EFTA00178967

:4/17/2007 
:4L FM Mal: 1/1 Y 1, am L. Richey, P Yiliiaa L. Richey, P.A. 
TO: 5
PAGE: 002 OF 00; 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
FGJ 07-103 (WPB) 
IN RE GRAND JURY SUBPOENAS 
DUCES TECUM NUMBERS 
FILED UNDER SEAL 
OLY-63 & OLY-64 
REPLY OF WILLIAM RILEY AND RILEY KIRALY TO 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 
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. 2007. By 
the agreement of the parties. that appearance was rescheduled for July 17, 2007. The day before 
that scheduled appearance, i.e.. July 16. 2007. counsel for Jeffrey Epstein, who seeks to 
intervene in this matter, was informed by Deputy Chief 
that Riley did not have to 
appear physically before the grand jury if a motion to quash the subpoena at issue was filed by 
Epstein before the end of the day on July 17. 2007. As the Government's Response states. 
Epstein's motion to quash was filed on July 17, 2007 before the close of business. See Gov't 
Resp. at 1. Riley was informed of these matters by Roy Black, Esquire. and did not appear in 
reliance on the Government's agreement with Roy Black. 
I 
Undersigned counsel has been out of the country and just recently 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"; of 
FGJ 07-103 (WPB) 
Therefore, contrary to the Government's claim. Riley did not flout the subpoena. Rather. 
Riley's non-appearance was known by the Government. and Riley met the condition of that 
excuse, that is. Epstein timely filed the motion to quash. 
Respect fully submitted, 
WILLIAM I.. RICHEY. H.A. 
201 South Biscayne Boulevard 
344 Floor, Miami Center 
Miami. Florida 33131 
Tel: 
Fax: 
B 
William L. Riche'
Ha. Bar No. 
CERTIFICATE OF SERVICF, 
I hereby certify that on August 17. 2007, the foregoing document will be served via 
facsimile and U.S. Mail on counsel, as listed on the attached service list. This document was not 
filed using CM/ECF because it is bring filed under seal. 
011am . Richey 
William L Ridley, P.A. 
201 South Biscaync Bo deism, 34th Floor, Miami Center, Miami, Florida 33131-4325 • 
- Facsimile 
EFTA00178968

A/17/2007 ):101 114 FWII: Lis ),1( am L. Pachty, P William L. luchey, P.A. TO: ( 
PAGE: 0.: 
Service List 
In re: Grand Jury Subpoenas 
FOJ 07-103 (WPB) 
United States District Court, Southern District of Florida 
Assistant US Attorney 
500 South Australian Avenue. Suite 400 
West Palm Beach, Florida 33401 
Fax: 
Roy Black. Esquire 
Black Srebnick Kornspan & Stumpf 
201 South Biscayne Boulevard, Suite 1300 
Miami Florida 33131 
Fax: 
-3-
William I.. Richey, RA. 
201 South Biscayne Bottlevant, 34th Floor, Miami Center, Miami, Florida 33131-43a1 
FGJ 07-103 (WPII) 
- Facsimile 
EFTA00178969

x/1./2007 ):27 PM FROM: WiTliAm L. Richey, P William L. Richey, P.A. TO: .,mmin
 
FADE: 002 OF 00'. 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
FGJ 07-103 ( WPB) 
IN RE GRAND JURY SUBPOENAS 
DUCES TECUM NUMBERS 
OLY-63 & OLY-64 
FILED UNDER SEAL 
MOTION OF 
AND I 
FOR AN 
EXTENSION OF TIME NUNC PRO TUNC TO FILE THEIR REPLY 
ME arid 
('`_'1. 
by and through undersigned counsel, 
respectfully request for an enlargement of time. mine pro tune, to file their Reply to the 
Government's Response to the Motion to Intervene and to Quash Grand Jury Subpoenas and 
Cross Motion to Compel. In support thereof. 
states as follows: 
I. 
Undersigned counsel has been out of the country recently, only returning on 
August I I, 2007. By that time, the time to reply to the Government's Response to the Motion of 
Jeffrey Epstein to Intervene and to Quash Grand Jury Subpoenas and Cross Motion to Compel 
had already expired. 
2. 
Undersigned counsel received a copy of the Reply tiled by Jeffrey Epstein 
yesterday, August 16. 2007. Counsel has now reviewed that filing. along with the Government's 
response. 
3. 
reply is being filed concurrently with this request for an extension of time. 
4. 
Counsel attempted to contact the AUSA in this case to determine whether she 
would consent to the relief requested herein, however. she is unavailable until next Thursday. 
August 23, 2007. Accordingly, to prevent further delay, this request is being tiled at this time. 
5. 
This request is not made for the purpose of delay. 
EFTA00178970

