Latest / The Epstein Chronicles / Mega Edition: The USVI Targets Glenn Dubin And Bella Klein In Their Investigation (9/5/26)

Transcript

Mega Edition: The USVI Targets Glenn Dubin And Bella Klein In Their Investigation (9/5/26) · The Epstein Chronicles

• 0:00
  Speaker 1: Hello everyone and welcome to the Jeffrey Epstein Show. I'm
• 0:04
  Speaker 1: your host, Bobby Cappucci, and this is a morning update.
• 0:10
  Speaker 1: What's going on everybody? So I've had a lot of
• 0:11
  Speaker 1: people ask me about the pictures that I post on Twitter,
• 0:16
  Speaker 1: and some folks were asking if those prints were for sale.
• 0:21
  Speaker 1: And the good news is, they most certainly are. I
• 0:24
  Speaker 1: have a profile set up on Picfair, where you can
• 0:29
  Speaker 1: go over and purchase some of my prints. Right now,
• 0:33
  Speaker 1: I have four prints on there, I believe. And by
• 0:36
  Speaker 1: the end of the day today, there will be 12
• 0:40
  Speaker 1: or so on there. So make sure that if you're
• 0:44
  Speaker 1: interested in some of those pictures, and you've sent me
• 0:47
  Speaker 1: a message before asking about them, well, they will be
• 0:50
  Speaker 1: there now for purchase if that is something you are
• 0:54
  Speaker 1: interested in. Now, as you all know, I really don't
• 0:57
  Speaker 1: have much to sell you as far as the Jeffrey
• 0:59
  Speaker 1: Epstein case goes. I'm not writing any books or any
• 1:03
  Speaker 1: of that stuff at all. It's just with the pictures,
• 1:07
  Speaker 1: it's something that I've always really enjoyed doing, right? And
• 1:12
  Speaker 1: now that PicFair has a place where I could just
• 1:14
  Speaker 1: post my pictures the same as I would on like
• 1:17
  Speaker 1: Instagram or something. And it gives people the ability to
• 1:21
  Speaker 1: purchase them if they'd like. I think that's a pretty
• 1:23
  Speaker 1: cool deal. So if you're interested in those kind of pictures,
• 1:27
  Speaker 1: landscape pictures, pictures of, you know, the great Southwest, mainly Nevada, Arizona, Utah,
• 1:37
  Speaker 1: Southern California, national parks all across the West Coast, that
• 1:42
  Speaker 1: kind of stuff. If you're interested in that, the link
• 1:44
  Speaker 1: to the pick fair page will be in the description
• 1:49
  Speaker 1: box along with the link to this article that we're
• 1:53
  Speaker 1: going to get into, and to the PayPal if you're
• 1:57
  Speaker 1: looking to help out the podcast. All right, so on
• 2:02
  Speaker 1: to today's article. We're going to talk a little bit
• 2:05
  Speaker 1: about this article in the New York Post about Glenn
• 2:09
  Speaker 1: Dubin and the subpoena from the Virgin Islands. Now, we
• 2:13
  Speaker 1: were way ahead of the curve here, right? OK Magazine
• 2:17
  Speaker 1: and Chris Spargo talked about this a couple of weeks ago.
• 2:21
  Speaker 1: And like I've said, Chris Spargo over at OK Magazine
• 2:24
  Speaker 1: has been all over this. And they've done a fantastic
• 2:28
  Speaker 1: job with the news that's coming out of the Virgin Islands.
• 2:31
  Speaker 1: And Chris especially deserves a tip of the cap, no
• 2:34
  Speaker 1: doubt about it. Him, Kate Bricklett, those are two of
• 2:39
  Speaker 1: the journalists that have been covering this case that really
• 2:42
  Speaker 1: stand out to me, that have done a fantastic job.
• 2:45
  Speaker 1: And I think that it's pretty telling. that OK Magazine
• 2:50
  Speaker 1: and Chris Spargo are so ahead of the curve when
• 2:53
  Speaker 1: it comes to this subpoena situation. Now, the New York
• 2:56
  Speaker 1: Post is usually way out ahead of things when it
• 2:59
  Speaker 1: comes to page six kind of reporting. But this comes
• 3:05
  Speaker 1: a few weeks after we had originally learned about this.
• 3:09
  Speaker 1: The reason I'm adding it to the catalog this morning is,
• 3:12
  Speaker 1: like usual, we'll get some context and perhaps we'll glean
• 3:17
  Speaker 1: a little nugget or two that we missed the first
• 3:20
  Speaker 1: time around. So we're going to talk about bitch-ass Glenn
• 3:24
  Speaker 1: Dubin and the fact that him and his wife were
• 3:28
  Speaker 1: a lot closer to Jeffrey Epstein than they'd like to
• 3:32
  Speaker 1: let on. And now Denise George, man, I almost just
• 3:37
  Speaker 1: called her Denise Richards, Denise George down in the Virgin Islands,
• 3:41
  Speaker 1: the Attorney General down there, she is involved in a
• 3:45
  Speaker 1: civil RICO case right now against Epstein and his estate.
• 3:49
  Speaker 1: And she has fired off all sorts of subpoenas to
• 3:52
  Speaker 1: Glenn Dubin in relation to Glenn Dubin's children and their
• 3:57
  Speaker 1: relationship with Jeffrey Epstein. So shit's getting hot and heavy
• 4:01
  Speaker 1: down in the Virgin Islands, as we have known. And
• 4:04
  Speaker 1: let me tell you what, as much as I'm not
• 4:08
  Speaker 1: a fan of Denise George looking for that money grab,
• 4:11
  Speaker 1: I am a big fan of the way she has
• 4:13
  Speaker 1: pursued this. I'm a big fan of her firing off
• 4:16
  Speaker 1: a grip of subpoenas. And I want more, right? I
• 4:19
  Speaker 1: think that not only subpoenas, there should be some indictments
• 4:23
  Speaker 1: down there and she should arrest some people. That would
• 4:26
  Speaker 1: be fantastic. Let's turn this civil racketeering case into an
• 4:30
  Speaker 1: actual criminal RICO case down in the Virgin Islands and
• 4:34
  Speaker 1: then have two concurrent RICO investigations running at the same time. Boy,
• 4:38
  Speaker 1: that would be fantastic. And that certainly would make up
• 4:41
  Speaker 1: some ground that they have lost throughout these decades, huh?
• 4:46
  Speaker 1: All right, so our article, New York Post. Headline, Jeffrey
• 4:50
  Speaker 1: Epstein case subpoena seeks documents related to billionaire Glenn Dubin's kids. Author,
• 4:57
  Speaker 1: Isabel Vincent. Now, let's just pump the brakes right away.
• 5:01
  Speaker 1: Imagine being Glenn Dubin and his wife and having your
• 5:05
  Speaker 1: kids embroiled in this whole entire brouhaha. You are supposed
• 5:12
  Speaker 1: to protect your children from shit like this. Not have
• 5:15
  Speaker 1: them hang out with Uncle Jeffy. Not have Uncle Jeffy
• 5:18
  Speaker 1: have a trust in their name. Not have Uncle Jeffy
• 5:21
  Speaker 1: as the godfather. And certainly, the last thing you want
• 5:25
  Speaker 1: is your children's names being brought up in an investigation
• 5:29
  Speaker 1: into one of the most prolific pedophiles in the history
• 5:33
  Speaker 1: of America. Talk about a failure as a human and
• 5:37
  Speaker 1: talk about a failure as a parent. It just goes
• 5:40
  Speaker 1: to show you all the money in the world, all
• 5:42
  Speaker 1: of the status in the world doesn't mean shit if
• 5:45
  Speaker 1: you're a douche. U.S. Virgin Islands prosecutors are demanding billionaire
• 5:53
  Speaker 1: MoMA benefactor and board member Glenn Dubin turn over all
• 5:57
  Speaker 1: communications that his friend Jeffrey Epstein had with Dubin's three children.
• 6:02
  Speaker 1: It's gross, right, to read that. I know I have
• 6:05
  Speaker 1: a penchant for being a sarcastic person when it comes
• 6:09
  Speaker 1: to this stuff. And I think that that is the
• 6:14
  Speaker 1: proper measure when we're dealing with these people. But at
• 6:17
  Speaker 1: the same time, it's spine tingling and gross and chilling
• 6:22
  Speaker 1: to think that your children would be involved in a
• 6:26
  Speaker 1: subpoena that has to do with Jeffrey Epstein. Now, look.
