EFTA01076133

IN THE COURT OF THE FIFTEENTH 
JUDICIAL CIRCUIT, IN AND FOR PALM 
BEACH COUNTY, FLORIDA 
B.B., 
CASE NO. 502008CA037319XXXXMB AB 
Plaintiff, 
v. 
JEFFREY EPSTEIN, 
and MKELLEN, 
Defendants. 
DEFENDANT EPSTEIN'S MOTION TO COMPEL TOWN OF PALM BEACH 
RECORDS CUSTODIAN'S AND POLICE OFFICERS' TO PRODUCE RECORDS 
SOUGHT PURSUANT TO DEFENDANT'S SUBPOENAS DUCES TECUM 
Defendant, JEFFREY EPSTEIN (hereinafter "EPSTEIN") by and through his 
undersigned attorneys, moves to compel the non-parties, TOWN OF PALM BEACH 
RECORDS CUSTODIAN and TOWN OF PALM BEACH POLICE OFFICERS, to better 
respond to and produce certain of the records sought pursuant to the cross-notices and 
notices of depositions with subpoenas duces tecum served upon them. In support of 
his motion to compel, Defendant states: 
1. 
Defendant JEFFERY EPSTEIN served multiple Cross-Notices for Deposition 
with Subpoenas Duces Tecum, dated October 26, 2009, and Subpoenas Duces Tecum 
for Deposition, dated October 26, 2009, and one dated November 3, 2009, directed to 
the Town Of Palm Beach Records Custodian ("RC"), and certain Police Officers and the 
Police Captain of Town of Palm Beach ("Police"). The items requested and the Police's 
and RC's responses and objections thereto are set forth in Non-Party Police Officers' 
Response And Objection To Subpoena Duces Tecum, dated January 15, 2010, 
attached hereto as Exhibit A; and in Non-Party Town of Palm Beach Records 
EFTA01076133

Page 2 
Custodian's Response And Objection to Subpoena Duces Tecum, dated January 15, 
2010, and attached hereto as Exhibit B. 
2. 
The Police and RC have produced very little of the documents and items 
sought generally and improperly claiming that the records were exempt from production 
under Florida's Public Records Act. As discussed more fully below herein, certain of the 
records sought are not completely exempt from being produced for inspection and 
copying. In addition, the Police and RC have not properly asserted a Public Records 
Act exemption as required by the statute. As set forth in §119.07, Fla. Stat., the Police 
and RC are still required to produce the requested records by redacting any information 
that is statutorily exempted or confidential. 
3. 
In response to the Subpoenas Duces Tecum, the Police Officers' filed a Motion 
to Quash Subpoenas And/Or Motion For Protective Order, dated November 20, 2009. 
In short, the Police asserted generally that almost all the public records sought were 
subject to exemptions and, thus, they were not required to produce the records sought, 
pursuant to §119.071(2)(j); §119.071(2)(h)1.b.; and §119.071(4)(d)1.a, Fla. Stat. 
§119.071, Fla. Stat., is part of what is commonly referred to as Florida's Public Records 
Act. See endnote 1 below herein for referenced statutory text.' 
4. 
As noted above, on January 15, 2010, the Police and RC each served a 
Response And Objection To Subpoena Duces Tecum, attached hereto as Exhibit A 
and Exhibit B. respectively. Once again, the Police and RC generally cite to §119.07, 
and Chapter 119, Fla. Stat., and produced a small amount of documents that 
unilaterally redacted matters that "include, but are not limited to, the home addresses 
EFTA01076134

