EFTA00723743

IN THE COURT OF THE FIFTEENTH 
JUDICIAL CIRCUIT, IN AND FOR PALM 
BEACH COUNTY, FLORIDA 
L.M., 
CASE NO. 502008CA028051XXXXMB AB 
Plaintiff, 
v. 
JEFFREY EPSTEIN 
Defendant. 
ORDER ON EPSTEIN'S MOTION FOR PROTECTIVE ORDER TO PROHIBIT 
INAPPROPRIATE DEPOSITION QUESTIONS 
THIS CAUSE came before the Court on Epstein's Motion for Protective Order to 
Prohibit Inappropriate Deposition Questions, and the Court having heard argument of 
counsel and being fully advised in these premises, it is hereby 
ORDERED and ADJUDGED that: Defendant's Motion is hereb 
Pi a °66PC, 
1.1.2-4./tColAt WU_ A"--e-trts7 
DONE AND ORDER 
at Palm Beach r ounty Courthouse, West Palm Beach, 
Florida, this  /T  day of  
• 
 201 
Copies furnished: 
ROBERT D. CRITTON, JR., ESQ., and MICH EL J. PIKE, ESQ., 303 Banyan Boulevard, Suite 400, 
West Palm Beach, FL 33401, BRADLEY J. EDWARDS, ESQ., Farmer, Jaffe, Weissing, Edwards, 
Fistos & Lehrman, PL, 425 N. Andrews Avenue, Suite 2, Fort Lauderdale, FL 33301, JACK A. 
GOLDBERGER, ESQ. Atterbury, Goldberger & Weiss, PA, 250 Australian Avenue South, Suite 1400, 
West Palm Beach, FL 33401 and JAY HOWELL, ESQ., Jay Howell & Associates, P.A., 644 Cesery 
Boulevard, Suite 250. Jacksonville, FL 32211 
EFTA00723743

JONES 
FOS I ER 
JOHNSTON 
& STUBBS, P.A., 
Attorneys and Counselors 
Joanne M. 'C 
're 
Direct Dial: 
Direct Fax: 
E-Mail: 
January 15, 2010 
Robert Critton, Esquire 
303 Banyan Boulevard 
Suite 400 
West P 
FL 33401 
Flagler Center Tower, Suite 1100 
505 South Flagler Drive 
West Palm Beach, Florida 33401 
Telephone (561)659-3000 
Mailing Address 
Post Office Box 3475 
West Palm Beach, Florida 33402-3475 
Re: 
B.B. v. Jeffrey Epstein, Case No. 502008CA037319XXXXMB AB 
Dear Bob: 
In response to your correspondence dated January 5, 2010, enclosed please find 
Responses and Objections to the subpoenas served on the Town of Palm Beach Police 
Department Records Custodian and certain Town of Palm Beach police officers. 
Pursuant to the line of case law originating with Gosman v. Luzinski, 937 So. 2d 293 
(Fla. 41" DCA 2006), we are not under any present duty to provide you with a privilege 
log identifying statutorily protected documents that we are not producing and will not 
produce such a log at this time. 
Finally, with regard to Administrative Order G.O. 11-65, we have produced two 
documents to you. One document is the order effective January 15, 1999, as revised 
on August 29, 2000 (note the language at the bottom of the first page of G.O. 11-65: 
"'Revised 08/29/00"). I am advised by the Town Records Custodian that there is no 
separate amendment dated August 29, 2000: The January 15, 1999 document was 
simply revised and you have been provided the revised version. The second document 
is the Order currently in effect as of June 15, 2009. 
Sincerely, 
JONES, FOSTER, JOHNSTON & STUBBS, P.A. 
By 
oanne M. O'Connor 
JMO:mtm 
PftDOCS VI3156 \ 003151.TR\ 1160772.DOC 
www.fones-fostercom 
IBIBIBWMVIMITEI 
EFTA00723744