• 6:30
  Speaker 1: I'm not a parent. I don't have any kids. I
• 6:32
  Speaker 1: have four dogs. Those are like my kids. And I
• 6:35
  Speaker 1: wouldn't let my dogs spend a minute with Jeffrey Epstein.
• 6:38
  Speaker 1: Never mind my children. And then you want to add
• 6:43
  Speaker 1: a little whipped cream on top of that banana split?
• 6:46
  Speaker 1: Oh yeah, now your kids' names are being brought up
• 6:49
  Speaker 1: in legal documents, subpoenas, that have to do with Jeffrey
• 6:53
  Speaker 1: Epstein's criminal enterprise. Glenn Dubin, Eva Dubin, You both suck.
• 7:02
  Speaker 1: As human beings. And obviously as parents. A subpoena seeks
• 7:09
  Speaker 1: all documents and communications... Related to any of your three children. May,
• 7:13
  Speaker 1: Selena or Jordan. Which also relate in any way to
• 7:18
  Speaker 1: Jeffrey Epstein. Or any Epstein entity. This is how you
• 7:21
  Speaker 1: put the pieces together folks. This is how you build
• 7:24
  Speaker 1: a case. Remember when I told you that Rico is
• 7:28
  Speaker 1: very invasive... And that RICO charges are far-reaching, meaning even
• 7:35
  Speaker 1: people in your family can get caught up in it? Well,
• 7:39
  Speaker 1: you're seeing it here, but in a civil version. Now,
• 7:42
  Speaker 1: the criminal version of this is even worse, even more draconian.
• 7:47
  Speaker 1: You ask me how I know? Well, I've experienced it
• 7:49
  Speaker 1: firsthand in my life. I've had a loved one face
• 7:53
  Speaker 1: RICO charges. I've had a loved one look at a
• 7:58
  Speaker 1: hundred RICO charges. And that's what they do. They throw
• 8:03
  Speaker 1: a bunch of RICO charges at you and then they
• 8:05
  Speaker 1: go after the people that you loved, anybody you might
• 8:07
  Speaker 1: have given money to. They'll tap your children's phones. They'll
• 8:11
  Speaker 1: do all sorts of wild shit when they have RICO power.
• 8:17
  Speaker 1: And you see that here when they're bringing up the
• 8:19
  Speaker 1: names of his children and it's just the part and
• 8:24
  Speaker 1: parcel for how a RICO investigation is conducted. And once
• 8:29
  Speaker 1: the FBI gets their teeth sunk in on a RICO investigation,
• 8:32
  Speaker 1: at least to regular folks, Italian folks anyway, because I
• 8:38
  Speaker 1: can only speak about my experiences and what my people
• 8:40
  Speaker 1: have dealt with. So when they start with that RICO shit,
• 8:44
  Speaker 1: forget it. It doesn't matter if you're a 16-year-old kid
• 8:47
  Speaker 1: walking home from school. They're going to try and hem
• 8:49
  Speaker 1: you up and ask you about your loved one. Try
• 8:52
  Speaker 1: and put you in the back of that car. They're
• 8:53
  Speaker 1: going to try and threaten you. They're going to try
• 8:56
  Speaker 1: and tell you that your parents are going to go
• 8:58
  Speaker 1: to jail if you don't talk to them. And this
• 9:01
  Speaker 1: is the kind of shit the FBI does against us,
• 9:03
  Speaker 1: the average citizen. But when it comes to bitch-ass mother
• 9:07
  Speaker 1: effers like Glenn Dubin and the rest of this posse
• 9:10
  Speaker 1: of scumbags, they don't get that kind of treatment. They
• 9:14
  Speaker 1: get overlooked. They get lost in the sauce. They get
• 9:18
  Speaker 1: moved around in the system. But me or you or
• 9:23
  Speaker 1: your loved one, forget it. They get involved in bookmaking? Well,
• 9:28
  Speaker 1: they're looking at seven years, seven prime years taken away
• 9:31
  Speaker 1: from them and from them and their families. Meanwhile, Jeffrey Epstein,
• 9:36
  Speaker 1: 13 months? I'll just say right now, straight up, point blank, period,
• 9:42
  Speaker 1: F the FBI, okay? They're a bunch of scumbags. They're corrupt.
• 9:46
  Speaker 1: The whole organization is corrupt, in my opinion. The island's
• 9:53
  Speaker 1: attorney general is probing alleged racketeering by the late billionaire
• 9:56
  Speaker 1: pedophile and has issued subpoenas to numerous Epstein associates. including lawyers,
• 10:01
  Speaker 1: accountants and bankers. Now, again, I really wish that we'd
• 10:05
  Speaker 1: see this in the SDNY. And I think we're going
• 10:09
  Speaker 1: to once we get another arrest, if we get another arrest.
• 10:13
  Speaker 1: But I'm on record saying that if it doesn't go RICO,
• 10:17
  Speaker 1: then in my opinion, the fix is most certainly in.
• 10:20
  Speaker 1: And that will be the most telling sign that the
• 10:22
  Speaker 1: elite are once again protecting the elite. This is a
• 10:26
  Speaker 1: Rico case if I have ever seen one. And we
• 10:30
  Speaker 1: have the proof right there in the pudding. With Keith
• 10:34
  Speaker 1: Ranieri getting himself 120 years under Rico and racketeering. Allison
• 10:39
  Speaker 1: Mack gets charged with racketeering and Rico. But Ghislaine Maxwell doesn't.
• 10:44
  Speaker 1: It doesn't sit well with me. And if it doesn't
• 10:48
  Speaker 1: go Rico... then you know for a fact that the
• 10:52
  Speaker 1: fix is in and I will definitely be on every
• 10:55
  Speaker 1: mountaintop yelling even louder than I am now about the
• 10:58
  Speaker 1: corruption in the government. And for those of you who
• 11:01
  Speaker 1: think that Joe Biden is going to ride in on
• 11:04
  Speaker 1: his white horse swinging his sword and cutting down all
• 11:08
  Speaker 1: of the orcs of evil around us, folks, I got
• 11:11
  Speaker 1: bad news for you. Meet the new boss, same as
• 11:16
  Speaker 1: the old boss. The idea is Is to stop sending people.
• 11:21
  Speaker 1: Like Biden. To D.C. And. I get it right. A
• 11:27
  Speaker 1: lot of people hate Trump. And they you know. This
• 11:30
  Speaker 1: was a referendum on Trump. And I understand completely. But
• 11:34
  Speaker 1: at the same time. You must stay vigilant. just because
• 11:37
  Speaker 1: Biden has been elected as the president-elect of the United
• 11:40
  Speaker 1: States of America, doesn't mean that we all throw up
• 11:43
  Speaker 1: our hands and say, all right, things are going to
• 11:45
  Speaker 1: go back to normal. Everything's good. Nothing is good. Nothing
• 11:48
  Speaker 1: is normal. We've had a look behind the curtain now, folks.
• 11:51
  Speaker 1: We can't go back. It's only moving forward now. There
• 11:58
  Speaker 1: is no retreating. There is no regrouping. There is forming
• 12:02
  Speaker 1: a vanguard and smashing hard right into the heart Of
• 12:07
  Speaker 1: the elite's lines. And crushing them. And putting them on
• 12:10
  Speaker 1: their back foot. And making them scatter for once. And
• 12:14
  Speaker 1: that's going to happen. If we do it. No politician
• 12:18
  Speaker 1: is going to save us. Joe Biden or otherwise. One
• 12:24
  Speaker 1: of you. Out there in the audience. Run for office.
• 12:29
  Speaker 1: You might save us. One of you good hearted people.
