Episode Transcript
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Speaker 1 (00:00):
What's up everyone, and welcome back to the Epstein Chronicles.
In this episode, we're taking a look at the US
Virgin Islands and their subpoena to Bella Cline Case number
st Dash twenty DASH CV DASH zero one four. Government
of the United States Virgin Islands versus Darren ky Endike
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in his capacity as the Executor for the Estate of
Jeffrey Epstein and against Richard D. Con in his capacity
as the Executor of the Estate of Jeffrey Epstein, plaintiff
Subpoena to third party Bellocline, in accordance with Rule forty
five of the Virgin Islands Rules of Civil Procedure, and
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pursuant to the subpoena issued in the pending action Government
of the United States, Virgin Islands versus the Estate of
Jeffrey E. Epstein before the Superior Court of the Virgin
Islands Division of Saint Thomas and Saint John. You Bellocline
or hereby commanded to produce and deliver all documents responsive
to the requests set fourth below to Carol Thomas Jacobs
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within thirty days of following receipt of the subpoena. If
you have any questions, please contact Carol Thomas Jacobs. The
instructions One when providing your responses, indicate the request to
which each document or answer responds in the metadata FUELD. Two.
Documents produced pursuant to these requests shall be produced as
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they are kept in the ordinary course of business. Three.
For each document you must produce, produce the current version
together with all earlier editions or predecessor documents during the
relevant time period, even though the title of earlier documents
may differ from current versions. Format for documents produced electronically,
a data shall be produced in single page TIFFs at
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three hundred DPI resolution, which are named for the bates
number of the page. There shall be no more than
one thousand images per folder. Numbers, confidentiality designations, and redactions
shall be burned into the tiff image file so as
to not unreasonably obstruct any information on the page. B
Document unitization. Each page of a document shall be electronically
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converted into an image as described above. If a document
is more than one page, the unitization of the document
and any attachments and lore of fixed notes shall be
maintained as it existed in the original when creating the
image file, and appropriately designated in the load files. The
corresponding parent attachment relationships to the extent possible, shall be
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provided in the load files furnished with each production. C
include document level text files containing optical character recognition OCR
or extracted text named with debates number of the first
page of the document. D include data load files containing
all of the metadata fields both system and application see
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list below from the original native documents. E Include the
database field name in the first line of the metadata
file in such a manner that it is clear how
the metadata is organized in the file. F All hidden
text eg. Track changes, hidden columns, comments, notes, etc. Shall
be expanded, extracted, and rendered in the tip file. G
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Documents created in Excel or CSV files, access databases, and
audio and video media files shall be produced in native format.
The extractable metadata and text shall be produced in the
same manner as other documents that originated in electronic form
as described here. In to the extent that the exact
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duplicate documents based on MD five or SAHA one hash
values at the document level reside within a party's data set.
Each party is only required to produce a single copy
of a responsive document so long as there is a
data field that identifies each custodian who had a copy.
In addition, documents may be duplicated in such a way
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as to eliminate earlier or incomplete chains of emails and
produce only the most complete iteration of an email chain,
so long as there is a data field that identifies
each custodian who had a copy. Four Format for hard
copies of documents produced in response to this request, A
retype the question or request to which the documents respond,
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and firmly attach the documents to the retype request. B
Number all documents consecutively, consistently with the numbers used for
the documents produced electronically. Five, unless otherwise indicated. The relevant
time period for this request for production of documents as
January first, nineteen ninety eight to the present. Six. If
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no documents responsive to a particular request exists, so state seven.
As to any document which no longer exists, but which
you are aware existed at one time, identify such a
document with as much particular as possible, and an addition,
identify the last known location of the document, the reason
the document is no longer in existence, and the person
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responsible for the document's disposition. Eight For information that you
withhold on the basis of privilege, provide a descriptive list
of each document, stating the grounds for your refusal, and
providing the following information. The name or title of the document,
a description of the nature and subject matter of the
document sufficient to enable a meaningful challenge to the assertion
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of privilege, the date, author, sender, and recipient of the document,
including whether the person is an attorney and or was
an employee of First Bank at the time the document
was altered center received, and the nature of the privilege. Nine.
These requests shall be deemed continuing in character so as
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to require prompt supplemental responses if additional documents called four
herein are obtained, discovered, or become known to you between
the time of responding to the requests and the final
disposition of this action. Number ten social security numbers may
be redacted from documents to the extent required by applicable
law definitions, unless otherwise specified. The documents specified below are
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required to be produced for the time period commencing January first,
nineteen ninety eight and continuing through the present. Where production
of account data is provided in electronic format or media,
the preferred software format to incorporate that data is Microsoft
XL as used here. In the following terms are defined
as indicated all each. The term all indeed shall be
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construed as all in beach two end or the connective's end,
and or shall be construed either disjunctively or conjunctively as
necessary to bring within the scope of the discovery requests
all responses that might otherwise be construed to the outside
of its scope. Three. Communication means the trend dan's middle
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of information in the form of facts, ideas, inquiries, and otherwise. Four.
The terms document or documents are defined to be synonymous
and equal in scope to the usage of these terms
in Federal Rule of Civil Procedure thirty four A, including,
without limitation, any written, drawn, printed, typed, photographed, or other
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graphic or electronically or computerized recorded data or compilations of
any kind or nature prepared or received by, or in
the possession, custody, or control of the answering party, its agents, servants, employees,
or other representatives. Originals, drafts, and all non identical copies
are separate documents within the meaning of this term. Number Five.