IN 
THE 
CIRCUIT 
COURT 
OF 
THE 
FIFTEENTH JUDICIAL CIRCUIT IN AND FOR 
PALM BEACH COUNTY, FLORIDA 
CASE NO: 50 2008 CA 037319 XXXX MB AB 
B.B., 
Plaintiff, 
vs 
JEFFREY EPSTEIN, 
Defendant. 
NON-PARTY TOWN OF PALM BEACH POLICE OFFICERS' 
RESPONSE AND OBJECTION TO SUBPOENA DUCES TECUM 
Non-parties, former Town of Palm Beach Chief of Police Michael Reiter, Captain 
George Frick, Detective Joseph Recarey, Detective Michael Dawson and Detective 
Michelle Pagan (collectively 'Town of Palm Beach Police Officers"), hereby file this, 
their response and objection to the subpoenas duces tecum served on each of them as 
follows: 
GENERAL OBJECTIONS 
As noted below, the Town of Palm Beach Police Officers have previously 
produced documents responsive to this subpoena. In accordance with its obligations 
under Section 119.07 of the Florida Public Records Law, the Town of Palm Beach 
Police Officers have redacted a number of those documents in order to protect those 
matters excepted from disclosure under Chapter 119, Fla. Stat. 
These areas of 
redaction include, but are not limited to, the home addresses and telephone numbers of 
the law enforcement personnel and any identifying information regarding the victims. 
EFTA00723745

Such redaction is necessary because of the broad range of criminal intelligence and 
investigative information regarding minor victims of sexual offenses under Florida 
Statutes Chapter 794 and/or 800 sought by the subpoenas. The redactions made by 
the Town of Palm Beach Police Officers may also include exempted personal 
information including their home addresses, telephone numbers and social security 
numbers. 
RESPONSES AND OBJECTIONS TO DUCES TECUM 
1. 
Any and all written reports, notes, memoranda or other papers authored 
by you or any other member of the Palm Beach Police Department, whether in hard-
copy or electronic form, that relate to any law enforcement investigation of Jeffrey 
Epstein including but not limited to the investigation that resulted in the filing of State 
criminal charges against Mr. Epstein. This request includes any written communications 
between you and any members of the Palm Beach Police Department, any member of 
any Federal Law Enforcement Agency, any member of the United States Attorney's 
Office, any member of the Office of the State Attorney, any representatives of the 
media, any civil parties, any civilian witnesses and/or any lawyers or representatives of 
any parents of any civilian witnesses. 
RESPONSE: For all of the reasons set forth in response to Request No. 2 
infra and incorporated herein, the Town Police Department objects to the request 
to the extent that it seeks electronic communications. Aside from personal e-mall 
of its employees, which the Town Police Department objects to producing for all 
of the reasons set forth in Response to Request No. 2, infra, all documents 
responsive to this request were produced on December 9, 2009. 
2. 
Any and all electronic communications (EMAIL) between al any of the 
following relating to any law enforcement investigation of Jeffrey Epstein including but 
not limited to the investigation that resulted in the filing of State criminal charges against 
him: (A) any member of the Palm Beach Police Department, (B) any member of any 
Federal Law Enforcement Agency, (C) any member of the Untied States Attomey's 
Office, (D) any member of the Office of the State Attorney (E) any member of any print, 
television, or radio media outlet, (F) any attorney representing any civilian witness or 
civil party who has filed or may potentially file a civil complaint against Mr. Epstein. 
RESPONSE: The Town of Palm Beach Police Officers object to this request 
on the grounds that it is unduly burdensome and seeks information that is 
protected from disclosure under Florida's Public Records Law. 
The Town 
reserves the right to submit a privilege log at the appropriate time should the 
2 
EFTA00723746

