HOUSE_OVERSIGHT_015607.jpg

Declaration dated February 5, 2015, which were filed with the United States District Court for the Southern District of Florida, in Jane Doe #1 and Jane Doe #2 v. United States of America, Case No. OS-S0736-CIV-MARRA/JOHNSON, [ECF No. 291-1] (the "Federal Action").” Defendant should not be using the subpoena power of this Court to issue a non-party subpoena for documents sought for a federal action.” c. Category 3 — Documents that Contain Personal Financial Information Completely Irrelevant to this Action Defendant also wrongfully abuses the subpoena power to seek personal financial information from this non-party. See Woodward v. Berkery, 714 So. 2d 1027, 1034-38 (Fla. 4" DCA 1998) (quashing lower court’s discovery order and finding irreparable harm to husband in disclosure of private financial information when wife’s clear purpose was to wrongfully disclose the financial information to the press) (emphasis added); see also Granville v. Granville, 445 So. 2d 362 (Fla. 1" DCA 1984) (court of appeal overturning denial of protective order and finding that private financial information should have been protected from disclosure). The requests are clearly meant to intimidate and harass her by, for example, seeking information during the time she was the subject of sexual trafficking by Jeffrey Epstein. Request no. 20 seeks “All documents showing any payments or remuneration of any kind made by Jeffery Epstein or any of his agents or associates to you from January 1, 1999 through December 31, 2002.” Whether Jeffrey Epstein paid minor children that he sexually trafficked has absolutely nothing to do with the action before this Court and there is no basis to force a non-party who was subject to this abuse to comply with a production demand on this topic. The subpoena also includes request for financial information relating to the media. Apparently, Defendant believes Jane Doe No. 3 has a book “deal” in the works. For example, Request no. 18 seeks: “All documents concerning any monetary payments or other consideration received by you from any > The requests relevant to this category are nos.: 1, 5, 6,7, 8, 9, 12, 13, 14, 22, and 24. 9 HOUSE_OVERSIGHT_015607