Mega Edition: The USVI Targets Glenn Dubin And Bella Klein In Their Investigation (9/6/26)

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Hello everyone and welcome to the Jeffrey Epstein Show. I'm
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your host, Bobby Cappucci, and this is a morning update.
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What's going on everybody? So I've had a lot of
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people ask me about the pictures that I post on Twitter,
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and some folks were asking if those prints were for sale.
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And the good news is, they most certainly are. I
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have a profile set up on Picfair, where you can
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go over and purchase some of my prints. Right now,
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I have four prints on there, I believe. And by
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the end of the day today, there will be 12
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or so on there. So make sure that if you're
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interested in some of those pictures, and you've sent me
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a message before asking about them, well, they will be
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there now for purchase if that is something you are
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interested in. Now, as you all know, I really don't
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have much to sell you as far as the Jeffrey
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Epstein case goes. I'm not writing any books or any
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of that stuff at all. It's just with the pictures,
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it's something that I've always really enjoyed doing, right? And
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now that PicFair has a place where I could just
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post my pictures the same as I would on like
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Instagram or something. And it gives people the ability to
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purchase them if they'd like. I think that's a pretty
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cool deal. So if you're interested in those kind of pictures,
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landscape pictures, pictures of, you know, the great Southwest, mainly Nevada, Arizona, Utah,
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Southern California, national parks all across the West Coast, that
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kind of stuff. If you're interested in that, the link
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to the pick fair page will be in the description
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box along with the link to this article that we're
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going to get into, and to the PayPal if you're
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looking to help out the podcast. All right, so on
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to today's article. We're going to talk a little bit
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about this article in the New York Post about Glenn
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Dubin and the subpoena from the Virgin Islands. Now, we
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were way ahead of the curve here, right? OK Magazine
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and Chris Spargo talked about this a couple of weeks ago.
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And like I've said, Chris Spargo over at OK Magazine
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has been all over this. And they've done a fantastic
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job with the news that's coming out of the Virgin Islands.
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And Chris especially deserves a tip of the cap, no
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doubt about it. Him, Kate Bricklett, those are two of
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the journalists that have been covering this case that really
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stand out to me, that have done a fantastic job.
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And I think that it's pretty telling. that OK Magazine
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and Chris Spargo are so ahead of the curve when
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it comes to this subpoena situation. Now, the New York
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Post is usually way out ahead of things when it
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comes to page six kind of reporting. But this comes
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a few weeks after we had originally learned about this.
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The reason I'm adding it to the catalog this morning is,
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like usual, we'll get some context and perhaps we'll glean
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a little nugget or two that we missed the first
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time around. So we're going to talk about bitch-ass Glenn
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Dubin and the fact that him and his wife were
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a lot closer to Jeffrey Epstein than they'd like to
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let on. And now Denise George, man, I almost just
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called her Denise Richards, Denise George down in the Virgin Islands,
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the Attorney General down there, she is involved in a
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civil RICO case right now against Epstein and his estate.
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And she has fired off all sorts of subpoenas to
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Glenn Dubin in relation to Glenn Dubin's children and their
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relationship with Jeffrey Epstein. So shit's getting hot and heavy
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down in the Virgin Islands, as we have known. And
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let me tell you what, as much as I'm not
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a fan of Denise George looking for that money grab,
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I am a big fan of the way she has
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pursued this. I'm a big fan of her firing off
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a grip of subpoenas. And I want more, right? I
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think that not only subpoenas, there should be some indictments
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down there and she should arrest some people. That would
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be fantastic. Let's turn this civil racketeering case into an
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actual criminal RICO case down in the Virgin Islands and
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then have two concurrent RICO investigations running at the same time. Boy,
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that would be fantastic. And that certainly would make up
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some ground that they have lost throughout these decades, huh?
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All right, so our article, New York Post. Headline, Jeffrey
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Epstein case subpoena seeks documents related to billionaire Glenn Dubin's kids. Author,
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Isabel Vincent. Now, let's just pump the brakes right away.
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Imagine being Glenn Dubin and his wife and having your
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kids embroiled in this whole entire brouhaha. You are supposed
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to protect your children from shit like this. Not have
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them hang out with Uncle Jeffy. Not have Uncle Jeffy
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have a trust in their name. Not have Uncle Jeffy
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as the godfather. And certainly, the last thing you want
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is your children's names being brought up in an investigation
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into one of the most prolific pedophiles in the history
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of America. Talk about a failure as a human and
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talk about a failure as a parent. It just goes
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to show you all the money in the world, all
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of the status in the world doesn't mean shit if
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you're a douche. U.S. Virgin Islands prosecutors are demanding billionaire
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MoMA benefactor and board member Glenn Dubin turn over all
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communications that his friend Jeffrey Epstein had with Dubin's three children.
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It's gross, right, to read that. I know I have
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a penchant for being a sarcastic person when it comes
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to this stuff. And I think that that is the
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proper measure when we're dealing with these people. But at
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the same time, it's spine tingling and gross and chilling
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to think that your children would be involved in a
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subpoena that has to do with Jeffrey Epstein. Now, look.
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I'm not a parent. I don't have any kids. I
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have four dogs. Those are like my kids. And I
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wouldn't let my dogs spend a minute with Jeffrey Epstein.
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Never mind my children. And then you want to add
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a little whipped cream on top of that banana split?
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Oh yeah, now your kids' names are being brought up
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in legal documents, subpoenas, that have to do with Jeffrey
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Epstein's criminal enterprise. Glenn Dubin, Eva Dubin, You both suck.
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As human beings. And obviously as parents. A subpoena seeks
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all documents and communications... Related to any of your three children. May,
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Selena or Jordan. Which also relate in any way to
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Jeffrey Epstein. Or any Epstein entity. This is how you
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put the pieces together folks. This is how you build
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a case. Remember when I told you that Rico is
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very invasive... And that RICO charges are far-reaching, meaning even
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people in your family can get caught up in it? Well,
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you're seeing it here, but in a civil version. Now,
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the criminal version of this is even worse, even more draconian.
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You ask me how I know? Well, I've experienced it
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firsthand in my life. I've had a loved one face
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RICO charges. I've had a loved one look at a
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hundred RICO charges. And that's what they do. They throw
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a bunch of RICO charges at you and then they
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go after the people that you loved, anybody you might
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have given money to. They'll tap your children's phones. They'll
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do all sorts of wild shit when they have RICO power.
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And you see that here when they're bringing up the
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names of his children and it's just the part and
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parcel for how a RICO investigation is conducted. And once
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the FBI gets their teeth sunk in on a RICO investigation,
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at least to regular folks, Italian folks anyway, because I
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can only speak about my experiences and what my people
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have dealt with. So when they start with that RICO shit,
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forget it. It doesn't matter if you're a 16-year-old kid
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walking home from school. They're going to try and hem
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you up and ask you about your loved one. Try
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and put you in the back of that car. They're
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going to try and threaten you. They're going to try
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and tell you that your parents are going to go
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to jail if you don't talk to them. And this
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is the kind of shit the FBI does against us,
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the average citizen. But when it comes to bitch-ass mother
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effers like Glenn Dubin and the rest of this posse
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of scumbags, they don't get that kind of treatment. They
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get overlooked. They get lost in the sauce. They get
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moved around in the system. But me or you or
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your loved one, forget it. They get involved in bookmaking? Well,
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they're looking at seven years, seven prime years taken away
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from them and from them and their families. Meanwhile, Jeffrey Epstein,
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13 months? I'll just say right now, straight up, point blank, period,
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F the FBI, okay? They're a bunch of scumbags. They're corrupt.