Page 3 
and telephone numbers of law enforcement personnel and identifying information 
regarding the victims." The Police and RC also claim that "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 Police "may also include 
exempted personal information including their home addresses, telephone numbers and 
social security numbers." See Exhibits A and B hereto. 
5. 
The claims of exemptions based on Chapter 119 and §119.07 have been 
improperly made. The scope of "public records" required to be made available for 
inspection and copying is rather broad. . "Public records" is defined rather broadly to 
include — 
all documents, papers, letters, maps, books, tapes, photographs, films, 
sound recordings, data processing software, or other material, regardless 
of the physical form, characteristics, or means of transmission, made or 
received pursuant to law or ordinance or in connection with the 
transaction of official business by any agency. 
§119.011(12), Fla. Stat. (eff. Oct. 1, 2008), and §119.011(11), Fla. Stat. (2006). 
(Bold emphasis added). Defendant is not seeking truly personal phone records, e-
mails, calendars, diaries, etc., or truly personal information of or about the Police. 
6. 
Defendant is not seeking truly personal phone records, e-mails, calendars, 
diaries, etc., or truly personal information of or about the Police. As set forth in the 
subpoenas, Defendant is seeking and is entitled to those records "made or received 
pursuant to law or ordinance or in connection with the transaction of official 
business by any agency." The investigation of EPSTEIN by the Police took place in 
EFTA01076135

Page 4 
2005 and 2006. It was a widespread investigation involving numerous Palm Beach 
Police Officers and Detectives; EPSTEIN was watched and placed under surveillance; 
his garbage was searched; numerous statements of potential witnesses and alleged 
victims were taken. In May, 2006, the Palm Beach Police claim its investigation ceased 
upon issuance of a Probable Cause Affidavit and the referral of the matter to state and 
federal law enforcement. Considering the scope of the investigation of EPSTEIN, the 
reality is that more documents and records exist than were produced by the Police and 
RC. 
7. 
The Police and RC have failed to comply with the procedures set forth in 
§119.07, Fla. Stat., which requires that the RC respond to records requests "promptly" 
and in "good faith." Pursuant to the statute, §119.07(1)(c), - "A good faith response 
includes making reasonable efforts to determine from other officers or employees within 
the agency whether such a record exists and, if so, the location at which the record can 
be accessed." 
8. 
In addition, when asserting an exemption, §119.07 further requires that — 
(d) A person who has custody of a public record who asserts that an 
exemption applies to a part of such record shall redact that portion of the 
record to which an exemption has been asserted and validly applies, and 
such person shall produce the remainder of such record for inspection and 
copying. 
(e) If the person who has custody of a public record contends that all or 
part of the record is exempt from inspection and copying, he or she shall 
state the basis of the exemption that he or she contends is applicable to 
the record, including the statutory citation to an exemption created or 
afforded by statute. 
EFTA01076136

Page 5 
(f) If requested by the person seeking to inspect or copy the record, the 
custodian of public records shall state in writing and with particularity the 
reasons for the conclusion that the record is exempt or confidential. 
9. 
The Police's and RC's Response and Objections fall woefully short of the 
statutory requirements in asserting that and exemption applies. 
The assertion of 
exemptions under Chapter 119 and 119.07 is so generalized that it is almost impossible 
to make any determination of what records the Police and RC have in their possession. 
Subpoenas Duces Tecum to Police — Nos. 1, 2, 12, 15. and 16. 
Subpoena Duces Tecum to RC — Nos. 1, 2, 4, and 20 
10. Specific to this motion, Defendant seeks to overrule certain of the objections 
and compel responses to Nos. 1, 2, 12, 15, and 16 of the duces tecum directed to the 
Police, and Nos. 1, 2, 4, and 20 directed to the RC. See Exhibits A and B. 
11. Contrary to the Police's and RC's response and objections to Nos. 1 and 2 of 
the Subpoenas Duces Tecum, Defendant is entitled to all electronic communications, 
including e-mails, related to the EPSTEIN matter, which were "made or received 
pursuant to law or ordinance or in connection with the transaction of official 
business by any agency." The definition of 'public records' encompasses electronic 
communications, including e-mails. The definition broadly includes "all documents, 
papers, letters, maps, books, tapes, photographs, films, sound recordings, data 
processing software, or other material, regardless of the physical form, characteristics, 
or means of transmission." Counsel for the Police and RC recently represented to 
Defendant's counsel that electronic communications, specifically e-mails, would 
be provided. If the electronic communications are provided, the motion to compel 
EFTA01076137

