Epstein Secrets

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

roduction as a shield to turning over documents whose existence is known to the government or is a foregone conclusion. See, e.g. In re Grand Jury Subpoena Duces Tecum Dated Oct. 29, 1992, 1 F.3d 87, 93 (2d Cir. 1993) (rejecting act of production argument because compliance with subpoena requiring production

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

puters, it is that content which must be particularly described in the subpoena to comply with the reasonableness requirement. See In re Grand Jury Subpoena Duces Tecum Dated November 15, 1993, 846 F.2d 11, 13 (S.D.N.Y. 1994). The subpoenas at issue fail utterly to do so. Rather,- they are overbroad and unpar

ncy, and for the past three years, I have been assigned to investigate mostly child exploitation cases. 2. In the Spring of 2006, Detective kith the Town of Palm Beach Police Department ("PBPD") contacted me about the investigation of Jeffrey Epstein's solicitation of minors to engage in prostitution and his lewd and lascivious cond

egories of documents and other information which the government believes relevant to the grand jury's investigation.' The court in In re Grand Jury Subpoena Duces Tecum Dated November 15, 1993, 846 F.Supp. 11 (S.D.N.Y. 1994), was confronted with a similar issue in the context of a grand jury subpoena for the