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The term identify, when used with reference to a person,
means to give, to the extent known, the person's full name,
present or last known address, and, when referring to a
natural person, additionally, the present or last known place of employment.
Once a person has been identified in accordance with this
sub paragraph, only the name of that person need to
be listed in response to subsequent discovery requesting the identification
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of that person. Six. The term identify, when used with
reference to documents, means to give, to the extent known
the type of document, general subject matter, date of the document,
and author's addresses and recipient. The term identify, when used
with reference to an oral communication, discussion, conversation, or any
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other oral statement, shall mean to describe in detail the
substance of each such communication, discussion, conversation, or statement, state
the date of such communication, discussion, conversation, or statement, the
place where such communication, discussion, conversation or statement was held,
and identify each person present for such communication, discussion, conversation,
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or statement. Number eight. Referring to relating to, reflecting, regarding,
or with respect to mean without limitation, 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,
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or otherwise involve in whole or in part. Number nine,
you and yours shall mean bella kline. These terms also
shall be deemed to include all agents and the other
persons acting or authorized to act on our behalf. Ten
Employee includes, but is not limited to, all current or
reformer salaried employees, hourly employees, independent contractors, and individuals performing
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work as temporary employees for the entity referred to in
the requests. Number eleven. Epstein entities shall include, but not
be limited to, Jeffrey e Epstein, a state of Jeffrey
e Epstein, The nineteen fifty three Trust, J E. G.
E LLC CY Incorporated, Financial Ballistics LLC, f s F LLC,
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FT Real Estate Incorporated, Great Saint Jim LLC, Hyperion Air LLC,
ig O Company LLC, Jeepers Incorporated, Laurel Incorporated, Little Saint
Jim LLC, ls j E LLC, LSJ Emergency LLC, Maple Incorporated,
Michelle's Transportation Company LLC, Nautilus Incorporated, plan D LLC, pop
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Law Incorporated, Prittany LLC, Southern Country International, Ltd, Southern Trust,
Company Incorporated, Southern Trust LLC, Thomas World Air LLC, vtn
T LLC, Zoro Management LLC, MORT Incorporated, cd E Incorporated,
Freedom Air Petroleum LLC, co UQ Foundation, Epstein Foundation Incorporated,
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Epstein Interests, Gratitude America Ltd, Jeffrey Epstein Foundation in Corporated,
Southern Trust Company, Financial Trust Company, igy Ahy, Saint Thomas
Holdings LLC, Butterfly Trust, LSJ Employees, LLC CDE Incorporated, nes
l EC, and Financial Informatics Requests for production from January first,
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nineteen ninety eight to present. Request number one All documents
and communications reflecting or related to payments, reimbursements, or receipts
from or for any females associated with Jeffrey Epstein, including
but not limited as employees or grantees of COUQ Foundation,
the Florida Science Foundation, SLK Designs, SJC Interiors, Jay Epstein,
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Virgin Islands Foundation, Gratitude America Nees or Southern Trust Company.
Request number two All documents and communications reflecting or related
to the American Express Cards other credit cards are bank
accounts paid, opened, or funded by Jeffrey Epstein, any Epstein agent,
including but not limited to you, Richard Kahn, Darren Indike,
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or Harry Beller, or any Epstein entity on behalf of
the females identified in response to request for production number one.
Request number three. All documents and communication reflecting or related
to preparing or filing taxes for any of the females
identified in response to request for production one. Request number four.
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All documents in communications reflecting or related to any correspondence
or other materials provided in connection with any application for
a work permit, visa, citizenship, or other travel or immigration
status for any female associated with Jeffrey Epstein. Request number five.
All documents and communications reflecting or related to obtaining, providing,
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or arranging for cash for Jeffrey Epstein. Request number six.
All documents and communications reflecting or related to instructions or
explanations you provided to any financial institution regarding financial transactions
or due diligence regarding Jeffrey Epstein or any Epstein entity.
Request number eight. All documents and communications reflecting or related
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to the purpose, activities, expenditure, income, or tax incentives for
Financial Trust Company, Financial Trust, Southern Trust Company, Southern Trust,
or Southern Country International Requests number nine any in all
documents and materials related to or reflecting the tax returns
for Financial Trust and Southern Trust, including adjusting journal entries,
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including computations supporting such entries, and supporting schedules and documents
that were proposed or prepared by you. Request number ten.
All documents reflecting the identity of in communications with individuals
or entities to which Financial Trust in Southern Trust provided
financial brokerage or investment advice, or other financial or investment
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related services. Request number eleven. All documents in communication regarding
transfers from Jeepers Incorporated or any other Epstein entity to
Glenn or Eva Anderson Dubin. Request number twelve. All documents
and communications regarding ARDA Bescardis. Request number thirteen. All documents
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in communications related to or reflecting any trust established by
or for Jeffrey Epstein. This document was signed by Denise
George and it was dated September thirtieth, twenty twenty. All right, folks, Well,
the crawl through the underbelly of Epstein's enterprise most certainly continues,
But that's going to do it for this one. All
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the information that goes with this episode can be found
in the description box.