Page 6 
directed to those items will be withdrawn; however, until such items are provided, 
Defendant will pursue this motion to compel. 
12. The Police and RC generally claim without making any showing whatsoever 
that the request "is unduly burdensome and seeks information that is privileged under 
Florida's Public Records Law.° 
The burden of showing that they are entitled to a 
protective order falls on the Police and RC. There is absolutely no showing whatsoever 
in the record, by means of affidavit or otherwise, that responding to the request is 
unduly burdensome. Accordingly, the objection is required to be overruled and the 
Police and RC should be required to immediately produce the electronic 
communications and e-mails, and immediately produce a privilege log to any 
documents to which they are claiming a privilege applies. The Police and RC's actions 
have not been in good faith and have been meant to unduly delay discovery in this and 
other pending cases involving EPSTEIN. 
13. The burden of demonstrating good cause for the issuance of a protective order 
concerning a deposition duces tecum of a non-party witness, pursuant to Rule 
1.280(B)(1)(c), Fla. R. Civ. P., providing that, where good cause is demonstrated, trial 
court may make any order to protect a party or person from annoyance, 
embarrassment, oppression or undue burden, or expense, that justice requires, falls 
upon the party seeking that relief. Towers v. City of Longwood, 960 So.2d 845 (Fla. 51' 
DCA 2007). 
"An objection claiming an undue burden in responding to discovery 
requests must be supported by record evidence, such as an affidavit detailing the basis 
for claiming that the onus of supplying the information or documents is inordinate." 19A 
EFTA01076138

Page 7 
Fla.Jur.2d Discovery and Depositions §52, and cases cited therein. It is clear that the 
Police and RC have intentionally delayed discovery by generally asserting that the 
requests are burdensome in an effort to toll the otherwise mandatory requirement that a 
privilege log be compiled and produced "in a manner that, without revealing itself 
privileged or protected information, will enable other parties to assess the applicability of 
the privilege or protection." Rule 1.280(b)(5), Fla.R.Civ.P.; and see Gosman v. Luzinski, 
937 So.2d 293 (Fla. 4th DCA 2006), the case cited by RC and the Police in an effort to 
avoid preparing a privilege log and produce relevant documents. 
14. RC and the Police also generally raise a burdensome objection in response to 
No. 20 directed to RC and No. 15 directed to the Police. See Exhibits A and B. 
Again, absolutely no showing of undue burden is made in the record, and any such 
objection is required to be overruled. See law cited above in ¶13. In response to No. 
20 to the RC, the RC claims it cannot respond because it has no information regarding 
the identity of Jane Doe #4. However, RC is well aware that such information, if 
needed, is readily available from Defendant's counsel. 
As discussed above, the 
definition of public records is broad and encompasses the items sought by Defendant. 
It is the RC's burden to show that any claim exemption applies. The RC has not done 
this. 
15. Contrary to the Police's response to Nos. 15 and 16, the phone records and 
calendars, diaries, etc. pertaining to and related to the Town of Palm Beach's 
investigation of EPSTEIN are clearly relevant. See Exhibit A. Relevant evidence is 
evidence tending to prove or disprove a material fact. Id. Pursuant to Rule 1.280(b)(1), 
EFTA01076139

