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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. 
My 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 
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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 
"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 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. 
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EFTA01076154

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"l'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.Gn*. 
RESPONSE: All responsive documents in the possession, custody or 
control of the Town Police Department wero 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 
EFTA01076155

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 
EFTA01076156

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, P.A., 2925 PGA Boulevard, Suite 200, Palm Beach 
Gardens, Florida 33410; Jack Alan Goldberger, Esquire, Atterbury Goldberger & 
Weiss, PA 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 
9
 c11taTr:f January, 2010. 
JONES, FOSTER, JOHNSTON & STUBBS, 
PA 
505 South Flagler Drive, Suite 1100 
Post Office Box 3475 
West Palm Be 
33402-3475 
Telephone: 
Facsimile: 
By 
PADOCS \1315b100315NPLD11753150.DOC 
ffrrif
ietir
 - 
ohn C. Randolph 
Florida Bar No. 129000 
[email protected]
6 
EFTA01076157