Epstein Secrets

NAS I, state that the following is true and correct to the best of my information and belief: 1. I am currently employed as a Special Agent with the Federal Bureau of Investigation ("FBI") and have been so employed for the past ten years. I am assigned to the Miami Division, Palm Beach County Resident Agency, and for the past t

.S.C. § 1746, that the foregoing is true and correct to the best of my knowledge and belief. Executed this 3 4h day of July, 2007. Special Agent Federal Bureau of Investigation Page 9 of 9 EFTA00179198 EFTA00179199 GOVERNMENT EXHIBIT C EFTA00179200 GOVERNMENT EXHIBIT B EFTA00179201 Contact Us Page 1 of 1 HOME I

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

D to bring with you the following document(s) or object(s): Please coordi of this subpoena and confum the date and time of ur a ante with Special Agen Federal Bureau of Investigation, Telephone: Please see additional information on reverse This subpoena shall remain in effect until you are granted leave to depart by the court or

ember I, 2006 9:00am Please coordinate your compliance of this subpoena and confirm the date and time of your a ranee with Special Agent-Federal Bureau of Investigation, Telephone: Please see additional information on '.et sc This subpoena shall remain in effect until you arc granted leave to depart by the court or

. 431 F.2d 384, 388 (5th Cir.1970), cert. denied. 400 U.S. Page 14 1000, 91 S.Ct. 456, 27 L.Ed.2d 451 (1971); In re 1980 United States Grand Jury Subpoena Duces Team 502 F.Supp. 576, 579-80 (E.D.La.1980); United States v. Grand Jury Investigation, 417 F.Supp. 389, 393 (E.D.Pa.1976). Thus, the case law cl

ding 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 asserting specific legal objections including but not limited to relying on cer

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

. BACKGROUND On June 29, 2020, a grand July sitting in this District returned an indictment charging the defendant in six counts. On July 2, 2020, the Federal Bureau of Investigation ("FBI") arrested the defendant. On July 8, 2020, a grand jury sitting in this District returned a superseding indictment (the "Indictment") contain

401 (2d Cir. 2004) 36, 43, 44 In re Grand Jucv Subpoena Duces Tecum Dated Apr. 19, 1991, 945 F.2d 1221 (2d Cir. 1991) 108, 113 In re Grand Jury Subpoena Duces Tecum Dated Oct. 29, 1992, 1 F.3d 87 (2d Cir. 1993) 140, 145 In re Grand Jury Subpoena, 826 F.2d 1166 (1987) 136 In re Grand Jury Subpoena,

. BACKGROUND On June 29, 2020, a grand jury sitting in this District returned an indictment charging the defendant in six counts. On July 2, 2020, the Federal Bureau of Investigation ("FBP") arrested the defendant. On July 8, 2020, a grand jury sitting in this District returned a superseding indictment (the "Indictment") contain

, 485 U.S. 681 (1988) 254 In re Enter. Mort. Acceptance Co. Sec. Litig. ("Enterprise", ), 391 F.3d 401 (2d Cir. 2004) 36,43,44 In re Grand Jury Subpoena Duces Tecum Dated Apr. 19, 1991, 945 F.2d 1221 (2d Cir. 1991) 108, 113 In re Grand Jury Subpoena Duces Tecum Dated Oct 29, 1992, 1 F.3d 87 (2d Cir. 199

. BACKGROUND On June 29, 2020, a grand jury sitting in this District returned an indictment charging the defendant in six counts. On July 2, 2020, the Federal Bureau of Investigation ("FBP") arrested the defendant. On July 8, 2020, a grand jury sitting in this District returned a superseding indictment (the "Indictment") contain

, 485 U.S. 681 (1988) 254 In re Enter. Mort. Acceptance Co. Sec. Litig. ("Enterprise", ), 391 F.3d 401 (2d Cir. 2004) 36,43,44 In re Grand Jury Subpoena Duces Tecum Dated Apr. 19, 1991, 945 F.2d 1221 (2d Cir. 1991) 108, 113 In re Grand Jury Subpoena Duces Tecum Dated Oct 29, 1992, 1 F.3d 87 (2d Cir. 199

. BACKGROUND On June 29, 2020, a grand jury sitting in this District returned an indictment charging the defendant in six counts. On July 2, 2020, the Federal Bureau of Investigation ("FBP") arrested the defendant. On July 8, 2020, a grand jury sitting in this District returned a superseding indictment (the "Indictment") contain

States, 485 U.S. 681 (1988) 166 In re Enter. Mort. Acceptance Co. Sec. Litig. ("Enterprise"), 391 F.3d 401 (2d Cir. 2004) 27, In re Grand Jury Subpoena Duces Tecum Dated Apr. 19, 1991, 945 F.2d 1221 (2d Cir. 1991) In re Grand Jury Subpoena Duces Tecum Dated Oct 29, 1992, 28, 77, 33 81 1 F.3d 87 (2d

S AND OB,TECTS LISTED ON ATTACHMENT A. '"Please coordinate MIR ROtntiliance with his subpoena and confirm the date, time, and I ' appearance with S/A I Federal Bureau of Investigation, Telephone: This subpoena shall remain in effect until you arc granted leave to depart by the court or by an officer acting on behalf of the court.

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

. BACKGROUND On June 29, 2020, a grand jury sitting in this District returned an indictment charging the defendant in six counts. On July 2, 2020, the Federal Bureau of Investigation ("FBP") arrested the defendant. On July 8, 2020, a grand jury sitting in this District returned a superseding indictment (the "Indictment") contain

, 485 U.S. 681 (1988) 254 In re Enter. Mort. Acceptance Co. Sec. Litig. ("Enterprise", ), 391 F.3d 401 (2d Cir. 2004) 36,43,44 In re Grand Jury Subpoena Duces Tecum Dated Apr. 19, 1991, 945 F.2d 1221 (2d Cir. 1991) 108, 113 In re Grand Jury Subpoena Duces Tecum Dated Oct 29, 1992, 1 F.3d 87 (2d Cir. 19