANIZATION
Virginia Giuffre
PERSON
George W. Bush
PERSON
Michael Douglas
PERSONFBI
ORGANIZATION
Prince Andrew
PERSON
Prince Charles
PERSON