Page 8 
Fla.R.Civ.P., "Parties may obtain discovery regarding any matter, not privileged, that is 
relevant to the subject matter of the pending matter, whether it relates to the claim or 
defense of the party seeking discovery or the claim or defense of any other party, . . . It 
is not grounds for objection that the information sought will be inadmissible at the trial if 
the information sought appears reasonably calculated to lead to the discovery of 
admissible evidence." Id. Such information is likely to include the specific periods of 
times during which EPSTEIN was under surveillance; what a particular officer's 
schedule was as it related to the investigation of EPSTEIN. Such information logically 
leads to discovery questions as to when and what was observed during the course of 
the investigation. 
Again, the identity of the alleged victims and the truly personal 
information of the Police does not have to be compromised. (See Public Records Act). 
16. No. 4 directed to the RC again seeks information regarding the investigation 
of EPSTEIN that ultimately led to the Palm Beach Police referring the matter to the state 
and federal law enforcement authorities for review. See Exhibit B. The RC claims that 
other than correspondence dated May 1, 2006, and July 24, 2006, no other responsive 
documents exist. Again, the investigation of EPSTEIN went on for almost 2 years by 
Palm Beach. Based on the delays and not well taken objections of Palm Beach, 
Defendant wants a good faith review of the records to confirm that no other such 
records exist concerning the decision to send the matter to state and federal law 
enforcement. 
WHEREFORE, Defendant requests that this Court overrule the objections of the 
Police and RC, and grant the motion to compel such that the Police and RC produce the 
EFTA01076140

Page 9 
records sought either in whole or in a redacted form in conformance with Florida's 
Public Record's Act, and such that a privilege log be produced within 3 (three) days 
from the date of hearing on this matter so as to avoid delaying this matter any further. 
Certificate of Service 
I HEREBY CERTIFY that a true copy of the foregoing was sent by fax and U.S. 
Mail to the following addressees on this
 day of 
Theodore J. Leopold, Esq. 
Spencer T. Kuvin, Esq. 
Leopold-Kuvin, P.A. 
2925 PGA Blvd., Suite 200 
Palm Beach Gardens, FL 33410 
Fax: 
Counsel for Plaintiff 
Courtesy Copy to: 
Joanne O'Connor, Esquire 
Jones Foster Johnston & Stubbs, P.A. 
505 South Flagler Drive, Suite 1100 
West Palm Beach. FL 33401 
Fax: 
Counsel or t e own of Palm Beach 
, 2010: 
Jack Alan Goldberger, Esq. 
Atterbury Goldberger & Weiss, P.A. 
250 Australian Avenue South 
Suite 1400 
West Palm Beach, FL 33401-5012 
Fax: 
Co-Counse or e endant Jeffrey Epstein 
BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 
515 N. Flagler Drive, Suite 400 
West Palm Beach, Ft 33401 
By: 
Robe D. Griffon, Jr. 
Florida Bar #224162 
Michael J. Pike 
Florida Bar #617296 
(Counsel for Defendant Jeffrey Epstein) 
EFTA01076141

Page 10 
§119.071. General exemptions from inspection and copying of public records 
- (2) Agency investigations.-
•
investigations.-
§119.071(2)(j) -
1. Any document that reveals the identity, home or employment 
telephone number, home or employment address, or personal assets of 
the victim of a crime and identifies that person as the victim of a crime, 
which document is received by any agency that regularly receives 
information from or concerning the victims of crime, is exempt from s. 
119.07(1) and s. 24(a), Art. I of the State Constitution. Any information not 
otherwise held confidential or exempt from s. 119.07(1) which reveals the 
home or employment telephone number, home or employment address, or 
personal assets of a person who has been the victim of sexual battery, 
aggravated child abuse, aggravated stalking, harassment, aggravated 
battery, or domestic violence is exempt from s. 119.07(1) and s. 24(a), Art. I 
of the State Constitution, upon written request by the victim, which must 
include official verification that an applicable crime has occurred. Such 
information shall cease to be exempt 5 years after the receipt of the written 
request. Any state or federal agency that is authorized to have access to 
such documents by any provision of law shall be granted such access in the 
furtherance of such agency's statutory duties, notwithstanding this section. 
2. a. Any information in a videotaped statement of a minor who is alleged to 
be or who is a victim of sexual battery, lewd acts, or other sexual misconduct 
proscribed in chapter 800 or in s. 794.011, s. 827.071, s. 847.012, s. 
847.0125, s. 847.013, s. 847.0133, or s. 847.0145, which reveals that minor's 
identity, including, but not limited to, the minor's face; the minors home, 
school, church, or employment telephone number; the minors home, school, 
church, or employment address; the name of the minor's school, church, or 
place of employment; or the personal assets of the minor; and which 
identifies that minor as the victim of a crime described in this subparagraph, 
held by a law enforcement agency, is confidential and exempt from s. 
119.07(1) and s. 24(a), Art. I of the State Constitution. Any governmental 
agency that is authorized to have access to such statements by any 
provision of law shall be granted such access in the furtherance of the 
agency's statutory duties, notwithstanding the provisions of this section. 
EFTA01076142

