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assertion of privilege is improper Request No. 1. The ENTIRE FILE (including all discovery) provided to you by the State Attorney's Office, and/or Palm Beach County Police Department and/or U.S. Attorney's Office and/or the Federal Bureau of Investigation relating to the Defendant, JEFFREY EPSTEIN. Response: Defendant is assert
rious facts have asked whether the government was aware of the documents' existence apart from any actions of the defendant. Thus, United States v. Hubbell, 530 U.S. 27 (2000), rejected the Government's argument that it was a foregone conclusion that the defendant possessed "ordinary business records."
ctims identified. F2 Epstein's counsel is correct, however, in asserting that Epstein's criminal conduct first came to the attention of the FBI when the City of Palm Beach Police Department became concerned about the manner in which the Palm Beach County State Attorney's Office was handling the state prosecution. The investigation of t
(4th Cir. 1991) (Fifth Amendment does not protect the contents of voluntarily prepared documents, whether business or personal); United States v. Hubbell , 167 F.3d 552, 567 (D.C. Cir. 1999) (same), aff'd on other grounds , 530 U.S. 27 (2000); In re Grand Jury Proceedings , 759 F.2d 1418, 1419 (9th Ci
ctims identified. fi Epstein's counsel is correct, however, in asserting that Epstein's criminal conduct first came to the attention of the FBI when the City of Palm Beach Police Department became concerned about the way the Palm Beach County State Attorney's Office was handling the matter. The investigation of the Palm Beach Police De
3 (4th Cir. 1991) (Fifth Amendment does not protect the contents of voluntarily prepared documents, whether business or personal); United States I Hubbell , 167 F.3d 552, 567 (D.C. Cir. 1999) (same), aff 'd on other grounds , 530 U.S. 27 (2000); In re Grand Jury Proceedings , 759 F.2d 1418, 1419 (9th C
ctims identified. F2 Epstein's counsel is correct, however, in asserting that Epstein's criminal conduct first came to the attention of the FBI when the City of Palm Beach Police Department became concerned about the manner in which the Palm Beach County State Attorney's Office was handling the state prosecution. The investigation of t
3 (4th Cir. 1991) (Fifth Amendment does not protect the contents of voluntarily prepared documents, whether business or personal); United States I Hubbell , 167 F.3d 552, 567 (D.C. Cir. 1999) (same), aff'd on other grounds , 530 U.S. 27 (2000); In re Grand Jury Proceedings , 759 F.2d 1418, 1419 (9th Ci
ACCREDITED LAW ENFORCEMENT AGENCY July 24, 2006 HAND DELIVERED Dear M Via Your daughterawas the victim of a crime which has been investigated by the Palm Beach Police Department and subsequently referred for prosecution to the Palm Beach County State Attorney's Office. You may be aware that Jeffrey Epstein was indicted on c
rty's] belief that the papers are those described in the subpoena. Doe, 465 U.S. at 612, quoting Fisher, 425 U.S. at 410:see also United States v. Hubbell, 530 U.S. 27, 40 (2000) (compelled testimony "is not to be found in the documents produced in response tip the subpoena" but is instead "the testimo
Entities connected to both Palm Beach Police Department and Hubbell

Jeffrey Epstein
PERSON
United States
LOCATIONFBI
ORGANIZATIONthe Southern District
LOCATION
Alexander Acosta
PERSONJack Goldberger
PERSONGerald Lefcourt
PERSONJane Doe
PERSONLeon Black
PERSON
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATION
Kenneth Marra
PERSON
Palm Beach
LOCATION
Alan Dershowitz
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSON
Palm Beach County
LOCATIONRoy Black
PERSON
Jay Lefkowitz
PERSON
the United States District Court
ORGANIZATION