Court overrule its objections. See Gosman v. Luzinski, 937 So. 2d 293 (Fla. 4th
DCA 2006). 
3. 
Any and all notes, memoranda or reports reflecting any communications 
between you and counsel on behalf of Mr. Epstein, including but not limited to any 
request for exculpatory evidence. 
RESPONSE: None. 
4. 
Any and all notes, memoranda or reports reflecting any attempts by you to 
initiate or encourage a federal review of any facet/aspect of the Epstein investigation or 
State prosecution of Epstein. 
RESPONSE: Aside from the previously produced correspondence from 
Michael S. Reiter to Barry E. Krischer dated May 1, 2006 and correspondences 
from Michael S. Reiter to parents of victims dated July 24, 2006, no responsive 
documents exist. 
5. 
Any and all notes, memoranda or reports reflecting any complaints made 
to the Palm Beach Police Department from any person, parent, or lawyer for any person 
or parent claiming to have been a victim of any conduct of Mr. Epstein or from any other 
private citizen of Palm Beach County relating to any conduct of Epstein from January 1, 
2000-October 22, 2009. 
RESPONSE: 
All responsive documents in the possession, custody or 
control of the Town of Palm Beach Police Officers were produced on December 9, 
2009. 
6. 
Any and all notes, memoranda, or reports reflecting any communication 
between You or and any other member of the Palm Beach Police Department with 
"A.H."* in relation to her being subpoenaed to testify before or her requested attendance 
before a State Grand Jury, including but not limited to any discussions regarding what 
she would testify to and/or any preparation that any law enforcement officer provided 
her with prior to any testimony. 
RESPONSE: 
All responsive documents in the possession, custody or 
control of the Town of Palm Beach Police Officers were produced on December 9, 
2009. 
7. 
Any and all notes, memoranda, or reports reflecting any communication 
between you or any other member of the Palm Beach Police Department with "A.H."* or 
referencing "A.H."* in relation to her being subpoenaed to testify before or her 
requested attendance before a State Grand Jury where you or any Palm Beach police 
officer or official sought to discourage her or influence her not to testify or to testify in a 
certain manner at any Grand Jury proceeding involving Mr. Epstein. 
3 
EFTA00723747

RESPONSE: None. 
8. 
Any and all agreements, memoranda, and/or notes of any kind, electronic 
or otherwise, between you and any member of the Palm Beach Police Department, any 
member of the Office of the State Attorney, and/or any member of the United States 
Attorney's Office relating to any criminal charges, formal or otherwise, regarding "A.H." 
at any time. 
RESPONSE: None. 
9. 
Any and all notes, memoranda, or reports of meetings or communications 
between you and "S.G."*, her parents, or any lawyers who represent "S.G." 
RESPONSE: All responsive documents in the possession, custody or 
control of the Town of Palm Beach Police Officers were produced on December 9, 
2009. 
10. 
Any and all records of expenditures made or incurred by you, and all 
requests for expenditures relating to the criminal investigation of Mr. Epstein. 
RESPONSE: None. 
11. 
Any and all logs, pictures, videos, digital information, reports, memoranda 
or notes, and any record of expenditure, which relate to the institution of and/or 
maintenance of any video surveillance of Mr. Epstein, his residence, or his visitors 
during the following time periods: 
a. 
January 1, 2004-December 31, 2004 
b. 
January 1, 2005-December 31, 2005 
c. 
January 1, 2006-December 31, 2006 
d. 
January 1, 2007-December 31, 2007 
e. 
January 1, 2008-December 31, 2008 
f. 
January 1, 2009-today's date. 
RESPONSE: None. 
12. 
Any and all reports, logs, pictures, videos, notes, records of expenditures 
or any other memoranda relating to any physical surveillance of Mr. Epstein, his 
residence, his visitors, or any individual who was believed to be a potential witnesses or 
co-conspirator other than the information relating to video surveillance that is requested 
in request number 11. 
RESPONSE: Photographs of Mr. Epstein taken by Detective Recarey will 
be produced. The Town possesses no other responsive documents. 
4 
EFTA00723748