• 12:31
  Speaker 1: With a moral compass. Who understands. That the work of
• 12:34
  Speaker 1: the people is more important than enriching yourself. You might
• 12:37
  Speaker 1: save us, but none of these retread-ass politicians are going
• 12:40
  Speaker 1: to save us. Just like none of these asshole coaches
• 12:43
  Speaker 1: who have never succeeded anywhere in the NFL are going
• 12:47
  Speaker 1: to make a team succeed magically when they get hired again. Epstein,
• 12:56
  Speaker 1: who hanged himself, allegedly, in a Manhattan lockup last year,
• 13:00
  Speaker 1: had openly declared his plans to marry Selena Dubin, sources
• 13:04
  Speaker 1: told Binnis Insider last year. Epstein and Selena developed an
• 13:10
  Speaker 1: especially close relationship when Selena was 12 and it continued
• 13:14
  Speaker 1: into adulthood, according to the Palm Beach Post. The whole
• 13:18
  Speaker 1: thing was weird, right? This whole thing with Selena Dubin
• 13:21
  Speaker 1: and Jeffrey Epstein? Always odd, in my opinion. I mean,
• 13:26
  Speaker 1: why in the hell, as an adult, as a parent,
• 13:29
  Speaker 1: would you have this little kid calling Jeffrey Epstein Uncle
• 13:32
  Speaker 1: Jeffy sitting on his lap? You know what he was. Hell,
• 13:37
  Speaker 1: after he was arrested, you had him over for some
• 13:38
  Speaker 1: good old turkey dinner. Meanwhile, you're going to try and
• 13:44
  Speaker 1: distance yourself from Jeffrey Epstein? You're going to try and
• 13:48
  Speaker 1: act like you weren't one of his top dogs? And
• 13:51
  Speaker 1: that your wife wasn't his chick back in the day?
• 13:53
  Speaker 1: Who knows? You guys might have still been doing the
• 13:56
  Speaker 1: same kind of thing. You might have still been... Who
• 13:59
  Speaker 1: knows what kind of relationship these people had. Maybe they
• 14:02
  Speaker 1: were involved in a thruple. Who the hell knows? My
• 14:04
  Speaker 1: point is this. They were very, very close to Jeffrey Epstein.
• 14:11
  Speaker 1: Selena wrote glowingly of their weekly science lesson... When Uncle Jeff,
• 14:15
  Speaker 1: as she calls him... Takes time from his personal business schedule...
• 14:19
  Speaker 1: To go over to her apartment and discuss science and
• 14:22
  Speaker 1: mathematics lessons she is learning at school, reported the newspaper,
• 14:27
  Speaker 1: citing a profile prepared by Epstein's lawyers in 2007, the
• 14:31
  Speaker 1: year they negotiated a non-prosecution agreement that allowed him to
• 14:35
  Speaker 1: avoid federal sex trafficking charges. So the most ironic thing
• 14:42
  Speaker 1: about this is is that the Dubins themselves opened their
• 14:46
  Speaker 1: mouth and this can of worms by writing this glowing
• 14:49
  Speaker 1: report for Jeffrey Epstein. They involved their daughter. They brought
• 14:52
  Speaker 1: their kids into this. And they were the ones who
• 14:55
  Speaker 1: put their kids in jeopardy, in my opinion, by having
• 14:58
  Speaker 1: them around a scumbag like Uncle Jeffy Epstein. There is
• 15:04
  Speaker 1: no evidence that Epstein ever had a romantic relationship with Selena,
• 15:08
  Speaker 1: now 25, according to Business Insider. adding that his motivation
• 15:13
  Speaker 1: to marry her might have been driven by his desire
• 15:16
  Speaker 1: to leave her his fortune and avoid inheritance taxes. That
• 15:19
  Speaker 1: makes no sense, okay? Sorry, really? Jeffrey Epstein, Mr. Scumbag,
• 15:25
  Speaker 1: extraordinaire himself, couldn't have found a way to launder that
• 15:28
  Speaker 1: money to marry her? That's why he wanted to marry her? No,
• 15:31
  Speaker 1: let's stop making excuses for these people. He wanted to, quote-unquote,
• 15:35
  Speaker 1: I'm using air quotes right here, folks, you can't see me,
• 15:37
  Speaker 1: but that's what I'm doing. He wanted to marry her? No.
• 15:40
  Speaker 1: He wanted to be... romantically involved with her he wanted
• 15:44
  Speaker 1: to abuse her and he wanted to do what he
• 15:47
  Speaker 1: did with every other young teenage girl he came into
• 15:50
  Speaker 1: contact with alright let's not sugarcoat it anymore let's not
• 15:54
  Speaker 1: cut corners let's not act like Glenn Dubin and his
• 15:57
  Speaker 1: wife deserve the benefit of the doubt they do not Look,
• 16:02
  Speaker 1: this isn't like a regular case, right? Where everything's happening
• 16:05
  Speaker 1: in real time and shit's convoluted and we don't know
• 16:09
  Speaker 1: up from down. There's spin, there's propaganda. Of course there's that.
• 16:14
  Speaker 1: But we've had plenty of years to go through all
• 16:18
  Speaker 1: of these details with a fine-tooth comb. We've had plenty
• 16:21
  Speaker 1: of time to compile these articles. And we know from
• 16:24
  Speaker 1: the articles that we have read about Glenn Dubin and
• 16:28
  Speaker 1: his wife that they are scuzzbags and that they are
• 16:33
  Speaker 1: very much involved with Jeffrey Epstein on an intimate level.
• 16:37
  Speaker 1: No pun intended. The subpoena, which was filed in Virgin
• 16:42
  Speaker 1: Island Superior Court in September, is also seeking all financial
• 16:46
  Speaker 1: records between Dubin, who is married to Epstein's former beauty
• 16:49
  Speaker 1: queen girlfriend, Eva Anderson Dubin, and Epstein. It also seeks
• 16:54
  Speaker 1: all documents and communications with a Swedish female traveling with
• 16:58
  Speaker 1: or employed by Epstein. That's huge. That is the little
• 17:02
  Speaker 1: girl that cried to the guy in Dubin and Eva
• 17:10
  Speaker 1: Andersson's kitchen. Right? The little Swedish girl that we've talked
• 17:13
  Speaker 1: about that we always wondered what the hell happened to
• 17:15
  Speaker 1: this kid. Well... She is also involved in this, and
• 17:20
  Speaker 1: they're asking for documentation that has to do with their
• 17:23
  Speaker 1: contact with this unnamed 15-year-old Swedish girl. Who in the
• 17:27
  Speaker 1: hell is this poor kid, folks? Where is she? What
• 17:30
  Speaker 1: has become of her? And I can only hope that
• 17:34
  Speaker 1: she is doing okay now. Court papers unsealed a day
• 17:40
  Speaker 1: before Epstein's death last year included allegations that a 15-year-old
• 17:44
  Speaker 1: Swedish girl was held against her will on Epstein's compound
• 17:48
  Speaker 1: in the Virgin Islands. The girl allegedly told her story
• 17:52
  Speaker 1: to Rinaldo Rizzo, a chef who worked for the Dubin family,
• 17:56
  Speaker 1: according to court papers. Now remember, this isn't just hearsay.
• 17:59
  Speaker 1: This isn't just shit thrown at the wall. That's for
• 18:02
  Speaker 1: other people involved in this Jeffrey Epstein case to do.
• 18:05
  Speaker 1: That's another, that's another, that's an adventure for them to
• 18:08
  Speaker 1: take you on. We don't do that here on this podcast, okay?
• 18:12
  Speaker 1: Our work speaks for itself. Everything we talk about is
• 18:15
  Speaker 1: in the newspapers and based on court documentation. When I
• 18:19
  Speaker 1: go hard on somebody here on the podcast, you better
• 18:21
  Speaker 1: damn believe there is a reason, folks. And that is
• 18:26
  Speaker 1: exactly what we have here with the Dubins. All of
• 18:29
  Speaker 1: this stuff is court documented. This man gave this statement
• 18:34
  Speaker 1: under oath. And it's obvious that the Dubins are being
• 18:38
  Speaker 1: protected right along with Jeffrey Epstein. But they shouldn't be.
• 18:42
  Speaker 1: Our prosecutors and our justice system should be big game
• 18:46
  Speaker 1: hunting right now. Both Dubin and his wife, who dated
• 18:51
  Speaker 1: Epstein for 11 years, have vigorously denied any knowledge of
• 18:55
  Speaker 1: Epstein's wrongdoing. A spokesman for Dubin refused to comment last week.
