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 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

that, when dissected, do not apply to the subpoenaed items. The first issue is whether the act of production privilege applies to William Riley's or Riley Kiraly's production of the computers removed from Epstein's home. The act of production privilege derives from the EFTA00222987 Fifth Amendment, which "pr

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

ling records is overly burdensome. Furthermore, Riley Kiraly is the owner of those documents and is best suited to make such a claim, if warranted. Riley Kiraly's failure to do so before the time for production waives such a claim. -4- EFTA00179089 CONCLUSION For the foregoing reasons, as well as the reason

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.

lling records is overly burdensome. Furthermore, Riley Kiraly is the owner of those documents and is best suited to make such a claim, if warranted. Riley Kiraly's failure to do so before the time for production waives such a claim. CONCLUSION For the foregoing reasons, as well as the reasons set forth in the