13. 
Any and all reports (including forensic reports), memoranda, notes, and 
reports of any examination of any computer seized from Mr. Epstein's residence in 
October 2005 or on any other occasion. 
RESPONSE: None. 
14. 
Any and all reports, memoranda, or notes reflecting a criminal theft or 
burglary investigation of Mr. Epstein or his residence on any occasion prior to October 
2005. 
RESPONSE: 
All responsive documents in the possession, custody or 
control of the Town of Palm Beach Police Officers were produced on December 9, 
2009. 
15. 
All cell phone records, both official cell phone and personal cell phone, 
used by you between during the following time periods: 
a. 
January 1, 2004-December 31, 2004 
b. 
January 1, 2005-December 31, 2005 
c. 
January 1, 2006-December 31, 2006 
d. 
January 1, 2007-December 31, 2007 
e. 
January 1, 2008-December 31, 2008 
f. 
January 1, 2009-today's date. 
RESPONSE: The Town of Palm Beach Police Officers object to this request 
on the grounds that it seeks information that is irrelevant and not likely to lead to 
the discovery of admissible evidence. The Town of Palm Beach Police Officers 
further object on the grounds that the request is overly broad and unduly 
burdensome. Finally, the Town of Palm Beach Police Officers object on the 
grounds that the request seeks information that is specifically excepted from 
disclosure under Florida's Public Records Law. See generally Non-Party Town of 
Palm Beach Police Officers' Motion to Quash Subpoenas and/or Motion for 
Protective Order, incorporated herein. The Town reserves the right to submit a 
privilege log at the appropriate time should the Court overrule its objections. See 
Gosman v. Luzinski, 937 So. 2d 293 (Fla. e DCA 2006). 
16. 
All calendars or diaries, electronic or hard-copy, kept for the periods 
between October 1, 2004 up through and including today, reflecting your schedules, 
activities, meeting, etc. 
RESPONSE: The Town of Palm Beach Police Officers object to this request 
on the grounds that it seeks information that is irrelevant and not likely to lead to 
the discovery of admissible evidence and as overly broad. The Town of Palm 
Beach Police Officers further object on the grounds that the request seeks private 
information that is not subject to disclosure as a public record under Section 
5 
EFTA00723749

119.011(1), Fla. Stat. and seeks statutorily protected information regarding the law 
enforcement officers who made the calls and the persons to whom calls were 
made including, but not limited, to family members, crime victims and 
confidential informants. See generally Non-Party Town of Palm Beach Police 
Officers' Motion to Quash Subpoenas and/or Motion for Protective Order, 
incorporated herein. The Town reserves the right to submit a privilege log at the 
appropriate time should the Court overrule its objections. 
See Gosman v. 
Luzinski, 937 So. 2d 293 (Fla. 4th DCA 2006). 
17. 
Any and all reports, memoranda, and notes of any communication 
between y_qm and any member of the Office of the State Attorney relating to the criminal 
investigation and subsequent prosecution of Mr. Epstein from October 1, 2004 up 
through and including today. 
RESPONSE: Aside from the previously produced correspondence from 
Michael S. Reiter to Barry E. Krischer dated May 1, 2006, no responsive 
documents exist. 
18. 
All policies and procedures of the Palm Beach Police Department setting 
forth the procedures for police officers, including the Chief, any detective and officers 
when commenting to any media outlets, including but not liming to the local news, the 
national media, print outlets, and any web-based media format. 
RESPONSE: All responsive documents in the possession, custody or 
control of the Town of Palm Beach Police Officers were produced on December 9, 
2009. 
19. 
All personal notes contained either on your personal computer, work 
computer, and those that are handwritten containing any witnesses that y.clq, or any 
other member of the Palm Beach Police Department interviewed or attempted to 
interview with regard to the Epstein investigation from January 1, 2004, up through and 
including today. 
RESPONSE: None. 
20. 
Any and all audio tapes of any witnesses that you or any member of the 
Palm Beach Police Department obtained statements or interviews from, either sworn or 
informal, with regard to the Epstein investigation. 
RESPONSE: None. 
21. 
Any and all audio tapes, notes (hand-written or typed), memoranda, 
reports, messages, and/or any communications obtained or generated by you or any 
member of the Palm Beach Police Department, either sworn or informal, that relate to 
Jane Doe #4", who is the Plaintiff in a Federal Civil Case No. 08-80380 filed against 
Jeffrey Epstein. 
6 
EFTA00723750

RESPONSE: The Town of Palm Beach Police Officers have no information 
regarding the identity of "Jane Doe #4" and therefore cannot properly respond to 
this Request 
Furthermore, the Town objects to producing any responsive 
documents of the type objected to in Request Nos. 2, 15 and 16, supra. Subject 
to and notwithstanding its objections, the Town Police Department responds that 
it possesses no responsive documents other than what has previously been 
produced, unless those documents are encompassed within Request No. 2. 
I HEREBY CERTIFY that a true copy of the foregoing instrument has been 
furnished by United States mail to Theodore J. Leopold, Esquire and Spencer T. 
Kuvin, Esquire, Leopold-Kuvin, P.A., 2925 PGA Boulevard, Suite 200, Palm Beach 
Gardens, Florida 33410; Jack Alan Goldberger, Esquire, Atterbury Goldberger & 
Weiss, P.A. 250 Australian Avenue South, Suite 1400, West Palm Beach, Florida 
33401-5012; and Robert D. Critton, Jr., Esquire, Burman, Critton, Luther & Coleman, 
LLP, 515 North Flagler Drive, Suite 400, West Palm Beach, Florida 
33401, this 
7.69-1-%-nay 
of January, 2010. 
JONES, FOSTER, JOHNSTON & STUBBS, 
P.A. 
505 South Flagler Drive, Suite 1100 
Post Office Box 3475 
West Palm Beach, Florida 33402-3475 
Telephone: 561-659-3000 
Facsimile. 
1-650-0465 
PADOCS513156`40031SPLCA1753111.DOC 
7 
EFTA00723751