3/11/200' )::7 PH FROM: William L. Richey, P William L. Richey, P.A. TO; 1-S61-802-17A7 
FAG 6: 00) OF on!. 
Pal 07-103 (W1>E1) 
WHEREFORE 
and 
respectfully request that the Court enter 
an order granting them art extension of time nunc pro rune to file their Reply to the 
Government's Response to the Motion to Intervene and to Quash Grand Jury Subpoenas and 
Cross Motion to Compel. 
Respect(Idly submitted. 
WILLIAM L. RICHEY, P.A. 
201 South Biscayne Boulevard 
34th Floor. Miami Center 
Miami. Florida 33131 
William L. Rib
Ha. Bar No. 
CERTIFICATE OF SERVICE 
I hereby certify that on August 17. 2007. the foregoing document will he served via 
facsimile and U.S. Mail on counsel, as listed on the attached service list. This document was not 
filed using CM/ECI because it is being filed under seal. 
illiam L. Richey 
cl
L Richey, P.A. 
201 South Biscayne Boulevard, 34th Floor, Miami Center, Miami, Florida 3.3131-1323 
- Facsimile 
EFTA00178971

8/10/2007 ):27 PM 
FROM: Wslp an L. Richey, 1, William L. Richey, P.A. 
TO: '-561-802-1787 
PAGE: 000 OF 
FGJ 07-103 (WPB) 
Service List 
In re: Grand Jury Subpoenas 
FOJ 07-103 (WPB) 
United States District Court, Southern District of Florida 
Assistant US Attorney 
500 South Australian Avenue. Suite 400 
West Palm Beach Florida 33401 
Fax: 
Roy Black. Esquire 
Black Srebnick Komspan & Stumpf 
201 South Biscayne Boulevard, Suite 1300 
Miami Florida 33 
1 
Fax: 
William 1.. Whey, P.A. 
201 South Biscayne Boulevard. 34th Floor, Miami Center, Miami, Florida 331M-4325 • 
Facsimile 
EFTA00178972

A/1/200, ):27 PM !Roll: W11•'am L. Richey, P Uilliam L. ktchwf, P.A. TO: • WIIIINES? 
( 
PAGE: Oin OF 00!. 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
RU 07-103 (WPB) 
IN RE GRAND JURY SUBPOENAS 
DUCES TECUM NUMBERS 
OLY-63 & OLY-64 
FILED UNDER SEAL 
ORDER GRANTING MOTION OF1 
' AND 
FOR AN EXTENSION OF TIME NUNC PRO TUNC TO FILE THEIR REPLY 
THIS CAUSE came before the Court on the Motion of_, 
for an Extension of Time Nom Pro Tune to File Their Reply. Upon review of the Motion. it is 
hereby: 
ORDERED AND ADJUDGED that the Motion is GRANTED. The Reply of la 
MI and Mel to the Govenunent's Response to the Motion to Intervene and to Quash 
Grand Jury Subpoenas and Cross Motion to Compel is deemed timely filed. 
DONE AND ORDERED in chambers this 
day of 
, ')007, at 
West Palm Beach. Florida. 
KENNETH A. MARRA 
UNITED STATES DISTRICT JUDGE 
cc: 
William L. Richey. Esquire 
Roy Black. Esquire 
EFTA00178973

(Rev. 06/2005)Sealcd Document Tracking Form 
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UNITED STATES DISTRICT COURT 
Southern District of Florida 
Case Number:  
RIO" 01 - Io 3 6,0 
In ire e rand Jury Plaintiff 
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K Returned to the party or counsel for the party, as identified above 
SEALED DOCUMENT TRACKING FORM 
Name:  
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Address: 
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EFTA00178974

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
IN RE GRAND JURY SUBPOENAS 
DUCES TECUM NUMBERS 
) 
CASE No. FGJ 07-103(WPB) 
OLY-63 and OLY-64 
UNDER SEAL 
EFTA00178975