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The whole organization is corrupt, in my opinion. The island's
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attorney general is probing alleged racketeering by the late billionaire
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pedophile and has issued subpoenas to numerous Epstein associates. including lawyers,
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accountants and bankers. Now, again, I really wish that we'd
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see this in the SDNY. And I think we're going
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to once we get another arrest, if we get another arrest.
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But I'm on record saying that if it doesn't go RICO,
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then in my opinion, the fix is most certainly in.
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And that will be the most telling sign that the
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elite are once again protecting the elite. This is a
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Rico case if I have ever seen one. And we
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have the proof right there in the pudding. With Keith
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Ranieri getting himself 120 years under Rico and racketeering. Allison
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Mack gets charged with racketeering and Rico. But Ghislaine Maxwell doesn't.
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It doesn't sit well with me. And if it doesn't
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go Rico... then you know for a fact that the
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fix is in and I will definitely be on every
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mountaintop yelling even louder than I am now about the
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corruption in the government. And for those of you who
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think that Joe Biden is going to ride in on
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his white horse swinging his sword and cutting down all
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of the orcs of evil around us, folks, I got
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bad news for you. Meet the new boss, same as
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the old boss. The idea is Is to stop sending people.
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Like Biden. To D.C. And. I get it right. A
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lot of people hate Trump. And they you know. This
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was a referendum on Trump. And I understand completely. But
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at the same time. You must stay vigilant. just because
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Biden has been elected as the president-elect of the United
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States of America, doesn't mean that we all throw up
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our hands and say, all right, things are going to
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go back to normal. Everything's good. Nothing is good. Nothing
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is normal. We've had a look behind the curtain now, folks.
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We can't go back. It's only moving forward now. There
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is no retreating. There is no regrouping. There is forming
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a vanguard and smashing hard right into the heart Of
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the elite's lines. And crushing them. And putting them on
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their back foot. And making them scatter for once. And
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that's going to happen. If we do it. No politician
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is going to save us. Joe Biden or otherwise. One
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of you. Out there in the audience. Run for office.
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You might save us. One of you good hearted people.
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With a moral compass. Who understands. That the work of
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the people is more important than enriching yourself. You might
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save us, but none of these retread-ass politicians are going
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to save us. Just like none of these asshole coaches
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who have never succeeded anywhere in the NFL are going
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to make a team succeed magically when they get hired again. Epstein,
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who hanged himself, allegedly, in a Manhattan lockup last year,
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had openly declared his plans to marry Selena Dubin, sources
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told Binnis Insider last year. Epstein and Selena developed an
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especially close relationship when Selena was 12 and it continued
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into adulthood, according to the Palm Beach Post. The whole
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thing was weird, right? This whole thing with Selena Dubin
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and Jeffrey Epstein? Always odd, in my opinion. I mean,
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why in the hell, as an adult, as a parent,
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would you have this little kid calling Jeffrey Epstein Uncle
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Jeffy sitting on his lap? You know what he was. Hell,
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after he was arrested, you had him over for some
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good old turkey dinner. Meanwhile, you're going to try and
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distance yourself from Jeffrey Epstein? You're going to try and
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act like you weren't one of his top dogs? And
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that your wife wasn't his chick back in the day?
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Who knows? You guys might have still been doing the
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same kind of thing. You might have still been... Who
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knows what kind of relationship these people had. Maybe they
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were involved in a thruple. Who the hell knows? My
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point is this. They were very, very close to Jeffrey Epstein.
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Selena wrote glowingly of their weekly science lesson... When Uncle Jeff,
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as she calls him... Takes time from his personal business schedule...
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To go over to her apartment and discuss science and
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mathematics lessons she is learning at school, reported the newspaper,
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citing a profile prepared by Epstein's lawyers in 2007, the
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year they negotiated a non-prosecution agreement that allowed him to
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avoid federal sex trafficking charges. So the most ironic thing
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about this is is that the Dubins themselves opened their
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mouth and this can of worms by writing this glowing
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report for Jeffrey Epstein. They involved their daughter. They brought
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their kids into this. And they were the ones who
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put their kids in jeopardy, in my opinion, by having
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them around a scumbag like Uncle Jeffy Epstein. There is
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no evidence that Epstein ever had a romantic relationship with Selena,
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now 25, according to Business Insider. adding that his motivation
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to marry her might have been driven by his desire
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to leave her his fortune and avoid inheritance taxes. That
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makes no sense, okay? Sorry, really? Jeffrey Epstein, Mr. Scumbag,
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extraordinaire himself, couldn't have found a way to launder that
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money to marry her? That's why he wanted to marry her? No,
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let's stop making excuses for these people. He wanted to, quote-unquote,
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I'm using air quotes right here, folks, you can't see me,
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but that's what I'm doing. He wanted to marry her? No.
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He wanted to be... romantically involved with her he wanted
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to abuse her and he wanted to do what he
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did with every other young teenage girl he came into
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contact with alright let's not sugarcoat it anymore let's not
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cut corners let's not act like Glenn Dubin and his
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wife deserve the benefit of the doubt they do not Look,
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this isn't like a regular case, right? Where everything's happening
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in real time and shit's convoluted and we don't know
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up from down. There's spin, there's propaganda. Of course there's that.
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But we've had plenty of years to go through all
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of these details with a fine-tooth comb. We've had plenty
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of time to compile these articles. And we know from
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the articles that we have read about Glenn Dubin and
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his wife that they are scuzzbags and that they are
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very much involved with Jeffrey Epstein on an intimate level.
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No pun intended. The subpoena, which was filed in Virgin
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Island Superior Court in September, is also seeking all financial
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records between Dubin, who is married to Epstein's former beauty
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queen girlfriend, Eva Anderson Dubin, and Epstein. It also seeks
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all documents and communications with a Swedish female traveling with
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or employed by Epstein. That's huge. That is the little
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girl that cried to the guy in Dubin and Eva
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Andersson's kitchen. Right? The little Swedish girl that we've talked
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about that we always wondered what the hell happened to
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this kid. Well... She is also involved in this, and
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they're asking for documentation that has to do with their
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contact with this unnamed 15-year-old Swedish girl. Who in the
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hell is this poor kid, folks? Where is she? What
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has become of her? And I can only hope that
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she is doing okay now. Court papers unsealed a day
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before Epstein's death last year included allegations that a 15-year-old
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Swedish girl was held against her will on Epstein's compound
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in the Virgin Islands. The girl allegedly told her story
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to Rinaldo Rizzo, a chef who worked for the Dubin family,
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according to court papers. Now remember, this isn't just hearsay.
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This isn't just shit thrown at the wall. That's for
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other people involved in this Jeffrey Epstein case to do.
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That's another, that's another, that's an adventure for them to
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take you on. We don't do that here on this podcast, okay?
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Our work speaks for itself. Everything we talk about is
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in the newspapers and based on court documentation. When I
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go hard on somebody here on the podcast, you better
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damn believe there is a reason, folks. And that is
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exactly what we have here with the Dubins. All of
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this stuff is court documented. This man gave this statement
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under oath. And it's obvious that the Dubins are being
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protected right along with Jeffrey Epstein. But they shouldn't be.
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Our prosecutors and our justice system should be big game
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hunting right now. Both Dubin and his wife, who dated
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Epstein for 11 years, have vigorously denied any knowledge of
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Epstein's wrongdoing. A spokesman for Dubin refused to comment last week.
