EFTA00726075.pdf

EXHIBIT "A" 1. Any and all written reports, notes, memoranda or other papers authored by ysti 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 Unites 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. 2. Any and all electronic communications (EMAIL) between vs 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 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. 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. 4. Any and all notes, memoranda or reports reflecting any attempts by yag to initiate or encourage a federal review of any facet/aspect of the Epstein investigation or State prosecution of Epstein. 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. 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 "M."* 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. 7. Any and all notes, memoranda, or reports reflecting any communication between u or any other member of the Palm Beach Police Department with "M."* or referencing "M."* in relation to her being subpoenaed to testify before or her requested attendance before a State Grand Jury where a.1 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. EFTA00726075 8. Any and all agreements, memoranda, and/or notes of any kind, electronic or otherwise, between y..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 "M." at any time. 9. Any and all notes, memoranda, or reports of meetas or communications between you and 1.1."*, her parents, or any lawyers who represent "M."* 10. Any and all records of expenditures made or incurred by yn, and all requests for expenditures relating to the criminal investigation of Mr. Epstein. II. 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. 12. 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 of 2004 or on any other occasion. 13. 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 2004. 14. All cell phone records, both official cell phone and personal cell phone, used by yint 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. 15. 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. 16. 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. EFTA00726076 17. 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. 18. 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 thorough and including today. 19. Any and all audio tapes of any witnesses that yai or any member of the Palm Beach Police Department obtained statements or interviews from, either sworn or informal, with regard to the Epstein investigation. * The initials IM. and M. refer to the individuals identified in the Palm Beach County Probable Cause Affidavit as it relates to the Jeffrey Epstein investigation. Shona, require the complete name of the individuals, please contact Jessica Cadwell at EFTA00726077