Epstein Secrets

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.

ly returned. Accordingly, this Reply has been prepared within days of his return. William L Richey, P.A. 301 South 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";

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

case, be served upon it at the address set forth below. Respectfully submitted, WILLIAM L. RICHEY, P.A. 201 South Biscayne Boulevard 34th Floor, Miami Center Miami, Flori Telephon Facsim. E-Mail: ILL AM L. RICH Fla. Bar No. EFTA00179067 CERTIFICATE OF SERVICE I hereby certify that a true and corre

; 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

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 intended only for the use of the addressee and may contain in

,I/17/2007 3:)s Ill FP.Oli: William L. Richey, F William L. Richey, P.A. TO: 1- PAGE: 001 OF 00- FGJ 07.103 (WPB) William Riley and Riley Kiraly ("Riley"). by and through undersigned counsel, hereby move to seal the following filings: (I) this Motion; (2) the order granting this Motion; (3) the Moti

documents be sealed until further Order of this Court. Respectfully submitted, WILLIAM L. RICFIEY, P.A. 201 South Biscayne Boulevard 34". Floor, Miami Center Miami, Florida 33131 Tel: Fax: William L. RI. Fla. Bar No. William L Richey, P.A. 201 South Biscayne Boulevard. 34th Floor, Miami Center, Miam