Epstein Secrets

OF PALM BEACH POLICE OFFICERS' MOTION TO QUASH SUBPOENAS AND/OR MOTION FOR PROTECTIVE ORDER Non-parties, former Town of Palm Beach Chief of Police Michael Reiter, Captain George le Detective Joseph , Detective Detective a, and the Town of Palm Beach Police Department Record Custodian (collectively 'Town

the Epstein duces tecum issued to the Records Custodian, which additionally seeks state grand jury testimony (No. 7) and personnel records of Chief Reiter and Detectives and (No. 19), the Epstein duces tecum served on the Town of Palm Beach Police Officers are identical. Epstein's extremely broad do

tment Record Custodian (collectively 'Town of Palm Beach Police Officers"), hereby move to quash the subpoena or for a protective order pursuant to Florida Rule of Civil Procedure 1.280(c) directing that discovery sought by the civil subpoenas for deposition issued by Plaintiff, B.B , and the cross-notices with subp

contemporaneous with this Motion: a. Deposition of Jeffrey Epstein (Ex. B); b. Deposition of (Ex. C); c. Deposition of Palm Beach Police Chief Reiter (Ex. D); d. Interrogatory responses of Plaintiff, B.B. (Ex. E); 13. Plaintiffs claim for Punitive Damages is further supported because Defendant

of (Ex. C); c. Deposition of Palm Beach Police Chief Reiter (Ex. D); d. Interrogatory responses of Plaintif

AMAGES Plaintiff, B.B., by and through undersigned counsel, and files this Motion for Leave to Amend Complaint to Seek Punitive Damages pursuant to Florida Rule of Civil Procedure 1.190(f) and F.S. § 768.72 and as grounds therefore, states as follows: R.I.C.O. 1. This is an action currently includes a cause of act

• • !iil .. . • i : ' i ' 1• I District:, spo S. Austtallari Ave., Ste. 400,West Palm Beach, FL 3314?1:(11;x: 5614820-8777); , • ir • 2' ' Michael i';;IcAnliffe,i'Esq;, and Judith Ste anon Arco, Esq., StutAtitsits ey's Office - West • : ' I I Palm Beach, 401 NoithI.)ixie Highway, Jut Palm B

TEIN, JEFFREY E, Defendant. 1VIOTION TO INTERVENE AND SUPPORTING MEMORANDUM OF LAW COMES NOW, Applicant, B.B. and requests this Court, pursuant to Florida Rule of Civil Procedure 1.230, for leave to intervene as a party in Mr. Epstein's criminal matter for the following reasons: 1. Applicant's intervention is in