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And let's not forget also, okay, the 500-pound gorilla in
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the room. Not only is Dubin accused of all of
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this nonsense, okay? Let's not forget what Virginia alleges happened
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to her at the hands of Glenn Dubin when she
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was trafficked to him. All right, let's keep that in
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the forefront of our mind. And the scumbags who have
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been mentioned by Virginia as people who have actually partaken
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in the abuse, those people all need to be brought
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in under the auspices of this grand investigation. They all
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need to be spoken with. Those aren't allegations of stealing
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a bologna sandwich or, you know, uh, You shoved me
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in the street. These are serious allegations that need to
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be looked at. into. And Glenn Dubin, my friends, is
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setting himself up for a huge fall from grace, in
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my opinion. In addition to Dubin, a subpoena in the
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00:20:02.349 --> 00:20:05.869
Epstein case has also been served on billionaire Leon Black,
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who is a member of the Museum of Modern Arts
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Board of Directors along with Dubin. Fellow travelers, huh? And
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what do you think? It's just a coincidence that all
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of these scuzzbags are in the art world or the
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00:20:18.069 --> 00:20:22.849
modeling world or the world of finance? No. These people
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00:20:22.890 --> 00:20:26.299
have been scummy since the start of time. I mean, look,
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I'm not a religious guy, right? I, you know, my...
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That's not my thing. But I will tell you this.
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I believe that Jesus was a real man. And who
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did he get pissed off at? The bankers. The only
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people he ever got pissed off at. Flipped over their table.
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The whole flip. And that's because bankers. Even since before
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00:20:45.809 --> 00:20:49.769
Jesus was around. Have been scumbag. Shit birds. Who have
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done nothing. But destroy the poor populations. That they're in
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charge of lending to. And Glenn Dubin. And Leon Black.
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And the rest of the pieces of shit. That come
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from that world. All deserve the karma train. That has
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just left the station. That is barreling towards them. At
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light speed. In January. Virgin Islands Attorney General Denise George.
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Sued Epstein's estate. Alleging violation of the Virgin Law's. Civil
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racketeering law. And that's what I was talking about earlier.
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About the Civil Rico case. That's what she's engaged in
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here folks. And she's engaged in a Mongolian type of
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campaign of scorched earth, right? She's trying to be Genghis
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Khan and stand atop all of these skulls when she's done.
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But my question is, why is it just civil? Let's
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move it out of the realm of civil and move
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it into the criminal realm down in the Virgin Islands too.
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Because I've said a million times on this podcast, I
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don't care how these people end up in jail. I
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don't care if it's financial crimes. or crimes due to
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their participation with Jeffrey Epstein. All I care about at
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this point, folks, is justice. If you'd like to contact me,
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you can do that at bobbycapucci at protonmail.com. That's B-O-B-B-Y-C-A-P-U-C-C-I
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at protonmail.com. You can also find me on Twitter at
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00:22:19.809 --> 00:22:26.150
B-O-B-B-Y underscore C-A-P-U-C-C-I. All of the links that go with
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this episode can be found in the description box. And
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to everybody who has donated to the podcast and who
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00:22:33.640 --> 00:22:36.720
has supported my work, I appreciate you all more than
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00:22:36.759 --> 00:22:40.519
you will ever know. All right, everybody, we will be
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back tonight for sure with a daily drop. Last night,
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way too tired after UFC, and I figured, eh, you
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guys could go a night without hearing me whinge. All right, folks,
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so until later on, I hope you all enjoy your Sunday.
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What's up, everyone, and welcome back to the Epstein Chronicles.
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In this episode, we're going to dive right back into
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the court documents, and this time we're taking a look
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at the USVI's subpoena to Glenn Dubin. Case number ST-20-CV-014.
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Action for damages. United States government, the US Virgin Islands
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versus Glenn Dubin. Plaintiff subpoena to third party Glenn Dubin.
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In accordance with Rule 45 of the Virgin Islands Rules
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of Civil Procedure and pursuant to subpoena issued in the
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pending action, Government of the United States Virgin Islands v.
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the Estate of Jeffrey Epstein, ST-20-CV-014, before the Superior Court
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00:23:37.890 --> 00:23:45.160
of the Virgin Islands, Division of St. Thomas and St. John, you,
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00:23:45.460 --> 00:23:49.319
Glenn Dubin, are hereby commanded to produce and deliver all
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documents responsive to the request set forth below to Carol
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00:23:53.359 --> 00:23:58.380
Thomas Jacobs, ESQ, within 30 days following receipt of this subpoena.
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00:23:58.859 --> 00:24:02.220
If you have any questions, please contact Carol Thomas Jacobs.
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00:24:03.009 --> 00:24:07.349
Instructions When providing your responses, indicate the request to which
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00:24:07.410 --> 00:24:12.700
each document or answer responds in the metadata field Request Number. 2.
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Documents produced pursuant to these requests shall be produced as
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00:24:16.750 --> 00:24:20.089
they are kept in the ordinary course of business. 3.
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00:24:20.089 --> 00:24:23.710
For each document you produce, the current version together with
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00:24:23.750 --> 00:24:27.769
an earlier edition or predecessor document during the relevant time period,
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00:24:28.109 --> 00:24:30.849
even though the title of earlier documents may differ from
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00:24:30.910 --> 00:24:35.930
current versions. Format for documents produced electronically. A. Data shall
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00:24:35.970 --> 00:24:38.839
be produced in single-page TIFFs at a 300 dpi resolution.
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which are named for the Bates number of the page.
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00:24:43.119 --> 00:24:45.940
There shall be no more than 1,000 images per folder.
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00:24:46.400 --> 00:24:51.200
Bates numbers, confidentiality designations, and redactions shall be burned into
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00:24:51.220 --> 00:24:54.180
the TIFF image file so as not to be unreasonably
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00:24:54.259 --> 00:25:01.609
obstructed any information on the page. B, document unitization. Each
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00:25:01.670 --> 00:25:05.430
page of document shall be electronically converted into an image
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00:25:05.509 --> 00:25:08.569
as described above. If a document is more than one page,
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00:25:08.880 --> 00:25:12.200
The utilization of the document and any attachments and or
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00:25:12.259 --> 00:25:15.990
affixed notes shall be maintained as it existed in the
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00:25:16.049 --> 00:25:20.069
original when creating the image file and appropriately designated in
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00:25:20.109 --> 00:25:25.150
the load files. The corresponding parent-attachment relationships, to the extent possible,
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00:25:25.410 --> 00:25:30.119
shall be provided in the load files furnished with each production. c.
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00:25:30.599 --> 00:25:35.960
Include document-level text files containing optical character recognition or extracted
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00:25:36.019 --> 00:25:39.119
text named With the Bates number of the first page
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00:25:39.160 --> 00:25:43.049
of the document. D. Include data load files containing all
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00:25:43.089 --> 00:25:47.009
of the metadata fields, both system and application, see list below,
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00:25:47.369 --> 00:25:51.099
from the original native documents. E. Include the database field
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00:25:51.119 --> 00:25:54.039
name in the first line of the metadata file in
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00:25:54.099 --> 00:25:57.059
such a manner that it is clear how the metadata
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00:25:57.180 --> 00:26:01.130
is organized in the file. F. All hidden text, e.g.,
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00:26:01.470 --> 00:26:06.109
track changes, hidden columns, comments, notes, etc., shall be expanded, extracted,
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00:26:06.450 --> 00:26:11.390
and rendered into the. tiff file. g. Documents created in
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00:26:11.430 --> 00:26:16.700
Excel spreadsheets, CSV files, Access databases, and audio and video
401
00:26:16.740 --> 00:26:20.559
media files shall be produced in native format. The extractable
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00:26:20.660 --> 00:26:23.859
metadata and text shall be produced in the same manner
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00:26:24.220 --> 00:26:28.519
as other documents that originated in electronic form as described herein.
