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used them. F15 See, e.g., United States v. Doe , 465 U.S. 605, 612 (1984); In re Grand Jury Proceedings , 393 F.3d 905, 909 (9th Cir. 2004); In re Foster , 188 F.3d 1259, 1269 (10th Cir. 1999). This reasoning applies even when the documents or information are classified as "personal papers" rather tha
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
m. EFTA00222988 See, e.g., United States' Doe , 465 U.S. 605, 612 (1984); In re Grand Jury Proceedings , 393 F.3d 905, 909 (9th Cir. 2004); In re Foster , 188 F.3d 1259, 1269 (10th Cir. 1999). This reasoning applies even when the documents or information are classified as "personal papers" rather tha
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
ho used them. F15 See, e.g., United States' Doe , 465 U.S. 605, 612 (1984); In re Grand Jury Proceedings , 393 F.3d 905, 909 (9th Cir. 2004); In re Foster , 188 F.3d 1259, 1269 (10th Cir. 1999). This reasoning applies even when the documents or information are classified as "personal papers" rather tha
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
s who used them.15 See, e.g., United States v. Doe, 465 U.S. 605, 612 (1984); In re Grand Jury Proceedings, 393 F.3d 905, 909 (9th Cir. 2004); In re Foster, 188 F.3d 1259, 1269 (10th Cir. 1999). This reasoning applies even when the documents or information are classified as "personal papers" rather than
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
acility For Children. The Washington Post (2/22, Foster-Frau, 10.52M) reports that "dozens of migrant tee
efend US-based public and private computer networks." Study Finds Cybercrime Rose As More Workers Went Virtual In 2020. The Washington Post (2/22, Riley, 10.52M) reports in its Cybersecurity 202 column that a new study from CrowdStrike found that "intrusions threatening organizations' cybersecurity a
New Hampshire Man Sentenced Over Bank Robbery. Foster's Daily Democrat (NH) (1/26, 13K) reports Thomas
The repercussions of the SolarWinds hack "are still being unraveled." Vaccine Distribution Creates Cybersecurity Risks. The Washington Post (1/26, Riley, 10.52M) reports in its 'Cybersecurity 202' column that security experts and government officials are "bracing for a wave of cyberattacks targeting
going to be really, really important." Hundreds Of ICUs Straining For Resources Due To High Number Of Patients With COVID. The AP (1/24, Johnson, Forster) reports that as they confront a high number of patients with COVID, hundreds of ICUs in the US, mainly in the South and the West, "are running out
ent session; 10:00 AM • Court hearing for woman accused of helping steal Dem Rep. Nancy Pelosi's laptop (virtual) - Virtual court hearing held for Riley June Williams, accused of theft, obstruction and trespassing, as well as violent entry and disorderly conduct on U.S. Capitol grounds * Williams is
ccountability." The Washington Post (4/25, Iati, Foster-Frau, Bellware, 10.52M) looks at how Minneapolis
summit between the two leaders." EFTA00149780 White House Cyber Director Nominee Seeks Closer Ties To Private Sector. The Washington Post (4/23, Riley, 10.52M) reported in its Cybersecurity 202 column that, "in one of his first public appearances since being nominated as White House cyber director,
a suspect's boyfriend" in Eastpointe, MI. Jason Foster was shot in his car in December. All of the suspe
e's expected to lay out the department's cyber priorities." Lawmakers Seek Details Hackers Accessing Chad Wolf's Emails. The Washington Post (3/30, Riley, 10.52M) reports in its Cybersecurity 202 column that new details on the hacking of emails at DHS "emerge as Congress weighs legislation to address
Entities connected to both Vince Foster and Riley

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSONLeon Black
PERSON
Donald Trump
PERSON
Julie K. Brown
PERSON
Scarlett Johansson
PERSON
Alan Dershowitz
PERSON
Marc Rich
PERSON
Virginia Giuffre
PERSON
Joe Biden
PERSON
United States
LOCATION
Bill Clinton
PERSON
Prince Charles
PERSON
Michael Jackson
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
Michael Douglas
PERSON
Stephen Hawking
PERSON