• 19:00
  Speaker 1: And let's not forget also, okay, the 500-pound gorilla in
• 19:05
  Speaker 1: the room. Not only is Dubin accused of all of
• 19:09
  Speaker 1: this nonsense, okay? Let's not forget what Virginia alleges happened
• 19:14
  Speaker 1: to her at the hands of Glenn Dubin when she
• 19:17
  Speaker 1: was trafficked to him. All right, let's keep that in
• 19:21
  Speaker 1: the forefront of our mind. And the scumbags who have
• 19:25
  Speaker 1: been mentioned by Virginia as people who have actually partaken
• 19:28
  Speaker 1: in the abuse, those people all need to be brought
• 19:32
  Speaker 1: in under the auspices of this grand investigation. They all
• 19:37
  Speaker 1: need to be spoken with. Those aren't allegations of stealing
• 19:41
  Speaker 1: a bologna sandwich or, you know, uh, You shoved me
• 19:46
  Speaker 1: in the street. These are serious allegations that need to
• 19:49
  Speaker 1: be looked at. into. And Glenn Dubin, my friends, is
• 19:53
  Speaker 1: setting himself up for a huge fall from grace, in
• 19:57
  Speaker 1: my opinion. In addition to Dubin, a subpoena in the
• 20:02
  Speaker 1: Epstein case has also been served on billionaire Leon Black,
• 20:06
  Speaker 1: who is a member of the Museum of Modern Arts
• 20:08
  Speaker 1: Board of Directors along with Dubin. Fellow travelers, huh? And
• 20:13
  Speaker 1: what do you think? It's just a coincidence that all
• 20:14
  Speaker 1: of these scuzzbags are in the art world or the
• 20:18
  Speaker 1: modeling world or the world of finance? No. These people
• 20:22
  Speaker 1: have been scummy since the start of time. I mean, look,
• 20:26
  Speaker 1: I'm not a religious guy, right? I, you know, my...
• 20:29
  Speaker 1: That's not my thing. But I will tell you this.
• 20:32
  Speaker 1: I believe that Jesus was a real man. And who
• 20:34
  Speaker 1: did he get pissed off at? The bankers. The only
• 20:37
  Speaker 1: people he ever got pissed off at. Flipped over their table.
• 20:41
  Speaker 1: The whole flip. And that's because bankers. Even since before
• 20:45
  Speaker 1: Jesus was around. Have been scumbag. Shit birds. Who have
• 20:49
  Speaker 1: done nothing. But destroy the poor populations. That they're in
• 20:55
  Speaker 1: charge of lending to. And Glenn Dubin. And Leon Black.
• 21:01
  Speaker 1: And the rest of the pieces of shit. That come
• 21:03
  Speaker 1: from that world. All deserve the karma train. That has
• 21:07
  Speaker 1: just left the station. That is barreling towards them. At
• 21:11
  Speaker 1: light speed. In January. Virgin Islands Attorney General Denise George.
• 21:17
  Speaker 1: Sued Epstein's estate. Alleging violation of the Virgin Law's. Civil
• 21:21
  Speaker 1: racketeering law. And that's what I was talking about earlier.
• 21:25
  Speaker 1: About the Civil Rico case. That's what she's engaged in
• 21:28
  Speaker 1: here folks. And she's engaged in a Mongolian type of
• 21:32
  Speaker 1: campaign of scorched earth, right? She's trying to be Genghis
• 21:35
  Speaker 1: Khan and stand atop all of these skulls when she's done.
• 21:40
  Speaker 1: But my question is, why is it just civil? Let's
• 21:44
  Speaker 1: move it out of the realm of civil and move
• 21:47
  Speaker 1: it into the criminal realm down in the Virgin Islands too.
• 21:50
  Speaker 1: Because I've said a million times on this podcast, I
• 21:53
  Speaker 1: don't care how these people end up in jail. I
• 21:55
  Speaker 1: don't care if it's financial crimes. or crimes due to
• 21:59
  Speaker 1: their participation with Jeffrey Epstein. All I care about at
• 22:03
  Speaker 1: this point, folks, is justice. If you'd like to contact me,
• 22:08
  Speaker 1: you can do that at bobbycapucci at protonmail.com. That's B-O-B-B-Y-C-A-P-U-C-C-I
• 22:15
  Speaker 1: at protonmail.com. You can also find me on Twitter at
• 22:19
  Speaker 1: B-O-B-B-Y underscore C-A-P-U-C-C-I. All of the links that go with
• 22:26
  Speaker 1: this episode can be found in the description box. And
• 22:30
  Speaker 1: to everybody who has donated to the podcast and who
• 22:33
  Speaker 1: has supported my work, I appreciate you all more than
• 22:36
  Speaker 1: you will ever know. All right, everybody, we will be
• 22:40
  Speaker 1: back tonight for sure with a daily drop. Last night,
• 22:44
  Speaker 1: way too tired after UFC, and I figured, eh, you
• 22:48
  Speaker 1: guys could go a night without hearing me whinge. All right, folks,
• 22:52
  Speaker 1: so until later on, I hope you all enjoy your Sunday.
• 22:55
  Speaker 1: What's up, everyone, and welcome back to the Epstein Chronicles.
• 22:59
  Speaker 1: In this episode, we're going to dive right back into
• 23:01
  Speaker 1: the court documents, and this time we're taking a look
• 23:04
  Speaker 1: at the USVI's subpoena to Glenn Dubin. Case number ST-20-CV-014.
• 23:14
  Speaker 1: Action for damages. United States government, the US Virgin Islands
• 23:19
  Speaker 1: versus Glenn Dubin. Plaintiff subpoena to third party Glenn Dubin.
• 23:24
  Speaker 1: In accordance with Rule 45 of the Virgin Islands Rules
• 23:27
  Speaker 1: of Civil Procedure and pursuant to subpoena issued in the
• 23:31
  Speaker 1: pending action, Government of the United States Virgin Islands v.
• 23:34
  Speaker 1: the Estate of Jeffrey Epstein, ST-20-CV-014, before the Superior Court
• 23:37
  Speaker 1: of the Virgin Islands, Division of St. Thomas and St. John, you,
• 23:45
  Speaker 1: Glenn Dubin, are hereby commanded to produce and deliver all
• 23:49
  Speaker 1: documents responsive to the request set forth below to Carol
• 23:53
  Speaker 1: Thomas Jacobs, ESQ, within 30 days following receipt of this subpoena.
• 23:58
  Speaker 1: If you have any questions, please contact Carol Thomas Jacobs.
• 24:03
  Speaker 1: Instructions When providing your responses, indicate the request to which
• 24:07
  Speaker 1: each document or answer responds in the metadata field Request Number. 2.
• 24:12
  Speaker 1: Documents produced pursuant to these requests shall be produced as
• 24:16
  Speaker 1: they are kept in the ordinary course of business. 3.
• 24:20
  Speaker 1: For each document you produce, the current version together with
• 24:23
  Speaker 1: an earlier edition or predecessor document during the relevant time period,
• 24:28
  Speaker 1: even though the title of earlier documents may differ from
• 24:30
  Speaker 1: current versions. Format for documents produced electronically. A. Data shall
• 24:35
  Speaker 1: be produced in single-page TIFFs at a 300 dpi resolution.
• 24:40
  Speaker 1: which are named for the Bates number of the page.
• 24:43
  Speaker 1: There shall be no more than 1,000 images per folder.
• 24:46
  Speaker 1: Bates numbers, confidentiality designations, and redactions shall be burned into
• 24:51
  Speaker 1: the TIFF image file so as not to be unreasonably
• 24:54
  Speaker 1: obstructed any information on the page. B, document unitization. Each
• 25:01
  Speaker 1: page of document shall be electronically converted into an image
• 25:05
  Speaker 1: as described above. If a document is more than one page,
• 25:08
  Speaker 1: The utilization of the document and any attachments and or
• 25:12
  Speaker 1: affixed notes shall be maintained as it existed in the
• 25:16
  Speaker 1: original when creating the image file and appropriately designated in
• 25:20
  Speaker 1: the load files. The corresponding parent-attachment relationships, to the extent possible,
• 25:25
  Speaker 1: shall be provided in the load files furnished with each production. c.