404
00:26:28.910 --> 00:26:33.400
to the extent that metadata exists or is reasonably accessible. H.
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00:26:33.980 --> 00:26:37.559
Email attachments and embedded files or links shall be mapped
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00:26:37.799 --> 00:26:41.829
to their parent. I. Produce all attachments to responsive documents
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00:26:42.200 --> 00:26:47.829
attached to the responsive document. J. Deduplicate prior to production,
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00:26:48.210 --> 00:26:52.210
to the extent that exact duplicate documents based on MD5
409
00:26:52.630 --> 00:26:56.599
or SHA-1 hash values at the document level reside within
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00:26:56.640 --> 00:26:59.740
the party's data set Each party is only required to
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00:26:59.799 --> 00:27:03.220
produce a single copy of a responsive document so long
412
00:27:03.289 --> 00:27:06.509
as there is a data field which identifies each custodian
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00:27:06.710 --> 00:27:10.329
who had a copy. In addition, documents may be deduplicated
414
00:27:10.670 --> 00:27:14.230
in such a way as to eliminate earlier or incomplete
415
00:27:14.269 --> 00:27:18.170
chains of emails and produce only the most complete iteration
416
00:27:18.210 --> 00:27:20.589
of an email chain so long as there is a
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00:27:20.690 --> 00:27:25.670
data field that identifies each custodian who had a copy. 4.
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00:27:25.670 --> 00:27:28.990
Format for hard copies of documents produced in response to
419
00:27:29.029 --> 00:27:33.069
this request. a. Retype the question or request to which
420
00:27:33.150 --> 00:27:36.829
the documents respond and firmly attach the documents to the
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00:27:36.930 --> 00:27:42.140
retyped request. b. Number all documents consecutively, consistently with the
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00:27:42.180 --> 00:27:48.450
numbers used for the documents produced electronically. 5. Unless otherwise indicated,
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00:27:48.630 --> 00:27:51.700
the relevant time period for this request for production of
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00:27:51.740 --> 00:27:56.940
documents is January 1, 1998 to the present. 6. If
425
00:27:57.000 --> 00:28:02.119
no documents responsive to a particular request exist, so state. 7.
426
00:28:02.119 --> 00:28:04.900
As to any document which no longer exists, but which
427
00:28:04.940 --> 00:28:08.549
you are aware existed at one time, identify such document.
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00:28:08.940 --> 00:28:12.859
with as much particularity as possible, and in addition, identify
429
00:28:12.880 --> 00:28:15.980
the last known location of the document, the reason the
430
00:28:16.019 --> 00:28:19.819
document is no longer in existence, and the person responsible
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00:28:19.880 --> 00:28:24.200
for the document's disposition. 8. For information that you would
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00:28:24.240 --> 00:28:27.200
withhold on the basis of privilege, provide a descriptive list
433
00:28:27.519 --> 00:28:30.680
of each document stating the grounds for your refusal and
434
00:28:30.740 --> 00:28:34.599
providing the following information. The name or title of the document,
435
00:28:34.960 --> 00:28:37.940
a description of the nature and subject matter of the document,
436
00:28:38.299 --> 00:28:42.109
sufficient to enable a meaningful challenge to the assertion of privilege,
437
00:28:42.460 --> 00:28:46.950
the date, author, sender, and recipient of the document, including
438
00:28:46.990 --> 00:28:50.589
whether the person is an attorney or was an employee
439
00:28:50.609 --> 00:28:53.829
of First Bank at the time the document was authored, sent,
440
00:28:53.869 --> 00:28:57.500
or received, and the nature of the privilege. 9. These
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00:28:57.579 --> 00:29:01.230
requests shall be deemed continuing in character. so as to
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00:29:01.269 --> 00:29:05.509
require prompt supplemental responses if additional documents called for herein
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00:29:05.829 --> 00:29:09.630
are obtained, discovered, or become known to you between the
444
00:29:09.670 --> 00:29:13.170
time of responding to the request and the final disposition
445
00:29:13.490 --> 00:29:17.690
of this action. 10. Social security numbers may be redacted
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00:29:17.710 --> 00:29:23.349
from documents to the extent required by applicable law. Definitions 1.
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00:29:23.349 --> 00:29:26.170
All shall be construed to include the collective as well
448
00:29:26.250 --> 00:29:30.869
as the singular and shall mean each, any, and every. 2.
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00:29:30.869 --> 00:29:35.710
Document means any writing or any other tangible thing, whether printed, recorded,
450
00:29:35.990 --> 00:29:39.970
in audio, video, electronically, or by any other means, reproduced.
451
00:29:40.390 --> 00:29:44.210
by any process, or written or produced by hand, including
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00:29:44.259 --> 00:29:51.319
but not limited to letters, memoranda notes, opinions, books, reports, studies, agreements, statements, communications,
453
00:29:51.759 --> 00:29:57.980
including intercompany and intracompany communications, correspondence, telegrams, email, instant messages,
454
00:29:58.339 --> 00:30:04.640
chat logs, SMS, MMS, or other text messages, posted information, messages,
455
00:30:04.740 --> 00:30:08.180
chat logs on social networking sites, including but not limited
456
00:30:08.220 --> 00:30:13.089
to Facebook, Google +, MySpace, and Twitter, logs, bookkeeping entries,
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00:30:13.369 --> 00:30:18.329
summaries of records, of personal conversations, diaries, calendars, telephone messages,
458
00:30:18.750 --> 00:30:25.990
and logs, forecasts, photographs, images, tape recordings, models, statistical statements, graphs, laboratory,
459
00:30:26.009 --> 00:30:32.000
and and engineering reports, notebooks, charts, plans, drawings, minutes, bylaws, resolutions,
460
00:30:32.380 --> 00:30:36.380
records of conferences, expressions or statements of policy, lists of
461
00:30:36.440 --> 00:30:40.440
persons attending meetings or conferences, lists of clients or customers
462
00:30:40.579 --> 00:30:44.980
or suppliers, reports or summaries of interviews, opinions of reports,
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00:30:45.380 --> 00:30:51.240
of negotiations, brochures, pamphlets, advertisements, circulars, trade letters, press releases,
464
00:30:51.640 --> 00:30:54.980
drafts of any document and revisions of drafts of any document,
465
00:30:55.440 --> 00:30:58.750
and any other similar paper of record. The terms also
466
00:30:58.829 --> 00:31:01.990
include a copy of a document where the copy is
467
00:31:02.029 --> 00:31:05.690
not exactly the same as the original. The terms also
468
00:31:05.750 --> 00:31:09.970
include emails and other documents made or stored in electronic form,
469
00:31:10.369 --> 00:31:14.890
whether kept on computers, computer tapes, disks, or drivers, including
470
00:31:14.950 --> 00:31:18.609
cloud storage of any type or other media upon which
471
00:31:18.670 --> 00:31:24.380
information may be recorded. 3. Communication means the transmittal of
472
00:31:24.420 --> 00:31:28.920
information in the form of facts, ideas, inquiries, otherwise. 4.