IN 
THE 
CIRCUIT 
COURT 
OF 
THE 
FIFTEENTH JUDICIAL CIRCUIT IN AND FOR 
PALM BEACH COUNTY, FLORIDA 
CASE NO: 50 2008 CA 037319 XXXX MB AB 
B.B., 
Plaintiff, 
vs 
JEFFREY EPSTEIN, 
Defendant. 
NON-PARTY TOWN OF PALM BEACH RECORDS CUSTODIAN'S 
RESPONSE AND OBJECTION TO SUBPOENA DUCES TECUM 
Non-party, Town of Palm Beach Police Department Records Custodian ("Town 
Police Department"), hereby file this, her response and objection to the subpoenas 
duces tecum served on her as follows: 
GENERAL OBJECTIONS 
As noted below, the Town Police Department has previously produced 
documents responsive to this subpoena. In accordance with its obligations under 
Section 119.07 of the Florida Public Records Law, the Town Police Department has 
redacted a number of those documents in order to protect those matters excepted from 
disclosure under Chapter 119, Fla. Stat. These areas of redaction include, but are not 
limited to, the home addresses and telephone numbers of the law enforcement 
personnel and any identifying information regarding the victims. Such redaction is 
necessary because of the broad range of criminal intelligence and investigative 
information regarding minor victims of sexual offenses under Florida Statutes Chapter 
EFTA00723752

794 and/or 800 sought by the subpoenas. The redactions made by the Town Police 
Department may also include exempted personal information regarding its law 
employment officers and personnel including their home addresses, telephone numbers 
and social security numbers. 
RESPONSES AND OBJECTIONS TO DUCES TECUM 
1. 
Any and all written reports, notes, memoranda or other papers authored 
by any member of the Palm Beach Police Department and/or any of its employees, 
members, agents, or representatives acting on behalf of the Palm Beach Police 
Department whether in hard-copy or electronic form, that relate to any law enforcement 
investigation of Jeffrey Epstein including but not limited to the investigation that resulted 
in the filing of State criminal charges against Mr. Epstein. This request includes any 
written communications between the Palm Beach Police Department and/or any of its 
members, agents, or representatives acting on behalf of the Palm Beach Police 
Department and any members of any Federal Law Enforcement Agency, any member 
of the United States Attorney's Office, any member of the Office of the State Attorney, 
any representatives of any media outlet, any civil parties, any civilian witnesses and/or 
any lawyers or representatives of any parents of any civilian witnesses. 
RESPONSE: For all of the reasons set forth in response to Request No. 2 
infra and incorporated herein, the Town Police Department objects to the request 
to the extent that it seeks electronic communications. Aside from personal e-mail 
of its employees, which the Town Police Department objects to producing for all 
of the reasons set forth in Response to Request No. 2, infra, all documents 
responsive to this request on December 9, 2009. 
2. 
Any and all electronic communications (EMAIL) between the Palm Beach 
Police Department and/or any of its employees, members, agents, or representatives 
acting on behalf of the Palm Beach Police Department and any of the following that 
relate to any law enforcement investigation of Jeffrey Epstein including but not limited to 
the investigation that resulted in the filing of State criminal charges against him: (A) any 
other member of the Palm Beach Police Department, (B) any member of any Federal 
Law Enforcement Agency, (C) any member of the Untied States Attorney's Office, (D) 
any member of the Office of the State Attorney (E) any member of any print, television, 
and/or radio media outlets (F) any attorney representing any civilian witness or civil 
party who has filed or may potentially file a civil complaint against Mr. Epstein. 
RESPONSE: The Town of Palm Beach Police Officers object to this request 
on the grounds that it is unduly burdensome and seeks information that is 
protected from disclosure under Florida's Public Records Law. 
The Town 
reserves the right to submit a privilege log at the appropriate time should the 
2 
EFTA00723753