• 25:30
  Speaker 1: Include document-level text files containing optical character recognition or extracted
• 25:36
  Speaker 1: text named With the Bates number of the first page
• 25:39
  Speaker 1: of the document. D. Include data load files containing all
• 25:43
  Speaker 1: of the metadata fields, both system and application, see list below,
• 25:47
  Speaker 1: from the original native documents. E. Include the database field
• 25:51
  Speaker 1: name in the first line of the metadata file in
• 25:54
  Speaker 1: such a manner that it is clear how the metadata
• 25:57
  Speaker 1: is organized in the file. F. All hidden text, e.g.,
• 26:01
  Speaker 1: track changes, hidden columns, comments, notes, etc., shall be expanded, extracted,
• 26:06
  Speaker 1: and rendered into the. tiff file. g. Documents created in
• 26:11
  Speaker 1: Excel spreadsheets, CSV files, Access databases, and audio and video
• 26:16
  Speaker 1: media files shall be produced in native format. The extractable
• 26:20
  Speaker 1: metadata and text shall be produced in the same manner
• 26:24
  Speaker 1: as other documents that originated in electronic form as described herein.
• 26:28
  Speaker 1: to the extent that metadata exists or is reasonably accessible. H.
• 26:33
  Speaker 1: Email attachments and embedded files or links shall be mapped
• 26:37
  Speaker 1: to their parent. I. Produce all attachments to responsive documents
• 26:42
  Speaker 1: attached to the responsive document. J. Deduplicate prior to production,
• 26:48
  Speaker 1: to the extent that exact duplicate documents based on MD5
• 26:52
  Speaker 1: or SHA-1 hash values at the document level reside within
• 26:56
  Speaker 1: the party's data set Each party is only required to
• 26:59
  Speaker 1: produce a single copy of a responsive document so long
• 27:03
  Speaker 1: as there is a data field which identifies each custodian
• 27:06
  Speaker 1: who had a copy. In addition, documents may be deduplicated
• 27:10
  Speaker 1: in such a way as to eliminate earlier or incomplete
• 27:14
  Speaker 1: chains of emails and produce only the most complete iteration
• 27:18
  Speaker 1: of an email chain so long as there is a
• 27:20
  Speaker 1: data field that identifies each custodian who had a copy. 4.
• 27:25
  Speaker 1: Format for hard copies of documents produced in response to
• 27:29
  Speaker 1: this request. a. Retype the question or request to which
• 27:33
  Speaker 1: the documents respond and firmly attach the documents to the
• 27:36
  Speaker 1: retyped request. b. Number all documents consecutively, consistently with the
• 27:42
  Speaker 1: numbers used for the documents produced electronically. 5. Unless otherwise indicated,
• 27:48
  Speaker 1: the relevant time period for this request for production of
• 27:51
  Speaker 1: documents is January 1, 1998 to the present. 6. If
• 27:57
  Speaker 1: no documents responsive to a particular request exist, so state. 7.
• 28:02
  Speaker 1: As to any document which no longer exists, but which
• 28:04
  Speaker 1: you are aware existed at one time, identify such document.
• 28:08
  Speaker 1: with as much particularity as possible, and in addition, identify
• 28:12
  Speaker 1: the last known location of the document, the reason the
• 28:16
  Speaker 1: document is no longer in existence, and the person responsible
• 28:19
  Speaker 1: for the document's disposition. 8. For information that you would
• 28:24
  Speaker 1: withhold on the basis of privilege, provide a descriptive list
• 28:27
  Speaker 1: of each document stating the grounds for your refusal and
• 28:30
  Speaker 1: providing the following information. The name or title of the document,
• 28:34
  Speaker 1: a description of the nature and subject matter of the document,
• 28:38
  Speaker 1: sufficient to enable a meaningful challenge to the assertion of privilege,
• 28:42
  Speaker 1: the date, author, sender, and recipient of the document, including
• 28:46
  Speaker 1: whether the person is an attorney or was an employee
• 28:50
  Speaker 1: of First Bank at the time the document was authored, sent,
• 28:53
  Speaker 1: or received, and the nature of the privilege. 9. These
• 28:57
  Speaker 1: requests shall be deemed continuing in character. so as to
• 29:01
  Speaker 1: require prompt supplemental responses if additional documents called for herein
• 29:05
  Speaker 1: are obtained, discovered, or become known to you between the
• 29:09
  Speaker 1: time of responding to the request and the final disposition
• 29:13
  Speaker 1: of this action. 10. Social security numbers may be redacted
• 29:17
  Speaker 1: from documents to the extent required by applicable law. Definitions 1.
• 29:23
  Speaker 1: All shall be construed to include the collective as well
• 29:26
  Speaker 1: as the singular and shall mean each, any, and every. 2.
• 29:30
  Speaker 1: Document means any writing or any other tangible thing, whether printed, recorded,
• 29:35
  Speaker 1: in audio, video, electronically, or by any other means, reproduced.
• 29:40
  Speaker 1: by any process, or written or produced by hand, including
• 29:44
  Speaker 1: but not limited to letters, memoranda notes, opinions, books, reports, studies, agreements, statements, communications,
• 29:51
  Speaker 1: including intercompany and intracompany communications, correspondence, telegrams, email, instant messages,
• 29:58
  Speaker 1: chat logs, SMS, MMS, or other text messages, posted information, messages,
• 30:04
  Speaker 1: chat logs on social networking sites, including but not limited
• 30:08
  Speaker 1: to Facebook, Google +, MySpace, and Twitter, logs, bookkeeping entries,
• 30:13
  Speaker 1: summaries of records, of personal conversations, diaries, calendars, telephone messages,
• 30:18
  Speaker 1: and logs, forecasts, photographs, images, tape recordings, models, statistical statements, graphs, laboratory,
• 30:26
  Speaker 1: and and engineering reports, notebooks, charts, plans, drawings, minutes, bylaws, resolutions,
• 30:32
  Speaker 1: records of conferences, expressions or statements of policy, lists of
• 30:36
  Speaker 1: persons attending meetings or conferences, lists of clients or customers
• 30:40
  Speaker 1: or suppliers, reports or summaries of interviews, opinions of reports,
• 30:45
  Speaker 1: of negotiations, brochures, pamphlets, advertisements, circulars, trade letters, press releases,
• 30:51
  Speaker 1: drafts of any document and revisions of drafts of any document,
• 30:55
  Speaker 1: and any other similar paper of record. The terms also
• 30:58
  Speaker 1: include a copy of a document where the copy is
• 31:02
  Speaker 1: not exactly the same as the original. The terms also
• 31:05
  Speaker 1: include emails and other documents made or stored in electronic form,
• 31:10
  Speaker 1: whether kept on computers, computer tapes, disks, or drivers, including
• 31:14
  Speaker 1: cloud storage of any type or other media upon which
• 31:18
  Speaker 1: information may be recorded. 3. Communication means the transmittal of
• 31:24
  Speaker 1: information in the form of facts, ideas, inquiries, otherwise. 4.
• 31:28
  Speaker 1: Including is used merely to emphasize that a request for
• 31:32
  Speaker 1: a certain type of document or information should be construed
• 31:35
  Speaker 1: as limiting the request in any way. 5. Referencing to,
• 31:39
  Speaker 1: relating to, reflecting, regarding, or with respect to mean, without limitation,
• 31:44
  Speaker 1: the concepts pertain to, deal with, concern, reflect, record, report, constitute, contain, mention, describe, discuss, analyze, evaluate, estimate, study, survey, project, assess, support, modify, contradict, criticize, summarize, comment,
• 32:01
  Speaker 1: or otherwise involve, in whole or in part. 6. Epstein
• 32:06
  Speaker 1: entities shall include, but not be limited, to Jeffrey E. Epstein,
• 32:11
  Speaker 1: estate of Jeffrey E. Epstein, the 1953 Trust, JEGE LLC,
• 32:17
  Speaker 1: Cypress Incorporated, Financial Ballistics, FT Real Estate, Inc., Great St. Jim, LLC,
• 32:24
  Speaker 1: Hyperion Air, LLC, IGO Company, LLC, Jeepers, Inc., Laurel, Inc.,
• 32:30
  Speaker 1: Little St. Jim, LLC, LSJE, LLC, LSJ Emergency, LLC, Maple, Inc.,
• 32:38
  Speaker 1: Michelle's Transportation Company, LLC, Nautilus, Inc., Plan D, LLC, Poplar, Inc., Prititani, LLC,
• 32:48
  Speaker 1: Southern Country International LTD, Southern Trust Company, Southern Financial, Thomas
• 32:54
  Speaker 1: World Air, Zorro Management, Mort Incorporated, Freedom Air Petroleum, the
• 32:59
  Speaker 1: COUQ Foundation, Epstein Foundation Incorporated, Epstein Interest, Gratitude America LTD,
• 33:05
  Speaker 1: Jeffrey Epstein Foundation, Southern Trust Company, Financial Trust Company, IGYAHY, St.
