EFTA00088596.pdf

U.S. Department of Justice United States Attorney Southern District of New York The Silvio J. Motto Building One Saint Andrew s Plaza New York, New York 10007 March 26, 2021 VIA EMAIL IMIW Esq. 2139 Palm Beach Lakes Blvd. West Palm Beach FL 33409-6601 Re: Grand Jury Subpoena Please be advised that the accompanying grand jury subpoena has been issued in connection with an official criminal investigation of a suspected felony being conducted by a federal grand jury. The Government hereby requests that you voluntarily refrain from disclosing the existence of the subpoena to any third party. Though you are under no obligation to comply with our request, we are requesting you not to make any disclosure in order to preserve the confidentiality of the investigation and because disclosure of the existence of this investigation might interfere with and impede the investigation. If you intend to disclose the existence of this Grand Jury Subpoena request to a third party, please let me know before making any such disclosure. Thank you for your cooperation in this matter. By: Very truly yours, Audrey Strauss United States Attorney Assistant United States Attorney EFTA00088596 Grand Jury Subpoena SOUTHERN DISTRICT OF NEW YORK TO: , Esq. 2139 Palm Beach Lakes Blvd. West Palm Beach FL 33409-6601 GREETINGS: WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend before the GRAND JURY of the people of the United States for the Southern District of New York, at the United States Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New York, New York, in the Southern District of New York, at the following date, time and place: Appearance Date: April 5, 2021 Appearance Time: 10:00 am to testify and give evidence in regard to an alleged violation o£ 18 U.S.C. §§ 1591, 2423(a), 2422(b) and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you bring with you and produce at the above time and place the following: SEE ATTACHED RIDER N.B.: Personal appearance is not required if the re uested records are (1) produced by on or before the return date to Assistant U.S. Attorney at: U.S. Attome 's Office, Southern District of New York, 1 St. Andrew's Plaza, New York, NY 10007, telephone: or via email at and (2) accompanied by an executed copy of the attached Declaration of Custodian of Records. PLEASE PROVIDE IN ELECTRONIC FORMAT IF POSSIBLE. Failure to attend and produce any items hereby demanded will constitute contempt of court and will subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law. DATED: New York, New York March 26, 2021 egkg/tea Audrey Strauss United States Attorney for the Southern District of New York Assistant United States Attorney One St. Andrew's Plaza New York, New York 10007 EFTA00088597 RIDER (Grand Jury Subpoena to Esq. dated March 26, 2021) Instructions and Definitions: I. This Subpoena calls for the production of categories of documents, as specified below, in the possession, custody, or control of Esq. 2. This subpoena covers all responsive documents wherever they may be found, including on computers, servers, and personal electronic devices, whether in the United States or any foreign jurisdiction. 3. The "Litigation" means the civil lawsuit filed by against Jeffrey Epstein on behalf of plaintiff under the case caption Jane Doe No. 2 v. Epstein, No. 08 Civ. 80119 in the United States District Court for the Southern District of Florida. 4. Where possible, please produce the records requested herein in electronic form. 5. This subpoena does not call for the production of any documents protected by a valid claim of privilege, although any responsive document over which privilege is being asserted must be preserved. Any documents withheld on grounds of privilege may be required to be specifically identified on a privilege log with descriptions sufficient to identify their dates, authors, recipients, and general subject matter. Materials To Be Produced: I. All non-privileged documents relating to the settlement of the Litigation, including any and all settlement agreements between the parties. N.B.: Personal appearance is not required if the re uested records are (1) produced by on or before the return date to Assistant U.S. Attorney at: U.S. Attorne 's Office. Southern District of New York, 1 St. Andrew's Plaza, New York, NY 10007, telephone: or via email at ; and (2) accompanied by an executed copy of the attached Declaration of Custodian of Records. PLEASE PROVIDE IN ELECTRONIC FOR NIkT IF POSSIBLE. EFTA00088598 Declaration of Custodian of Records Pursuant to 28 U.S.C. K 1746, I, the undersigned, hereby declare: My name is (name of declarant) I am a United States citizen and I am over eighteen years of age. I am the custodian of records of the business named below, or I am otherwise qualified as a result of my position with the business named below to make this declaration. I am in recei t of a Grand Jury Subpoena, dated March 26, 2021 and signed by Assistant United States Attorney requesting specified records of the business named below. Pursuant to Rules 902(11) and 803(6) of the Federal Rules of Evidence, I hereby certify that the records provided herewith and in response to the Subpoena: (1) were made at or near the time of the occurrence of the matters set forth in the records, by, or from information transmitted by, a person with knowledge of those matters; (2) were kept in the course of regularly conducted business activity; and (3) were made by the regularly conducted business activity as a regular practice. I declare under penalty of perjury that the foregoing is true and correct. Executed on (date) (signature of declarant) (name and title of declarant) (name of business) (business address) Definitions of terms used above: As defined in Fed. R. Evid. 803(6), "record" includes a memorandum, report, record, or data compilation, in any form, of acts, events, conditions, opinions, or diagnoses. The term, "business" as used in Fed. R. Evid. 803(6) and the above declaration includes business, institution, association, profession, occupation, and calling of every kind, whether or not conducted for profit. EFTA00088599