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

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

o. OLY-63 and OLY-64 United States District Court, Southern District of Florida Assistant U.S. Attorney Attorney for United States EFTA00223014 William L. Richey, Esq. Attorney for Subpoenaed Parties Riley Kiraly and William Riley Service via Federal Express Roy Black, Esq. Attorney for Intervenor Jeffrey

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.

Biscayne Boulevard, 34th Floor, Miami Center, Miami, Florida 331314325 •---- Facsimile EFTA00178967 x/17/.:007 PH FRCII: VI: 1 ar L. Richey, P William L. Richey, P.A. TO:, ' • PAGE: 00"; of FGJ 07-103 (WPB) Therefore, contrary to the Government's claim. Riley did not flout the subpoena. Rather. Riley's n

L. Richey, P.A. Miami, FL 33131 Re: Subppena to William Riley Dear Mr. Richey: I have not received a motion to quash the subpoena served upon Mr. Riley, so I expect that your client will appear before the grand jury tomorrow. As of now, I believe that his appearance will be at 4:00 p.m., but please

tates Attorney Southern District of Florida 500 South Australian Ave., Suite 400 West Palm Beach, FL 33401 Facsimile: July 16, 2 VIA FACSIMILE William L. Richey, Esq. William L. Richey, P.A. Miami, FL 33131 Re: Subppena to William Riley Dear Mr. Richey: I have not received a motion to quash the subpoena

es filed by Witness William Riley and Intervenor Jeffrey Epstein, a and notes the following: I. Both the witness and the intervenor assert that Mr. Riley was excused from appearing before the grand jury and that Mr. Riley did not flout the subpoena by failing to appear. AUSA agreed with Attorney Mr.

211804 U.S. Attorney 5 s Office 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401 Telephonel Facsimile: I Attorney for United States William L. Richey, Esq. William L. Richey P.A Miami, Fl Telephon Facsimile: Attorney for Subpoenaed Parties Riley Kiraly and William Riley Service via U.S. Mail

; Subject: RE: Dates of Availability for William Riley I apologize, but the only date I have available in September is September 18, 2007. Both Mr. Riley and Mr. Richey will be out of the state on vacation for the first half of September and Mr. Richey has oral argument scheduled in the Third DCA on

e a date certain in our calendar. Thank you for your help. October 2, 2007 October 9, 2007 October 16, 2007 October 23, 2007 Danise Townsend William L. Richey, P.A. 201 South Biscayne Boulevard 34th Floor, Miami Center Miami, Florida 33131-4325 ATTORNEY-CLIENT PRIVILEGED INFORMATION This transmittal is