• 33:12
  Speaker 1: Thomas Holdings, Butterfly Trust, LSJ Employees, and Financial Informatics. 7.
• 33:19
  Speaker 1: You or your refers to Glenn Dubin and Dubin & Company.
• 33:23
  Speaker 1: Request for production from January 1st, 1998 to present. Request
• 33:28
  Speaker 1: number one. All documents and communication relating to all financial
• 33:32
  Speaker 1: transactions between you, Jeffrey Epstein, and any Epstein entity, agent,
• 33:37
  Speaker 1: or associate. This includes but is not limited to three
• 33:40
  Speaker 1: wire transfers between 2014 and 2016. Request number two. All
• 33:45
  Speaker 1: documents and communications relating or referring to the Virgin Islands
• 33:49
  Speaker 1: or Little St. James, including but not limited to, travel
• 33:53
  Speaker 1: to or from the Virgin Islands or Little St. James.
• 33:57
  Speaker 1: Request number three. All documents and communications relating or referring
• 34:01
  Speaker 1: to Jeffrey Epstein's criminal plea, conviction, probation, or any other criminal, civil,
• 34:07
  Speaker 1: or administrative investigation or litigation related to Epstein or or
• 34:11
  Speaker 1: the sexual abuse or trafficking of females by Epstein or
• 34:14
  Speaker 1: any individual associated with Epstein. Request number four. All documents
• 34:20
  Speaker 1: and communications between you and Darren Indyk, Richard Kahn, Bella Klein,
• 34:25
  Speaker 1: and or Harry Beller, and or regarding Jeffrey Epstein's estates, trusts,
• 34:29
  Speaker 1: and or will. Request number five. All documents and communications
• 34:33
  Speaker 1: regarding any assistant employed by Jeffrey Epstein or with Jeffrey
• 34:37
  Speaker 1: Epstein or any Epstein agent or associate regarding any au
• 34:42
  Speaker 1: pair or child care provider employed by you. Request number six.
• 34:47
  Speaker 1: All documents and communications regarding a Swedish female living with
• 34:51
  Speaker 1: or employed by Jeffrey Epstein or regarding transportation you provided
• 34:55
  Speaker 1: or arranged for. Request number seven. all documents and communications
• 35:00
  Speaker 1: regarding the departure of Ronaldo and or Deborah Rizzo from
• 35:04
  Speaker 1: your employment, any severance or non-disclosure agreement or payment, or
• 35:09
  Speaker 1: regarding statements or testimony by Ronaldo or Deborah Rizzo in
• 35:13
  Speaker 1: any investigation or litigation related to Jeffrey Epstein and or
• 35:17
  Speaker 1: Ghislaine Maxwell. Request number eight. All documents and communications regarding
• 35:22
  Speaker 1: travel by you on any airplane used by Jeffrey Epstein,
• 35:26
  Speaker 1: any travel with Jeffrey Epstein, Ghislaine Maxwell, or any individual
• 35:30
  Speaker 1: or agent associated with or accompanying Jeff Epstein or Ghislaine Maxwell,
• 35:35
  Speaker 1: or any travel by Jeffrey Epstein, Ghislaine Maxwell, or any
• 35:39
  Speaker 1: individual or agent associated with or accompanying Jeffrey Epstein or
• 35:43
  Speaker 1: Ghislaine Maxwell on an airplane used by you. Request number nine.
• 35:47
  Speaker 1: All documents and communications... Regarding Virginia Roberts or any other
• 35:51
  Speaker 1: allegations that you sexually abused any female associated with Jeffrey Epstein.
• 35:57
  Speaker 1: Request number 10. All documents and communications regarding any employee
• 36:02
  Speaker 1: or female that was transported by car, plane, boat, or
• 36:05
  Speaker 1: otherwise to or from any of Jeffrey Epstein's properties. Request
• 36:10
  Speaker 1: number 11. Any and all documents and communications related to
• 36:13
  Speaker 1: any of your three children, May, Selena, or Jordan, which
• 36:18
  Speaker 1: also relate in any way to Jeffrey Epstein or any
• 36:21
  Speaker 1: Epstein enterprise. Request number 12. All schedules reflecting visits you
• 36:25
  Speaker 1: made to Jeffrey Epstein's or Glenn Maxwell's properties or any
• 36:29
  Speaker 1: visits made by Jeffrey Epstein or Glenn Maxwell to any
• 36:32
  Speaker 1: property owned by you. Request number 13. All documents and
• 36:36
  Speaker 1: communications about Jeffrey Epstein sent or received by you. Request
• 36:41
  Speaker 1: number fourteen. All trust documents related to Jeffrey Epstein. Request
• 36:45
  Speaker 1: number fifteen. All documents and communications evidencing donations made by
• 36:50
  Speaker 1: you to Jeffrey Epstein or an Epstein entity or donations
• 36:54
  Speaker 1: by Jeffrey Epstein to you or an entity related to you.
• 36:58
  Speaker 1: Request number sixteen. All documents and communications between you and
• 37:02
  Speaker 1: any female associated with Jeffrey Epstein. Number seventeen. All documents
• 37:08
  Speaker 1: and communications related to or reflecting any massage you received
• 37:12
  Speaker 1: at any of Jeffrey Epstein's properties or performed by someone
• 37:16
  Speaker 1: sent to your property at the direction of Jeffrey Epstein.
• 37:20
  Speaker 1: Request number 18. All documents and communication related to or
• 37:24
  Speaker 1: reflecting any assistance that you provided in securing employment for
• 37:28
  Speaker 1: any female at the request of Jeffrey Epstein or for
• 37:32
  Speaker 1: any female associated with Jeffrey Epstein. Request number 19. All
• 37:36
  Speaker 1: documents and communications between you, Jeffrey Epstein, and or James E.
• 37:40
  Speaker 1: Staley regarding massages, travel to or meetings in the Virgin
• 37:45
  Speaker 1: Islands or elsewhere, the sale or purchase of Highbridge Capital,
• 37:49
  Speaker 1: or any other financial transaction, commission, fee, or investment, or
• 37:53
  Speaker 1: any Epstein entity. Request number 20. All documents and communications
• 37:58
  Speaker 1: between you, Jeffrey Epstein, and or Daniel Zwirn regarding investments
• 38:03
  Speaker 1: by Jeffrey Epstein, in or litigation related to investments by
• 38:07
  Speaker 1: Jeffrey Epstein. Request number 21, all documents and communications reflecting
• 38:12
  Speaker 1: your relationship, including as an investment advisor to Jeffrey Epstein
• 38:17
  Speaker 1: or any Epstein entity. Request number 22, any photographs, videos,
• 38:23
  Speaker 1: or other recordings related to or reflecting any visits you
• 38:26
  Speaker 1: made to Little St. James. This was dated September 3rd, 2020,
• 38:31
  Speaker 1: and it was signed by Denise George. Alright folks, that's
• 38:35
  Speaker 1: going to do it for this one. All of the
• 38:37
  Speaker 1: information that goes with this episode can be found in
• 38:41
  Speaker 1: the description box. What's up everyone and welcome back to
• 38:44
  Speaker 1: the Epstein Chronicles. In this episode, we're taking a look
• 38:49
  Speaker 1: at the U.S. Virgin Islands and their subpoena to Bella Klein.
• 38:55
  Speaker 1: Case number ST-20-CV-014 Government of the United States Virgin Islands vs.
• 39:03
  Speaker 1: Darren K. Endyke in his capacity as the executor for
• 39:07
  Speaker 1: the estate of Jeffrey E. Epstein, and against Richard D.