Page 11 
b. A public employee or officer who has access to a videotaped statement of 
a minor who is alleged to be or who is a victim of sexual battery, lewd acts, or 
other sexual misconduct proscribed in chapter 800 or in s. 794.011, s. 
827.071, s. 847.012, s. 847.0125, s. 847.013, s. 847.0133, or s. 847.0145 
may not willfully and knowingly disclose videotaped information that reveals 
the minor's identity to a person who is not assisting in the investigation or 
prosecution of the alleged offense or to any person other than the defendant, 
the defendant's attorney, or a person specified in an order entered by the 
court having jurisdiction of the alleged offense. A person who violates this 
provision commits a misdemeanor of the first degree, punishable as provided 
in s. 775.082 or s. 775.083. 
• §119.071(2)(h)1 .b. 
1. The following criminal intelligence information or criminal investigative 
information is confidential and exempt from s. 119.07(1) and s. 24(a), Art. I of 
the State Constitution: 
a. Any information, including the photograph, name, address, or other fact, 
which reveals the identity of the victim of the crime of child abuse as defined 
by chapter 827. 
b. Any information which may reveal the identity of a person who is a 
victim of any sexual offense, including a sexual offense proscribed in 
chapter 794, chapter 796, chapter 800, chapter 827, or chapter 847. 
• §119.071(4)(d)1.a. 
(4) Agency personnel information.—
(d) 1. a. The home addresses, telephone numbers, social security numbers, 
and photographs of active or former law enforcement personnel, including 
correctional and correctional probation officers, personnel of the Department 
of Children and Family Services whose duties include the investigation of 
abuse, neglect, exploitation, fraud, theft, or other criminal activities, 
personnel of the Department of Health whose duties are to support the 
investigation of child abuse or neglect, and personnel of the Department of 
Revenue or local governments whose responsibilities include revenue 
collection and enforcement or child support enforcement; the home 
addresses, telephone numbers, social security numbers, photographs, and 
places of employment of the spouses and children of such personnel; and 
the names and locations of schools and day care facilities attended by the 
children of such personnel are exempt from s. 119.07(1). 
EFTA01076143

Page 12 
NOTE: The above quoted provisions are from the current version of the statute. 
EFTA01076144

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. 
EXHIBIT A
EFTA01076145

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-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 were produced on December 9, 2009. 
2. 
Any and all electronic communications (EMAIL) between you 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 Attorney's 
Office, (D) any member of the Office of the State Attomey (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 
EFTA01076146

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 
EFTA01076147

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 wore 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 
EFTA01076148

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. 4th 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 
EFTA01076149

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. 4Ih DCA 2006). 
17. 
Any and all reports, memoranda, and notes of any communication 
between you 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 you, 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, ether 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 
EFTA01076150

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, Luttier & 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 
33402-3475 
Telephone: 
Facsimile* 
1-650-0465 
By 
PADOCS1131565O031SPLD11753111.DOC 
C. Randolph 
F rida Bar No. 129000 
jrandoloheiones-foster.com 
7 
EFTA01076151

2-
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 
EXHIBIT 
EFTA01076152