UNDER SEAL 
NOTICE OF UNAVAILABILITY OF COUNSEL FOR INTERVENOR 
Jeffrey Epstein has moved to intervene in this matter and to quash grand jury 
subpoenas to investigator 
and his firm, 
Mr. Epstein is 
represented by undersigned counsel Roy Black. 
The issues raised by the motions to intervene and to quash have been briefed 
and the parties await a hearing date from the Court. Undersigned counsel would like 
to inform the Court that he is out of the jurisdiction on a family vacation until 
September 1, 2007. We respectfully request that any hearing the Court may 
scheduled in this matter be scheduled after September 1, 2007, at the Court's 
discretion. Undersigned counsel spoke with the prosecutor, who indicated that the 
government objects. 
Respectfully Submitted, 
BLACK, SREBNICK, KORNSPAN & STUMPF, PA. 
201 South Biscayne Boulevard 
Suite 1300 
Miami Florida 33131 
Ph: 
— Fax: 
E-Mail: 
By:  
BLACK, 
ffot
R 
BLACK, ESQ. 
Florida Bar No. 
Counsel for Jeffrey Epstein 
2 
Black. Srebnkk. Komspan & Stumpf 
2015. Biscayne Boulevard. Suite 1300 • Miami. Florida 33131 • Phone: 305-371-6421 • Fat 
•www.Royffiack.corn 
EFTA00178976

CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on  Ihtri. 14.O.00*  a true and correct copy of the 
forging motion was furnished by email and by U.S. mail to: 
United States Attorney's Office, 500 South 
Australian Avenue, Suite 400, West Palm Beach, FL 33401. 
This pleading was not filed using the CM/ECF system because it pertains to a 
grand jury investigation and therefore it has been filed under seal. 
By: 
 
vezzczia4 Fop-
ROY ilLACK, ESQ. 
Counsel for Jeffrey Epstein 
3 
Black. Srebnick. Komspan & Stum f 
2015. Biscayne Boulevard. Suite 1300 • Miami. Florida 33131 • Phone: 
• Fax: 
• www.RoyBlack.com 
EFTA00178977

e/7/2007 2:01 PH FROM: Wally %. Richey. P William L. Richey. P.A. TO: 
PAGE: 002 01" 002 
August 7, 2007 
Assistant US Attorney 
500 South Australian Avenue, Suite 400 
West Palm Beach, Florida 33401 
RE: 
Grand Jury Subpoena 
CASE NO. FGJ 07-103(WPB)/No. OLY-64 
Dear Ms. 
Miami Office 
Via Facsimile No. 
Please accept this letter as notice that 
will be out of town (tom 
August 13,2007 through August 15, 2007 and both Mr. 
and I will be out of town 
from September 5, 2007 through September 16, 2007. 
If you wish to schedule anything, please be so kind as to contact my assistant, • 
Linda Vasserot and she will be glad to coordinate dates with you. 
Sincerely, 
William L. Richey 
Transcnbed as Dictated.• 
Minted & Approved for Electronic 
Transmission Absent Signature 
WLR/ dct 
EFTA00178978

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 South Australian Ave.. Suite 400 
ch, FL 3340! 
Facsimile: 
VIA FACSIMILE 
Roy Black, Esq. 
Black Srebnick Komspan & Stumpf P.A. 
201 S. Biscayne Blvd, Suite 1300 
Miami, FL 33131 
Re: 
Correspondence Dated July 13. 2007 
Dear Mr. Black: 
July 16, 2007 
Thank you for your letter of July 13, 2007. You and your firm are neither a subpoenaed party 
nor counsel to a subpoenaed party. Accordingly, pursuant to the Federal Rules of Criminal 
Procedure, I am not at liberty to discuss this matter with you. Moreover, it is not the practice of this 
Office to discuss internal Department of Justice policies with non-Justice Department personnel. 
If Mr. 
believes he has cause to move to quash the subpoena, or if Mr. Epstein does for that 
matter, counsel for the respective parties should so move. Otherwise, we expect compliance by 
tomorrow, which includes a one-week extension already requested by Ms. Sanchez prior to Mr. 
Richey's appearance as counsel for Mr...I 
cc: 
 
, Esq. 
William Richey, Esq. 
Lilly Ann Sanchez, Esq. 
B 
Sincerely, 
R. Alexander Acosta 
Assistant United States Attorney 
EFTA00178979

U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 South Australian Ave., Suite 400 
ch, FL 33401 
Facsimile: 
VIA FACSIMILE 
William L. Richey, Esq. 
William L. Richey, P.A. 
201 S. Biscayne Blvd, 34th Floor 
Miami, FL 33131 
Re: 
I
SARglatilMill 
July 16, 2007 
Dear Mr. Richey: 
I have not received a motion to quash the subpoena served upon Mr.Mil, so I expect that 
your client will appear before the grand jury tomorrow 
fnow, I believe that his appearance will 
be at 4:00 p.m. but
 contact my assistant 
, later this morning for confirmation of 
the start time.l.= 
can be reached at 
cc: 
Esq. 
By: 
Sincerely, 
R. Alexander Acosta 
United States Attorney fn
A 
Assistant United States Attorney 
EFTA00178980