473
00:31:28.920 --> 00:31:32.380
Including is used merely to emphasize that a request for
474
00:31:32.420 --> 00:31:35.660
a certain type of document or information should be construed
475
00:31:35.740 --> 00:31:39.609
as limiting the request in any way. 5. Referencing to,
476
00:31:39.730 --> 00:31:44.509
relating to, reflecting, regarding, or with respect to mean, without limitation,
477
00:31:44.569 --> 00:32:01.650
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,
478
00:32:01.970 --> 00:32:06.859
or otherwise involve, in whole or in part. 6. Epstein
479
00:32:06.900 --> 00:32:11.640
entities shall include, but not be limited, to Jeffrey E. Epstein,
480
00:32:11.859 --> 00:32:16.819
estate of Jeffrey E. Epstein, the 1953 Trust, JEGE LLC,
481
00:32:17.180 --> 00:32:24.000
Cypress Incorporated, Financial Ballistics, FT Real Estate, Inc., Great St. Jim, LLC,
482
00:32:24.319 --> 00:32:30.980
Hyperion Air, LLC, IGO Company, LLC, Jeepers, Inc., Laurel, Inc.,
483
00:32:30.940 --> 00:32:38.279
Little St. Jim, LLC, LSJE, LLC, LSJ Emergency, LLC, Maple, Inc.,
484
00:32:38.269 --> 00:32:43.609
Michelle's Transportation Company, LLC, Nautilus, Inc., Plan D, LLC, Poplar, Inc., Prititani, LLC,
485
00:32:48.730 --> 00:32:54.069
Southern Country International LTD, Southern Trust Company, Southern Financial, Thomas
486
00:32:54.089 --> 00:32:59.130
World Air, Zorro Management, Mort Incorporated, Freedom Air Petroleum, the
487
00:32:59.170 --> 00:33:05.569
COUQ Foundation, Epstein Foundation Incorporated, Epstein Interest, Gratitude America LTD,
488
00:33:05.990 --> 00:33:12.470
Jeffrey Epstein Foundation, Southern Trust Company, Financial Trust Company, IGYAHY, St.
489
00:33:12.490 --> 00:33:19.210
Thomas Holdings, Butterfly Trust, LSJ Employees, and Financial Informatics. 7.
490
00:33:19.210 --> 00:33:22.789
You or your refers to Glenn Dubin and Dubin & Company.
491
00:33:23.509 --> 00:33:28.549
Request for production from January 1st, 1998 to present. Request
492
00:33:28.569 --> 00:33:32.509
number one. All documents and communication relating to all financial
493
00:33:32.549 --> 00:33:37.190
transactions between you, Jeffrey Epstein, and any Epstein entity, agent,
494
00:33:37.230 --> 00:33:40.390
or associate. This includes but is not limited to three
495
00:33:40.430 --> 00:33:45.690
wire transfers between 2014 and 2016. Request number two. All
496
00:33:45.759 --> 00:33:49.440
documents and communications relating or referring to the Virgin Islands
497
00:33:49.940 --> 00:33:53.460
or Little St. James, including but not limited to, travel
498
00:33:53.519 --> 00:33:56.319
to or from the Virgin Islands or Little St. James.
499
00:33:57.180 --> 00:34:01.130
Request number three. All documents and communications relating or referring
500
00:34:01.170 --> 00:34:06.789
to Jeffrey Epstein's criminal plea, conviction, probation, or any other criminal, civil,
501
00:34:07.109 --> 00:34:11.550
or administrative investigation or litigation related to Epstein or or
502
00:34:11.590 --> 00:34:14.809
the sexual abuse or trafficking of females by Epstein or
503
00:34:14.889 --> 00:34:20.690
any individual associated with Epstein. Request number four. All documents
504
00:34:20.730 --> 00:34:24.929
and communications between you and Darren Indyk, Richard Kahn, Bella Klein,
505
00:34:25.289 --> 00:34:29.250
and or Harry Beller, and or regarding Jeffrey Epstein's estates, trusts,
506
00:34:29.449 --> 00:34:33.690
and or will. Request number five. All documents and communications
507
00:34:33.849 --> 00:34:37.590
regarding any assistant employed by Jeffrey Epstein or with Jeffrey
508
00:34:37.670 --> 00:34:42.139
Epstein or any Epstein agent or associate regarding any au
509
00:34:42.159 --> 00:34:46.639
pair or child care provider employed by you. Request number six.
510
00:34:47.420 --> 00:34:50.960
All documents and communications regarding a Swedish female living with
511
00:34:51.059 --> 00:34:55.519
or employed by Jeffrey Epstein or regarding transportation you provided
512
00:34:55.820 --> 00:35:00.360
or arranged for. Request number seven. all documents and communications
513
00:35:00.480 --> 00:35:04.550
regarding the departure of Ronaldo and or Deborah Rizzo from
514
00:35:04.590 --> 00:35:09.329
your employment, any severance or non-disclosure agreement or payment, or
515
00:35:09.409 --> 00:35:13.400
regarding statements or testimony by Ronaldo or Deborah Rizzo in
516
00:35:13.519 --> 00:35:17.639
any investigation or litigation related to Jeffrey Epstein and or
517
00:35:17.659 --> 00:35:22.239
Ghislaine Maxwell. Request number eight. All documents and communications regarding
518
00:35:22.280 --> 00:35:25.880
travel by you on any airplane used by Jeffrey Epstein,
519
00:35:26.199 --> 00:35:29.989
any travel with Jeffrey Epstein, Ghislaine Maxwell, or any individual
520
00:35:30.070 --> 00:35:35.610
or agent associated with or accompanying Jeff Epstein or Ghislaine Maxwell,
521
00:35:35.769 --> 00:35:39.250
or any travel by Jeffrey Epstein, Ghislaine Maxwell, or any
522
00:35:39.289 --> 00:35:43.519
individual or agent associated with or accompanying Jeffrey Epstein or
523
00:35:43.559 --> 00:35:47.219
Ghislaine Maxwell on an airplane used by you. Request number nine.
524
00:35:47.699 --> 00:35:51.880
All documents and communications... Regarding Virginia Roberts or any other
525
00:35:51.940 --> 00:35:56.829
allegations that you sexually abused any female associated with Jeffrey Epstein.
526
00:35:57.329 --> 00:36:01.989
Request number 10. All documents and communications regarding any employee
527
00:36:02.210 --> 00:36:05.619
or female that was transported by car, plane, boat, or
528
00:36:05.780 --> 00:36:10.179
otherwise to or from any of Jeffrey Epstein's properties. Request
529
00:36:10.199 --> 00:36:13.760
number 11. Any and all documents and communications related to
530
00:36:13.980 --> 00:36:18.179
any of your three children, May, Selena, or Jordan, which
531
00:36:18.260 --> 00:36:21.019
also relate in any way to Jeffrey Epstein or any
532
00:36:21.099 --> 00:36:25.599
Epstein enterprise. Request number 12. All schedules reflecting visits you
533
00:36:25.619 --> 00:36:29.139
made to Jeffrey Epstein's or Glenn Maxwell's properties or any
534
00:36:29.199 --> 00:36:32.489
visits made by Jeffrey Epstein or Glenn Maxwell to any
535
00:36:32.530 --> 00:36:36.550
property owned by you. Request number 13. All documents and
536
00:36:36.570 --> 00:36:41.110
communications about Jeffrey Epstein sent or received by you. Request
537
00:36:41.130 --> 00:36:45.800
number fourteen. All trust documents related to Jeffrey Epstein. Request
538
00:36:45.820 --> 00:36:50.559
number fifteen. All documents and communications evidencing donations made by
539
00:36:50.599 --> 00:36:54.760
you to Jeffrey Epstein or an Epstein entity or donations
540
00:36:54.820 --> 00:36:58.059
by Jeffrey Epstein to you or an entity related to you.