Court overrule its objections. See Gosman v. Luzinski, 937 So. 2d 293 (Fla. 4th
DCA 2006). 
3. 
Any and all notes, memoranda or reports reflecting any communications 
by the Palm Beach Police Department and/or any of its employees, members, agents, 
or representatives acting on behalf of the Palm Beach Police Department with any 
counsel on behalf of Epstein, including but not limited to any request for exculpatory 
evidence. 
RESPONSE: None. 
4. 
Any and all notes, memoranda or reports reflecting any attempts by the 
Palm Beach Police Department and/or any of its employees, members, agents, or 
representatives acting on behalf of the Palm Beach Police Department to initiate or 
encourage a federal review of any facet/aspect of the Epstein investigation or State 
prosecution of same. 
RESPONSE: Aside from the previously produced correspondence from 
Michael S. Reiter to Barry E. Krischer dated May 1, 2006 and correspondences 
from Michael S. Reiter to parents of victims dated July 24, 2006, no responsive 
documents exist. 
5. 
Any and all notes, memoranda or reports reflecting any complaints made 
to the Palm Beach Police Department or any of its employees, members, agents, or 
representatives acting on behalf of the Palm Beach Police Department from any person, 
parent, or lawyer for any person or parent claiming to have been a victim of any conduct 
of Mr. Epstein or from any other private citizen of Palm Beach County from 2000-2009. 
RESPONSE: All responsive documents in the possession, custody or 
control of the Town Police Department were produced on December 9, 2009. 
6. 
Any and all notes, memoranda, or reports reflecting any communication 
between the Palm Beach Police Departments and/or any of its employees, members, 
agents or representatives acting on behalf of the Palm Beach Police Department with 
"AA." in relation to her being subpoenaed to testify before or her requested attendance 
before a State Grand Jury, including but not limited to any discussions regarding what 
she would testify to and/or any preparation that any law enforcement officer provided 
her with prior to any testimony. 
RESPONSE: All responsive documents in the possession, custody or 
control of the Town Police Department were produced on December 9, 2009. 
7. 
Any State Grand Jury testimony that was sought or discouraged by the 
Palm Beach Police Department or any of its employees, members, agents, or 
representatives acting on behalf of the Palm Beach Police Department regarding any 
contact with "A.H". relating to any investigation of Mr. Epstein. 
3 
EFTA00723754

RESPONSE: None. 
8. 
Any and all agreements, memoranda, and/or notes of any kind, electronic 
or otherwise, between the Palm Beach Police Department or any of its employees, 
members, agents, or representatives acting on behalf of the Palm Beach Police 
Department and any member of the Office of the State Attorney, and/or any member of 
the United State s Attorney's Office relating to any criminal charges, formal or otherwise, 
regarding "A.H"at any time. 
RESPONSE: None. 
9. 
Any and all notes, memoranda, or reports of meetings or communications 
between the Palm Beach Police Department or any of its employees, members, agents, 
or representatives acting on behalf of the Palm Beach Police Department and "S.G."*, 
her parents, or any lawyers who represent "S.G"*. 
RESPONSE: All responsive documents in the possession, custody or 
control of the Town Police Department were produced on December 9, 2009. 
10. 
Any and all records and requests of expenditures made or incurred by the 
Palm Beach Police Department or any of its employees, members, agents, or 
representatives acting on behalf of the Palm Beach Police Department relating to the 
criminal investigation of Mr. Epstein. 
RESPONSE: 
None. 
The Town Police Department does not generally 
assign expenditures to specific cases. 
11. 
Any and all logs, pictures, videos, digital information, reports, memoranda 
or notes, and any record of expenditure, which relate to the institution of and 
maintenance of any video surveillance of Mr. Epstein, his residence, or his visitors. 
RESPONSE: None. 
12. 
Any and all reports, logs, pictures, videos, notes, records of expenditures 
or any other memoranda relating to any physical surveillance of Mr. Epstein, his 
residence, his visitors, or any individual who was believed to be a potential witness or 
co-conspirator other than the information relating to video surveillance identified in 
request number 11. 
RESPONSE: None. 
13. 
Any and all reports (including forensic reports), memoranda, notes, and 
reports of any examination of any computer seized from Mr. Epstein's residence in 
October 2005 or on any other occasion. 
4 
EFTA00723755