U.S. Departm 
of Justice 
United States Attorney 
Southern District of Florida 
500 S. Australian Ave, 4th Floor 
Wes Palm B ch, Florida 33401 
Facsimile 
FACSIMILE COVER SHEET 
TO: 
Roy Black, Esq. 
DATE: 
July 16.2007 
FAX NO. 
_ 
# OF PAGES:  
2
PHONE NO. _ 
RE: 
FROM: 
PHONE NO. 
, Assistant U.S. Attorney 
COMMENTS: 
EFTA00178981

U.S. Departni, 
of Justice 
United States Attorney 
Southern District of Florida 
500 S. Australian Ave, 4th Floor 
lm B ch, Florida 33401 
Facsimile 
FACSIMILE COVER SHEET 
TO: 
Lilly Ann Sanchez 
DATE: 
July 16, 2007 
FAX NO. 
PHONE NO. 
# OF PAGES:  
2
RE: 
FROM: 
PHONE NO. 
, Assistant U.S. Attorney 
COMMENTS: 
EFTA00178982

U.S. Departni 
of Justice 
United States Attorney 
Southern District of Florida 
500 S. Australian Ave, 4th Floor 
IVe • 
Beach, Florida 33401 
Facsimile 
FACSIMILE COVER SHEET 
TO: 
William L. Richey. Esq. 
DATE: 
July 16, 2007 
FAX NO. 
# OF PAGES:  
3
PHONE NO. _ 
RE: 
FROM: 
PHONE NO. 
Assistant U.S. Attorney 
COMMENTS: 
EFTA00178983

07/16/2007 09:33 FAX 
USA0 WPB FL 
0001 
TRANSMISSION OK 
TX/RX NO 
CONNECTION TEL 
SUBADDRESS 
CONNECTION ID 
ST. TIME 
USAGE T 
PGS. SENT 
RESULT 
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TX REPORT 
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********************* 
0076 
07/16 09:32 
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OK 
U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 S. Australian Ave, 4th Floor 
ch, Florida 33401 
Facsimile 
FACSIMILE COVER SHEET 
TO: 
William L. Richey. Esq. 
DATE: 
July 16, 2007 
FAX NO. 
# OF PAGES: 
PHONE NO. 
RE: 
3 
FROM: 
PHONE NO.
, Assistant U.S. Attorney 
COMMENTS: 
EFTA00178984

07/16/2007 09:31 FAX 
MAO WPB FL 
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TX/RX NO 
CONNECTION TEL 
SUBADDRESS 
CONNECTION ID 
ST. TIME 
USAGE T 
PCS. SENT 
RESULT 
********************* 
*** 
TX REPORT 
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********************* 
0075 
07/16 09:30 
01'00 
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OK 
U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
500 S. Australian Ave, 4th Floor 
West Palm Beach, Florida 33401 
Facsimile 
FACSIMILE COVER SHEET 
TO: 
Roy Black, Esq, 
DATE: 
July 16.2007 
FAX NO. 
# OF PAGES:  
2
PHONE NO. _ 
RE: 
FROM: 
PHONE NO. 
Assistant U.S. Attorney 
COMMENTS: 
EFTA00178985

07/16/2007 09:34 FAX 
USA0 %MB FL 
3***************3**** 
3** 
TX REPORT 
*** 
********************* 
TRANSMISSION OK 
TX/RX NO 
0077 
CONNECTION TEL 
SUBADDRESS 
CONNECTION ID 
ST. TIME 
07/16 09:33 
USAGE T 
00'52 
PGS. SENT 
2 
RESULT 
OK 
U.S. Department of Justice 
United States Attorney 
Southern District of Florida 
S00 S. Australian Ave. 4th Floor 
West Palm Beach, Florida 3340! 
(SO) 820-fi sm
Facsimile 
FACSIMILE COVER SHEET 
TO: 
Lilly Ann Sanchez 
DATE: 
July 16. 2007 
FAX NO. 
# OF PAGES:  
2
PHONE NO. _ 
RE: 
FROM: 
PHONE NO. 
Assistant U.S. Attorney 
COMMENTS: 
EFTA00178986