541
00:36:58.699 --> 00:37:02.920
Request number sixteen. All documents and communications between you and
542
00:37:02.980 --> 00:37:08.659
any female associated with Jeffrey Epstein. Number seventeen. All documents
543
00:37:08.739 --> 00:37:12.699
and communications related to or reflecting any massage you received
544
00:37:12.980 --> 00:37:16.440
at any of Jeffrey Epstein's properties or performed by someone
545
00:37:16.480 --> 00:37:19.699
sent to your property at the direction of Jeffrey Epstein.
546
00:37:20.199 --> 00:37:24.429
Request number 18. All documents and communication related to or
547
00:37:24.510 --> 00:37:28.610
reflecting any assistance that you provided in securing employment for
548
00:37:28.769 --> 00:37:31.989
any female at the request of Jeffrey Epstein or for
549
00:37:32.050 --> 00:37:36.800
any female associated with Jeffrey Epstein. Request number 19. All
550
00:37:36.840 --> 00:37:40.920
documents and communications between you, Jeffrey Epstein, and or James E.
551
00:37:40.940 --> 00:37:45.320
Staley regarding massages, travel to or meetings in the Virgin
552
00:37:45.409 --> 00:37:48.889
Islands or elsewhere, the sale or purchase of Highbridge Capital,
553
00:37:49.250 --> 00:37:53.449
or any other financial transaction, commission, fee, or investment, or
554
00:37:53.650 --> 00:37:58.730
any Epstein entity. Request number 20. All documents and communications
555
00:37:58.769 --> 00:38:03.030
between you, Jeffrey Epstein, and or Daniel Zwirn regarding investments
556
00:38:03.090 --> 00:38:07.429
by Jeffrey Epstein, in or litigation related to investments by
557
00:38:07.489 --> 00:38:12.739
Jeffrey Epstein. Request number 21, all documents and communications reflecting
558
00:38:12.780 --> 00:38:16.920
your relationship, including as an investment advisor to Jeffrey Epstein
559
00:38:17.219 --> 00:38:22.639
or any Epstein entity. Request number 22, any photographs, videos,
560
00:38:23.039 --> 00:38:26.940
or other recordings related to or reflecting any visits you
561
00:38:26.960 --> 00:38:31.349
made to Little St. James. This was dated September 3rd, 2020,
562
00:38:31.329 --> 00:38:35.809
and it was signed by Denise George. Alright folks, that's
563
00:38:35.829 --> 00:38:37.750
going to do it for this one. All of the
564
00:38:37.789 --> 00:38:41.050
information that goes with this episode can be found in
565
00:38:41.070 --> 00:38:44.809
the description box. What's up everyone and welcome back to
566
00:38:44.829 --> 00:38:49.030
the Epstein Chronicles. In this episode, we're taking a look
567
00:38:49.489 --> 00:38:54.679
at the U.S. Virgin Islands and their subpoena to Bella Klein.
568
00:38:55.760 --> 00:39:03.590
Case number ST-20-CV-014 Government of the United States Virgin Islands vs.
569
00:39:03.630 --> 00:39:07.010
Darren K. Endyke in his capacity as the executor for
570
00:39:07.050 --> 00:39:11.219
the estate of Jeffrey E. Epstein, and against Richard D.
571
00:39:11.320 --> 00:39:14.960
Kahn in his capacity as the executor of the estate
572
00:39:15.300 --> 00:39:19.780
of Jeffrey E. Epstein. Plaintiff's Subpoena to Third Party Bella
573
00:39:19.800 --> 00:39:23.409
Klein In accordance with Rule 45 of the Virgin Islands
574
00:39:23.469 --> 00:39:27.170
Rules of Civil Procedure and pursuant to the subpoena issued
575
00:39:27.510 --> 00:39:31.059
in the pending Action Government of the United States, Virgin
576
00:39:31.119 --> 00:39:35.480
Islands v. The Estate of Jeffrey E. Epstein, before the
577
00:39:35.519 --> 00:39:38.980
Superior Court of the Virgin Islands Division of St. Thomas
578
00:39:39.199 --> 00:39:42.719
and St. John, you, Bella Klein, are hereby commanded to
579
00:39:42.760 --> 00:39:46.440
produce and deliver all documents responsive to the request set
580
00:39:46.519 --> 00:39:50.510
forth below the to Carol Thomas Jacobs within 30 days
581
00:39:50.530 --> 00:39:54.269
of following receipt of the subpoena. If you have any questions,
582
00:39:54.369 --> 00:39:59.659
please contact Carol Thomas Jacobs. The instructions. One, when providing
583
00:39:59.699 --> 00:40:03.039
your responses, indicate the request to which each document or
584
00:40:03.199 --> 00:40:08.559
answer responds in the metadata field. Two, documents produced pursuant
585
00:40:08.840 --> 00:40:11.860
to these requests shall be produced as they are kept
586
00:40:11.980 --> 00:40:15.539
in the ordinary course of business. Three, for each document
587
00:40:15.559 --> 00:40:19.099
you must produce Produce the current version together with all
588
00:40:19.219 --> 00:40:23.119
earlier editions or predecessor documents during the relevant time period,
589
00:40:23.480 --> 00:40:26.349
even though the title of earlier documents may differ from
590
00:40:26.409 --> 00:40:32.070
current versions. Format for documents produced electronically. A. Data shall
591
00:40:32.130 --> 00:40:36.769
be produced in single-page TIFFs at 300 dpi resolution, which
592
00:40:36.849 --> 00:40:39.210
are named for the Bates number of the page. There
593
00:40:39.230 --> 00:40:43.280
shall be no more than 1,000 images per folder. Bates numbers...
594
00:40:43.239 --> 00:40:47.269
Confidentiality designations and redactions shall be burned into the TIFF
595
00:40:47.329 --> 00:40:51.329
image file so as to not unreasonably obstruct any information
596
00:40:51.650 --> 00:40:56.389
on the page. b. Document Unitization Each page of a
597
00:40:56.409 --> 00:41:00.309
document shall be electronically converted into an image as described above.
598
00:41:00.869 --> 00:41:03.809
If a document is more than one page, the unitization
599
00:41:03.949 --> 00:41:07.329
of the document and any attachments and or affixed notes
600
00:41:07.670 --> 00:41:10.909
shall be maintained as it existed in the original when
601
00:41:10.969 --> 00:41:15.400
creating the image file and appropriately designated in the load files.
602
00:41:15.940 --> 00:41:20.440
The corresponding parent-attachment relationships, to the extent possible, shall be
603
00:41:20.480 --> 00:41:24.780
provided in the load files furnished with each production. C.
604
00:41:25.280 --> 00:41:31.000
Include document-level text files. Containing optical character recognition, OCR, or
605
00:41:31.059 --> 00:41:34.039
extracted text named with the Bates number of the first
606
00:41:34.059 --> 00:41:37.780
page of the document, D. Include data load files containing
607
00:41:37.880 --> 00:41:41.159
all of the metadata fields, both system and application. See
608
00:41:41.219 --> 00:41:44.869
list below. From the original native documents, E. Include the
609
00:41:44.909 --> 00:41:47.550
database field name in the first line of the metadata
610
00:41:47.570 --> 00:41:50.349
file in such a manner that it is clear how
611
00:41:50.389 --> 00:41:54.389
the metadata is organized in the file. F. All hidden text, e.g.