RESPONSE: None. 
14. 
Any and all reports, memoranda, or notes reflecting a criminal theft or 
burglary investigation of Mr. Epstein or his residence on any occasion prior to October 
2005. 
RESPONSE: All responsive documents in the possession, custody or 
control of the Town Police Department were produced on December 9, 2009 
15. 
Any and all reports, memoranda, and notes of any communication by the 
Palm Beach Police Department or any of its employees, members, agents, or 
representatives acting on behalf of the Palm Beach Police Department and the Office of 
the State Attorney relating to the criminal investigation and subsequent prosecution of 
Mr. Epstein from October 1, 2004 up through and including today. 
RESPONSE: All responsive documents in the possession, custody or 
control of the Town Police Department were produced on December 9, 2009. 
16. 
All policies and procedures regarding commentary to any media outlets, 
including but not limited to the local news, the national media, print outlets, and any 
web-based media format. 
RESPONSE: All responsive documents in the possession, custody or 
control of the Town Police Department were produced on December 9, 2009. 
17. 
Any and all notes generated by the Palm Beach Police Department, its 
employees, members, agents, or representatives acting on behalf of the Palm Beach 
Police Department that concern or relate to any interviews or statements obtained 
regarding the Epstein investigation from January 1, 2004, up through and including 
today, including but not limited to notes that are handwritten, contained on any work 
computer, and/or any personal computer. 
RESPONSE: Aside from the Incident Report produced on December 9, 
2009, no responsive documents exist 
18. 
Any and all audio tapes of any witnesses that the Palm Beach Police 
Department or any of its employees, members, agents, or representatives acting on 
behalf of the Palm Beach Police Department obtained statements or interviews from, 
either sworn or informal, with regard to the Epstein investigation. 
RESPONSE: None. 
19. 
Any and all personnel records of Michael Reiter, Detective Joseph 
Recarey, Detective Michelle Pagan, and Detective Michael Dawson. 
RESPONSE: None. 
5 
EFTA00723756

20. 
Any and all audio tapes, notes (hand-written or typed), memoranda, 
reports, messages, and/or any communications, either sworn or informal, obtained or 
generated by Palm Beach Police Department, its employees, members, agents, or 
representatives acting on behalf of the Palm Beach Police Department that relate to 
Jane Doe #4**, who is the Plaintiff in a Federal Civil Case No. 08-80380 filed against 
Jeffrey Epstein. 
RESPONSE: The Town of Palm Beach Police Officers have no information 
regarding the identity of "Jane Doe #4" and therefore cannot properly respond to 
this Request. 
Furthermore, the Town objects to producing any responsive 
documents of the type objected to in Request Nos. 2, 15 and 16, supra. Subject 
to and notwithstanding its objections, the Town Police Department responds that 
it possesses no responsive documents other than what has previously been 
produced, unless those documents are encompassed within Request No. 2. 
I HEREBY CERTIFY that a true copy of the foregoing instrument has been 
furnished by United States mail to Theodore J. Leopold, Esquire and Spencer T. 
Kuvin, Esquire, Leopold-Kuvin, PA, 2925 PGA Boulevard, Suite 200, Palm Beach 
Gardens, Florida 33410; Jack Alan Goldberger, Esquire, Atterbury Goldberger & 
Weiss, P.A. 250 Australian Avenue South, Suite 1400, West Palm Beach, Florida 
33401-5012; and Robert D. Critton, Jr., Esquire, Burman, Critton, Luther & Coleman, 
LLP, 515 North Flagler Drive, Suite 400, West Palm Beach, Florida 
33401, this 
of January, 2010. 
JONES, FOSTER, JOHNSTON & STUBBS, 
P.A. 
505 South Flagler Drive, Suite 1100 
Post Office Box 3475 
West Palm 
3402-3475 
Telephone: 
Facsimile: 
PADOCSU31561.00315WW11753150.DOC 
By 
bhn C. Randolph 
6 
EFTA00723757