• 39:11
  Speaker 1: Kahn in his capacity as the executor of the estate
• 39:15
  Speaker 1: of Jeffrey E. Epstein. Plaintiff's Subpoena to Third Party Bella
• 39:19
  Speaker 1: Klein In accordance with Rule 45 of the Virgin Islands
• 39:23
  Speaker 1: Rules of Civil Procedure and pursuant to the subpoena issued
• 39:27
  Speaker 1: in the pending Action Government of the United States, Virgin
• 39:31
  Speaker 1: Islands v. The Estate of Jeffrey E. Epstein, before the
• 39:35
  Speaker 1: Superior Court of the Virgin Islands Division of St. Thomas
• 39:39
  Speaker 1: and St. John, you, Bella Klein, are hereby commanded to
• 39:42
  Speaker 1: produce and deliver all documents responsive to the request set
• 39:46
  Speaker 1: forth below the to Carol Thomas Jacobs within 30 days
• 39:50
  Speaker 1: of following receipt of the subpoena. If you have any questions,
• 39:54
  Speaker 1: please contact Carol Thomas Jacobs. The instructions. One, when providing
• 39:59
  Speaker 1: your responses, indicate the request to which each document or
• 40:03
  Speaker 1: answer responds in the metadata field. Two, documents produced pursuant
• 40:08
  Speaker 1: to these requests shall be produced as they are kept
• 40:11
  Speaker 1: in the ordinary course of business. Three, for each document
• 40:15
  Speaker 1: you must produce Produce the current version together with all
• 40:19
  Speaker 1: earlier editions or predecessor documents during the relevant time period,
• 40:23
  Speaker 1: even though the title of earlier documents may differ from
• 40:26
  Speaker 1: current versions. Format for documents produced electronically. A. Data shall
• 40:32
  Speaker 1: be produced in single-page TIFFs at 300 dpi resolution, which
• 40:36
  Speaker 1: are named for the Bates number of the page. There
• 40:39
  Speaker 1: shall be no more than 1,000 images per folder. Bates numbers...
• 40:43
  Speaker 1: Confidentiality designations and redactions shall be burned into the TIFF
• 40:47
  Speaker 1: image file so as to not unreasonably obstruct any information
• 40:51
  Speaker 1: on the page. b. Document Unitization Each page of a
• 40:56
  Speaker 1: document shall be electronically converted into an image as described above.
• 41:00
  Speaker 1: If a document is more than one page, the unitization
• 41:03
  Speaker 1: of the document and any attachments and or affixed notes
• 41:07
  Speaker 1: shall be maintained as it existed in the original when
• 41:10
  Speaker 1: creating the image file and appropriately designated in the load files.
• 41:15
  Speaker 1: The corresponding parent-attachment relationships, to the extent possible, shall be
• 41:20
  Speaker 1: provided in the load files furnished with each production. C.
• 41:25
  Speaker 1: Include document-level text files. Containing optical character recognition, OCR, or
• 41:31
  Speaker 1: extracted text named with the Bates number of the first
• 41:34
  Speaker 1: page of the document, D. Include data load files containing
• 41:37
  Speaker 1: all of the metadata fields, both system and application. See
• 41:41
  Speaker 1: list below. From the original native documents, E. Include the
• 41:44
  Speaker 1: database field name in the first line of the metadata
• 41:47
  Speaker 1: file in such a manner that it is clear how
• 41:50
  Speaker 1: the metadata is organized in the file. F. All hidden text, e.g.
• 41:54
  Speaker 1: track changes, hidden columns, comments, notes, etc. shall be expanded, extracted,
• 41:59
  Speaker 1: and rendered in the TIFF file. G. Documents created in
• 42:03
  Speaker 1: Excel or CSV files, access databases, and audio and video
• 42:08
  Speaker 1: media files shall be produced in native format. The extractable
• 42:13
  Speaker 1: metadata file and text shall be produced in the same
• 42:16
  Speaker 1: manner as other documents that originated in electronic form as
• 42:20
  Speaker 1: described herein. To the extent that the exact duplicate documents
• 42:24
  Speaker 1: based on MD5 or SHA, one hash values at the
• 42:28
  Speaker 1: document level reside within a party's dataset, each party is
• 42:31
  Speaker 1: only required to produce a single copy of a responsive
• 42:35
  Speaker 1: document so long as there is a data field that
• 42:37
  Speaker 1: identifies each custodian who had a copy. In addition, documents
• 42:42
  Speaker 1: may be deduplicated in such a way as to eliminate
• 42:46
  Speaker 1: earlier or incomplete chains of emails and produce only the
• 42:49
  Speaker 1: most complete iteration of an email chain so long as
• 42:53
  Speaker 1: there is a data field that identifies each custodian who
• 42:56
  Speaker 1: had a copy. 4. Format for hard copies of documents
• 43:01
  Speaker 1: produced in response to this request. A. Retype the question
• 43:05
  Speaker 1: or request to which the documents respond and firmly attach
• 43:08
  Speaker 1: the documents to the retyped request. B. Number all documents consecutively,
• 43:14
  Speaker 1: consistently with the numbers used for the documents produced electronically. 5.
• 43:19
  Speaker 1: Unless otherwise indicated, the relevant time period for this request
• 43:23
  Speaker 1: for production of documents is January 1, 1998 to the present. 6.
• 43:29
  Speaker 1: If no documents responsive to a particular request exist, so state. 7.
• 43:34
  Speaker 1: As to any document which no longer exists, but which
• 43:37
  Speaker 1: you are aware existed at one time, identify such a
• 43:40
  Speaker 1: document with as much particularity as possible, and in addition
• 43:44
  Speaker 1: identify the last known location of the document, the reason
• 43:48
  Speaker 1: the document is no longer in existence, and the person
• 43:51
  Speaker 1: responsible for the document's disposition. 8. For information that you
• 43:56
  Speaker 1: withhold on the basis of privilege, provide a descriptive list
• 43:59
  Speaker 1: of each document stating the grounds for your refusal and
• 44:03
  Speaker 1: providing the following information. the name or title of the document,
• 44:07
  Speaker 1: a description of the nature and subject matter of the
• 44:10
  Speaker 1: document sufficient to enable a meaningful challenge to the assertion
• 44:14
  Speaker 1: of privilege, the date, author, sender, and recipient of the document,
• 44:20
  Speaker 1: including whether the person is an attorney and or was
• 44:23
  Speaker 1: an employee of First Bank at the time the document
• 44:26
  Speaker 1: was authored, sent or received, and the nature of the privilege. 9.
• 44:30
  Speaker 1: These requests shall be deemed Continuing in character so as
• 44:34
  Speaker 1: to require prompt supplemental responses if additional documents called for
• 44:39
  Speaker 1: herein are obtained, discovered, or become known to you between
• 44:43
  Speaker 1: the time of responding to the request and the final
• 44:46
  Speaker 1: disposition of this action. 10. Social Security numbers may be
• 44:50
  Speaker 1: redacted from documents to the extent required by applicable law.
• 44:55
  Speaker 1: Definitions Unless otherwise specified, the documents specified below are required
• 45:00
  Speaker 1: to be produced for the time period commencing January 1,
• 45:04
  Speaker 1: 1998 and continuing through the present. Where production of account
• 45:08
  Speaker 1: data is provided in electronic format or media, the preferred
• 45:11
  Speaker 1: software format to incorporate that data is Microsoft Excel. As
• 45:16
  Speaker 1: used herein, the following terms are defined as indicated. All each.
• 45:20
  Speaker 1: The term all and each shall be construed as all
• 45:23
  Speaker 1: and each. To. End or the connectives end and or
• 45:28
  Speaker 1: shall be construed either disjunctively or conjunctively as necessary to
• 45:33
  Speaker 1: bring within the scope of the discovery requests all responses
• 45:36
  Speaker 1: that might otherwise be construed to the outside of its scope. 3.