612
00:41:54.769 --> 00:41:59.590
track changes, hidden columns, comments, notes, etc. shall be expanded, extracted,
613
00:41:59.909 --> 00:42:03.889
and rendered in the TIFF file. G. Documents created in
614
00:42:03.949 --> 00:42:08.829
Excel or CSV files, access databases, and audio and video
615
00:42:08.889 --> 00:42:13.090
media files shall be produced in native format. The extractable
616
00:42:13.250 --> 00:42:16.269
metadata file and text shall be produced in the same
617
00:42:16.329 --> 00:42:20.389
manner as other documents that originated in electronic form as
618
00:42:20.429 --> 00:42:24.360
described herein. To the extent that the exact duplicate documents
619
00:42:24.449 --> 00:42:28.000
based on MD5 or SHA, one hash values at the
620
00:42:28.039 --> 00:42:31.679
document level reside within a party's dataset, each party is
621
00:42:31.760 --> 00:42:35.159
only required to produce a single copy of a responsive
622
00:42:35.199 --> 00:42:37.750
document so long as there is a data field that
623
00:42:37.889 --> 00:42:42.300
identifies each custodian who had a copy. In addition, documents
624
00:42:42.360 --> 00:42:46.150
may be deduplicated in such a way as to eliminate
625
00:42:46.510 --> 00:42:49.769
earlier or incomplete chains of emails and produce only the
626
00:42:49.809 --> 00:42:53.429
most complete iteration of an email chain so long as
627
00:42:53.469 --> 00:42:56.880
there is a data field that identifies each custodian who
628
00:42:56.909 --> 00:43:01.340
had a copy. 4. Format for hard copies of documents
629
00:43:01.400 --> 00:43:05.340
produced in response to this request. A. Retype the question
630
00:43:05.480 --> 00:43:08.800
or request to which the documents respond and firmly attach
631
00:43:08.860 --> 00:43:13.750
the documents to the retyped request. B. Number all documents consecutively,
632
00:43:14.070 --> 00:43:19.800
consistently with the numbers used for the documents produced electronically. 5.
633
00:43:19.800 --> 00:43:23.579
Unless otherwise indicated, the relevant time period for this request
634
00:43:23.619 --> 00:43:29.260
for production of documents is January 1, 1998 to the present. 6.
635
00:43:29.260 --> 00:43:34.389
If no documents responsive to a particular request exist, so state. 7.
636
00:43:34.389 --> 00:43:37.340
As to any document which no longer exists, but which
637
00:43:37.380 --> 00:43:40.380
you are aware existed at one time, identify such a
638
00:43:40.420 --> 00:43:44.550
document with as much particularity as possible, and in addition
639
00:43:44.619 --> 00:43:48.090
identify the last known location of the document, the reason
640
00:43:48.130 --> 00:43:51.650
the document is no longer in existence, and the person
641
00:43:51.710 --> 00:43:56.650
responsible for the document's disposition. 8. For information that you
642
00:43:56.710 --> 00:43:59.829
withhold on the basis of privilege, provide a descriptive list
643
00:43:59.889 --> 00:44:03.110
of each document stating the grounds for your refusal and
644
00:44:03.150 --> 00:44:07.449
providing the following information. the name or title of the document,
645
00:44:07.840 --> 00:44:10.460
a description of the nature and subject matter of the
646
00:44:10.500 --> 00:44:14.480
document sufficient to enable a meaningful challenge to the assertion
647
00:44:14.619 --> 00:44:19.760
of privilege, the date, author, sender, and recipient of the document,
648
00:44:20.139 --> 00:44:23.199
including whether the person is an attorney and or was
649
00:44:23.239 --> 00:44:26.219
an employee of First Bank at the time the document
650
00:44:26.260 --> 00:44:30.829
was authored, sent or received, and the nature of the privilege. 9.
651
00:44:30.829 --> 00:44:34.909
These requests shall be deemed Continuing in character so as
652
00:44:34.969 --> 00:44:39.349
to require prompt supplemental responses if additional documents called for
653
00:44:39.389 --> 00:44:43.429
herein are obtained, discovered, or become known to you between
654
00:44:43.449 --> 00:44:46.110
the time of responding to the request and the final
655
00:44:46.139 --> 00:44:50.800
disposition of this action. 10. Social Security numbers may be
656
00:44:50.860 --> 00:44:54.599
redacted from documents to the extent required by applicable law.
657
00:44:55.860 --> 00:45:00.710
Definitions Unless otherwise specified, the documents specified below are required
658
00:45:00.750 --> 00:45:04.559
to be produced for the time period commencing January 1,
659
00:45:04.559 --> 00:45:08.219
1998 and continuing through the present. Where production of account
660
00:45:08.260 --> 00:45:11.760
data is provided in electronic format or media, the preferred
661
00:45:11.800 --> 00:45:16.360
software format to incorporate that data is Microsoft Excel. As
662
00:45:16.519 --> 00:45:20.429
used herein, the following terms are defined as indicated. All each.
663
00:45:20.869 --> 00:45:23.929
The term all and each shall be construed as all
664
00:45:23.989 --> 00:45:28.130
and each. To. End or the connectives end and or
665
00:45:28.429 --> 00:45:33.329
shall be construed either disjunctively or conjunctively as necessary to
666
00:45:33.389 --> 00:45:36.449
bring within the scope of the discovery requests all responses
667
00:45:36.820 --> 00:45:40.860
that might otherwise be construed to the outside of its scope. 3.
668
00:45:40.860 --> 00:45:46.000
Communication means the transmittal of information in the form of facts, ideas, inquiries,
669
00:45:46.380 --> 00:45:50.909
and otherwise. 4. The terms document or documents are defined
670
00:45:50.949 --> 00:45:53.969
to be synonymous and equal in scope to the usage
671
00:45:54.289 --> 00:45:58.630
of these terms in Federal Rule of Civil Procedure 34A, including,
672
00:45:58.889 --> 00:46:03.619
without limitation, any written, drawn, printed, typed, photographed, or other
673
00:46:03.679 --> 00:46:08.619
graphic or electronically or computerized recorded data or compilations of
674
00:46:08.699 --> 00:46:12.150
any kind or nature prepared or received by, or in
675
00:46:12.190 --> 00:46:17.820
the possession, custody, or control of the answering party, its agents, servants, employees,
676
00:46:18.179 --> 00:46:22.579
or other representatives, originals, drafts, and all non-identical copies or
677
00:46:22.639 --> 00:46:27.480
separate documents within the meaning of this term. 5. The
678
00:46:27.539 --> 00:46:30.980
term identify, when used with reference to a person, means
679
00:46:31.019 --> 00:46:34.539
to give, to the extent known, the person's full name, present,
680
00:46:34.880 --> 00:46:38.719
or last known address, and when referring to a natural person, additionally,
681
00:46:39.079 --> 00:46:42.019
the present or last known place of employment. Once a
682
00:46:42.059 --> 00:46:45.719
person has been identified in accordance with this subparagraph, only
683
00:46:45.760 --> 00:46:48.000
the name of that person need to be listed in
684
00:46:48.059 --> 00:46:53.670
response to subsequent discovery requesting the identification of that person. 6.
