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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
tion of criminal evidence that forecloses [the defendant's] attorney-client privilege argument . . ." Id. The district court addressed the cases of Clutchette v. Rushen, 770 F.2d 1469 (9th Cir. 1985), and People v. Meredith, 631 P.2d 46 (Cal. 1981). In Clutchette, the defendant's attorney had sent an inve
ry to the ability of Epstein's counsel to evaluate their significance; copies of the hard drives could have been made. Of course, unlike counsel in Clutchette and Meredith, Epstein's counsel never provided the evidence to law enforcement and, instead, tries to aver that the items may not exist. If that is
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
tion of criminal evidence that forecloses [the defendant's] attorney-client privilege argument . . ." Id. The district court addressed the cases of Clutchette v. Rushen , 770 F.2d 1469 (9th Cir. 1985), and People v. Meredith , 631 P.2d 46 (Cal. 1981). In Clutchette , the defendant's attorney had sent an in
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
The district court addressed the cases of Clutchette I Rushen , 770 F.2d 1469 (9th Cir. 1985), and People I Meredith , 631 P.2d 46 (Cal. 1981). In Clutchette , the defendant's attorney had sent an investigator to collect incriminating evidence from a shopkeeper, and the trial court had allowed that eviden
Entities connected to both Riley and Clutchette

Jeffrey Epstein
PERSONLeon Black
PERSON
Scarlett Johansson
PERSONRoy Black
PERSON
Alan Dershowitz
PERSON
United States
LOCATION
Palm Beach Police Department
ORGANIZATIONJack Goldberger
PERSON
Julie K. Brown
PERSONFBI
ORGANIZATIONEmmy Taylor
PERSONJoe Recarey
PERSONBarrett
PERSON
Alexander Acosta
PERSON
Bailey
PERSONSouthern District
LOCATION
Sarah Kellen
PERSON
Hunter Biden
PERSONGerald Lefcourt
PERSON
Thomas Rofrano
PERSON