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

, blanket assertions of the privilege are not proper—the assertion must be made on a question-by-question and document-by-document basis. See, e.g., Nguyen I Excel Corp. , 197 F.3d 200 (5th Cir. 1999); Clarke' American Commerce Nat. Bank , 974 F.2d 127 (9th Cir. 1992); United StatesI White , 950 F.2d 426, 430 (7th C

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

ing; instead, a witness' claims of attorney-client privilege are tested by refusing to answer specific questions. Davis , 636 F.2d at 1039. See also Nguyen I Excel Corp. , 197 F.3d 200 (5th Cir. 1999); Clarke I American Commerce Nat. Bank , 974 F.2d 127 (9th Cir. 1992); United States I White , 950 F.2d 426, 430 (7th

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

ing; instead, a witness' claims of attorney-client privilege are tested by refusing to answer specific questions. Davis , 636 F.2d at 1039. See also Nguyen I Excel Corp. , 197 F.3d 200 (5th Cir. 1999); Clarke I EFTA00222938 American Commerce Nat. Bank , 974 F.2d 127 (9th Cir. 1992); United States I White , 950 F.2d