• 45:40
  Speaker 1: Communication means the transmittal of information in the form of facts, ideas, inquiries,
• 45:46
  Speaker 1: and otherwise. 4. The terms document or documents are defined
• 45:50
  Speaker 1: to be synonymous and equal in scope to the usage
• 45:54
  Speaker 1: of these terms in Federal Rule of Civil Procedure 34A, including,
• 45:58
  Speaker 1: without limitation, any written, drawn, printed, typed, photographed, or other
• 46:03
  Speaker 1: graphic or electronically or computerized recorded data or compilations of
• 46:08
  Speaker 1: any kind or nature prepared or received by, or in
• 46:12
  Speaker 1: the possession, custody, or control of the answering party, its agents, servants, employees,
• 46:18
  Speaker 1: or other representatives, originals, drafts, and all non-identical copies or
• 46:22
  Speaker 1: separate documents within the meaning of this term. 5. The
• 46:27
  Speaker 1: term identify, when used with reference to a person, means
• 46:31
  Speaker 1: to give, to the extent known, the person's full name, present,
• 46:34
  Speaker 1: or last known address, and when referring to a natural person, additionally,
• 46:39
  Speaker 1: the present or last known place of employment. Once a
• 46:42
  Speaker 1: person has been identified in accordance with this subparagraph, only
• 46:45
  Speaker 1: the name of that person need to be listed in
• 46:48
  Speaker 1: response to subsequent discovery requesting the identification of that person. 6.
• 46:53
  Speaker 1: The term identify when used with reference to documents means
• 46:57
  Speaker 1: to give to the extent known the type of document,
• 47:00
  Speaker 1: general subject matter, date of the document, and author's addresses
• 47:04
  Speaker 1: and recipient. The term identify when used with reference to
• 47:08
  Speaker 1: an oral communication, discussion, conversation, or any other oral statement,
• 47:13
  Speaker 1: shall mean to describe in detail the substance of each
• 47:16
  Speaker 1: such communication, discussion, conversation, or statement, state the date of
• 47:21
  Speaker 1: such communication, discussion, conversation, or statement, the place where such communication, discussion, conversation,
• 47:28
  Speaker 1: or statement was held, and identify each person present for
• 47:32
  Speaker 1: such communication, discussion, conversation, or statement. 8. Referring to, Relating to, Reflecting, Regarding,
• 47:40
  Speaker 1: or with respect to mean, without limitation, the concepts pertain to,
• 47:44
  Speaker 1: deal with, concern, reflect, record, report, constitute, contain, mention, describe, discuss, analyze, evaluate, estimate, study, survey, project, assess, support, modify, contradict, criticize, summarize, comment,
• 48:01
  Speaker 1: or otherwise involve, in whole or in part. Number nine.
• 48:05
  Speaker 1: You and your shall mean Bella Klein. These terms also
• 48:09
  Speaker 1: shall be deemed to include all agents and other persons
• 48:12
  Speaker 1: acting or authorized to act on her behalf. 10. Employee includes,
• 48:17
  Speaker 1: but is not limited to, all current or former salaried employees,
• 48:21
  Speaker 1: hourly employees, independent contractors, and individuals performing work as temporary
• 48:26
  Speaker 1: employees for the entity referred to in the request. 11.
• 48:31
  Speaker 1: Epstein entities shall include, but not be limited to, Jeffrey E. Epstein,
• 48:36
  Speaker 1: Estate of Jeffrey E. Epstein, The 1953 Trust, JEGE LLC,
• 48:42
  Speaker 1: Cypress Inc., Financial Ballistics LLC, FSF LLC, FT Real Estate Inc.,
• 48:49
  Speaker 1: Great St. Jim LLC, Hyperion Air LLC, IGO Company LLC,
• 48:55
  Speaker 1: Jeepers Inc., Laurel Inc., Little St. Jim LLC, LSJE LLC,
• 49:03
  Speaker 1: LSJ Emergency LLC, Maple Inc., Michelle's Transportation Company LLC, Nautilus Inc.,
• 49:11
  Speaker 1: Plan D LLC, Poplar Inc., Prittany LLC, Southern Country International LTD,
• 49:18
  Speaker 1: Southern Trust Company Inc., Southern Trust, LLC, Thomas World Air, LLC,
• 49:24
  Speaker 1: VT & T, LLC, Zorro Management, LLC, Morton, Inc., CDE, Inc.,
• 49:31
  Speaker 1: Freedom Air Petroleum, LLC, COUQ Foundation, Epstein Foundation, Inc., Epstein Interest,
• 49:39
  Speaker 1: Gratitude America LTD, Jeffrey Epstein Foundation Incorporated, Southern Trust Company,
• 49:44
  Speaker 1: Financial Trust Company, IGYAHY, St. Thomas Holdings LLC, Butterfly Trust,
• 49:52
  Speaker 1: LSJ Employees LLC, CDE Incorporated, NES LEC, and Financial Infomatics.
• 49:59
  Speaker 1: Request for Production From January 1, 1998 to Present Request
• 50:03
  Speaker 1: Number 1 All documents and communications reflecting or related to payments, reimbursements,
• 50:10
  Speaker 1: or receipts from or for any females associated with Jeffrey Epstein,
• 50:14
  Speaker 1: including but not limited, as employees or grantees of COUQ Foundation,
• 50:20
  Speaker 1: the Florida Science Foundation, SLK Designs, SJC Interiors, Jay Epstein,
• 50:26
  Speaker 1: Virgin Islands Foundation, Gratitude America, NES, or Southern Trust Company.
• 50:32
  Speaker 1: Request number two. All documents and communications reflecting or related
• 50:36
  Speaker 1: to the American Express cards, other credit cards, or bank
• 50:39
  Speaker 1: accounts paid, opened, or funded by Jeffrey Epstein, any Epstein agent,
• 50:44
  Speaker 1: including but not limited to you, Richard Kahn, Darren Indyke,
• 50:48
  Speaker 1: or Harry Beller, or any Epstein entity on behalf of
• 50:51
  Speaker 1: the females identified in response to request for production number one.
• 50:55
  Speaker 1: Request number three. All documents and communication reflecting or related
• 51:00
  Speaker 1: to to preparing or filing taxes for any of the
• 51:03
  Speaker 1: females identified in response to requests for Production 1. Request
• 51:08
  Speaker 1: number 4. All documents and communications reflecting or related to
• 51:12
  Speaker 1: any correspondence or other materials provided in connection with any
• 51:17
  Speaker 1: application for a work permit, visa, citizenship, or other travel
• 51:21
  Speaker 1: or immigration status for any female associated with Jeffrey Epstein.
• 51:26
  Speaker 1: Request number 5. All documents and communications reflecting or related
• 51:30
  Speaker 1: to obtaining, providing, or arranging for cash for Jeffrey Epstein.
• 51:35
  Speaker 1: Request number six. All documents and communications reflecting or related
• 51:39
  Speaker 1: to instructions or explanations you provided to any financial institution
• 51:44
  Speaker 1: regarding financial transactions or due diligence regarding Jeffrey Epstein or
• 51:49
  Speaker 1: any Epstein entity. Request number eight. All documents and communications
• 51:55
  Speaker 1: reflecting or related to the purpose, activities, expenditure, income, or
• 52:01
  Speaker 1: tax incentives for Financial Trust Company, Financial Trust, Southern Trust Company,
• 52:05
  Speaker 1: Southern Trust, or Southern Country International. Request number nine. Any
• 52:11
  Speaker 1: and all documents and materials related to or reflecting the
• 52:14
  Speaker 1: tax returns for Financial Trust and Southern Trust, including adjusting
• 52:18
  Speaker 1: journal entries, including computation supporting such entries, and supporting schedules
• 52:24
  Speaker 1: and documents that were proposed or prepared by you. Request
• 52:28
  Speaker 1: number 10. All documents reflecting the identity of and communications
• 52:33
  Speaker 1: with individuals or entities to which Financial Trust and Southern
• 52:36
  Speaker 1: Trust provided financial, brokerage, or investment advice or other financial
• 52:41
  Speaker 1: or investment-related services. Request number 11. All documents and communication
• 52:47
  Speaker 1: regarding transfers from Jeepers Incorporated or any other Epstein entity
• 52:51
  Speaker 1: to Glenn or Eva Incorporated Anderson Dubin. Request number 12.
• 52:56
  Speaker 1: All documents and communications regarding Arda Beskardas. Request number 13.
• 53:02
  Speaker 1: All documents and communications related to or reflecting any trust
• 53:06
  Speaker 1: established by or for Jeffrey Epstein. This document was signed
• 53:11
  Speaker 1: by Denise George and it was dated September 30th, 2020.
• 53:15
  Speaker 1: All right, folks. Well, the crawl through the underbelly of
• 53:19
  Speaker 1: Epstein's enterprise most certainly continues. But that's going to do
• 53:23
  Speaker 1: it for this one. All the information that goes with
• 53:26
  Speaker 1: this episode can be found in the description box.