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

y have known about the United States' attempts to locate those computers for at least two months, when a subpoena for the same items was served upon Paul Lavery, another private investigator who worked with Riley. This is not a situation where failure to abide by the Court's rules should be tolerated. III.

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

refers to as warran ff i ce. F6 Through the FBI's investigation, it was determined that at some point before the execution of the search a l and Paul Lavery, a private investigator, traveled to Epstein's house and collected the computers, which were later turned over to William Riley, the subpoenaed part

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

y have known about the United States' attempts to locate those computers for at least two months, when a subpoena for the same items was served upon Paul Lavery, another private investigator who worked with Riley. This is not a situation where failure to abide by the Court's rules should be tolerated. III.

proved the subpoena. Andy and I met this morning and crafted a response (attached), which we sent to Roy and Lilly. I also sent a letter directly to Riley's attorney of record (also attached). Lilly faxed Andy asserting that my letter did not address their concerns. We just had a conference call and t

Lavery stated that he did get the equipment from Epstein's house and he gave it to William Riley, another private investigator. We then subpoenaed Riley. both in his individual capacity and as custodian of records for Riley Kiraly (his private investigator firm). The subpoenas and attachment are atta

anything with them, and a private investigator came and took them away. Based upon his description. we determined that the private investigator was Paul Lavery. We subpoenaed Paul Lavery. who tried to assert a blanket attorney-client privilege/work product immunity. I informed his attorney that he would ne

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

have known about the United States' attempts to locate those computers for at least two months, when a subpoena for the same items was served upon Paul Lavery, another private investigator who worked with Riley. This is not a situation where failure to abide by the Court's rules should be tolerated. III.

ose computers for at least two months, when a subpoena for the same items was served upon Paul Lavery, another private investigator who worked with Riley. This is not a situation where failure to abide by the Court's rules should be tolerated. EPSTEIN HAS FAILED TO ESTABLISH THAT THE ATTORNEY-CLIENT P

y have known about the United States' attempts to locate those computers for at least two months, when a subpoena for the same items was served upon Paul Lavery, another private investigator who worked with Riley. This is not a situation where failure to abide by the Court's rules should be tolerated. EPSTE

n Miami, Florida. Attached hereto as Exhibit K-1 are copies of printouts from the Riley Kiraly website, explaining the services offered. Neither Mr. Riley nor Riley Kiraly works exclusively for Roy Black or any other lawyer or law firm. 13. I personally served the subpoenas on William Riley at his off

tein is aware of that classification at this time. From the physical description of the private investigator, I knew that Banasiak was referring to Paul Lavery, a private investigator who had traveled to the homes of several victims. 11. A grand jury subpoena was served on Mr. Lavery at his office in Miami.