685
00:46:53.670 --> 00:46:57.289
The term identify when used with reference to documents means
686
00:46:57.329 --> 00:46:59.969
to give to the extent known the type of document,
687
00:47:00.289 --> 00:47:04.369
general subject matter, date of the document, and author's addresses
688
00:47:04.590 --> 00:47:08.769
and recipient. The term identify when used with reference to
689
00:47:08.809 --> 00:47:12.989
an oral communication, discussion, conversation, or any other oral statement,
690
00:47:13.329 --> 00:47:16.449
shall mean to describe in detail the substance of each
691
00:47:16.849 --> 00:47:21.289
such communication, discussion, conversation, or statement, state the date of
692
00:47:21.349 --> 00:47:28.380
such communication, discussion, conversation, or statement, the place where such communication, discussion, conversation,
693
00:47:28.420 --> 00:47:31.940
or statement was held, and identify each person present for
694
00:47:32.000 --> 00:47:39.679
such communication, discussion, conversation, or statement. 8. Referring to, Relating to, Reflecting, Regarding,
695
00:47:40.059 --> 00:47:44.750
or with respect to mean, without limitation, the concepts pertain to,
696
00:47:44.969 --> 00:48:01.119
deal with, concern, reflect, record, report, constitute, contain, mention, describe, discuss, analyze, evaluate, estimate, study, survey, project, assess, support, modify, contradict, criticize, summarize, comment,
697
00:48:01.199 --> 00:48:05.159
or otherwise involve, in whole or in part. Number nine.
698
00:48:05.630 --> 00:48:09.030
You and your shall mean Bella Klein. These terms also
699
00:48:09.090 --> 00:48:12.269
shall be deemed to include all agents and other persons
700
00:48:12.429 --> 00:48:17.079
acting or authorized to act on her behalf. 10. Employee includes,
701
00:48:17.139 --> 00:48:20.960
but is not limited to, all current or former salaried employees,
702
00:48:21.300 --> 00:48:26.860
hourly employees, independent contractors, and individuals performing work as temporary
703
00:48:26.900 --> 00:48:31.840
employees for the entity referred to in the request. 11.
704
00:48:31.840 --> 00:48:36.530
Epstein entities shall include, but not be limited to, Jeffrey E. Epstein,
705
00:48:36.889 --> 00:48:41.929
Estate of Jeffrey E. Epstein, The 1953 Trust, JEGE LLC,
706
00:48:42.349 --> 00:48:49.210
Cypress Inc., Financial Ballistics LLC, FSF LLC, FT Real Estate Inc.,
707
00:48:49.210 --> 00:48:54.889
Great St. Jim LLC, Hyperion Air LLC, IGO Company LLC,
708
00:48:55.329 --> 00:49:02.880
Jeepers Inc., Laurel Inc., Little St. Jim LLC, LSJE LLC,
709
00:49:03.440 --> 00:49:11.190
LSJ Emergency LLC, Maple Inc., Michelle's Transportation Company LLC, Nautilus Inc.,
710
00:49:11.050 --> 00:49:18.510
Plan D LLC, Poplar Inc., Prittany LLC, Southern Country International LTD,
711
00:49:18.869 --> 00:49:24.079
Southern Trust Company Inc., Southern Trust, LLC, Thomas World Air, LLC,
712
00:49:24.420 --> 00:49:31.269
VT & T, LLC, Zorro Management, LLC, Morton, Inc., CDE, Inc.,
713
00:49:31.300 --> 00:49:39.090
Freedom Air Petroleum, LLC, COUQ Foundation, Epstein Foundation, Inc., Epstein Interest,
714
00:49:39.250 --> 00:49:44.699
Gratitude America LTD, Jeffrey Epstein Foundation Incorporated, Southern Trust Company,
715
00:49:44.989 --> 00:49:51.659
Financial Trust Company, IGYAHY, St. Thomas Holdings LLC, Butterfly Trust,
716
00:49:52.239 --> 00:49:59.170
LSJ Employees LLC, CDE Incorporated, NES LEC, and Financial Infomatics.
717
00:49:59.969 --> 00:50:03.090
Request for Production From January 1, 1998 to Present Request
718
00:50:03.110 --> 00:50:10.230
Number 1 All documents and communications reflecting or related to payments, reimbursements,
719
00:50:10.329 --> 00:50:14.679
or receipts from or for any females associated with Jeffrey Epstein,
720
00:50:14.739 --> 00:50:19.980
including but not limited, as employees or grantees of COUQ Foundation,
721
00:50:20.219 --> 00:50:26.400
the Florida Science Foundation, SLK Designs, SJC Interiors, Jay Epstein,
722
00:50:26.440 --> 00:50:31.719
Virgin Islands Foundation, Gratitude America, NES, or Southern Trust Company.
723
00:50:32.059 --> 00:50:36.170
Request number two. All documents and communications reflecting or related
724
00:50:36.210 --> 00:50:39.050
to the American Express cards, other credit cards, or bank
725
00:50:39.090 --> 00:50:44.010
accounts paid, opened, or funded by Jeffrey Epstein, any Epstein agent,
726
00:50:44.289 --> 00:50:47.840
including but not limited to you, Richard Kahn, Darren Indyke,
727
00:50:48.000 --> 00:50:51.400
or Harry Beller, or any Epstein entity on behalf of
728
00:50:51.420 --> 00:50:55.300
the females identified in response to request for production number one.
729
00:50:55.920 --> 00:51:00.679
Request number three. All documents and communication reflecting or related
730
00:51:00.699 --> 00:51:03.539
to to preparing or filing taxes for any of the
731
00:51:03.579 --> 00:51:08.219
females identified in response to requests for Production 1. Request
732
00:51:08.260 --> 00:51:12.610
number 4. All documents and communications reflecting or related to
733
00:51:12.750 --> 00:51:16.949
any correspondence or other materials provided in connection with any
734
00:51:17.030 --> 00:51:21.250
application for a work permit, visa, citizenship, or other travel
735
00:51:21.349 --> 00:51:25.750
or immigration status for any female associated with Jeffrey Epstein.
736
00:51:26.230 --> 00:51:30.750
Request number 5. All documents and communications reflecting or related
737
00:51:30.789 --> 00:51:34.829
to obtaining, providing, or arranging for cash for Jeffrey Epstein.
738
00:51:35.369 --> 00:51:39.670
Request number six. All documents and communications reflecting or related
739
00:51:39.949 --> 00:51:44.079
to instructions or explanations you provided to any financial institution
740
00:51:44.280 --> 00:51:49.539
regarding financial transactions or due diligence regarding Jeffrey Epstein or
741
00:51:49.559 --> 00:51:54.969
any Epstein entity. Request number eight. All documents and communications
742
00:51:55.250 --> 00:52:00.929
reflecting or related to the purpose, activities, expenditure, income, or
743
00:52:01.010 --> 00:52:05.690
tax incentives for Financial Trust Company, Financial Trust, Southern Trust Company,
744
00:52:05.869 --> 00:52:11.590
Southern Trust, or Southern Country International. Request number nine. Any
745
00:52:11.630 --> 00:52:14.670
and all documents and materials related to or reflecting the
746
00:52:14.690 --> 00:52:18.929
tax returns for Financial Trust and Southern Trust, including adjusting
747
00:52:18.969 --> 00:52:24.079
journal entries, including computation supporting such entries, and supporting schedules
748
00:52:24.239 --> 00:52:28.320
and documents that were proposed or prepared by you. Request
749
00:52:28.360 --> 00:52:33.090
number 10. All documents reflecting the identity of and communications
750
00:52:33.119 --> 00:52:36.530
with individuals or entities to which Financial Trust and Southern
751
00:52:36.570 --> 00:52:41.409
Trust provided financial, brokerage, or investment advice or other financial
752
00:52:41.710 --> 00:52:46.929
or investment-related services. Request number 11. All documents and communication
753
00:52:47.030 --> 00:52:51.099
regarding transfers from Jeepers Incorporated or any other Epstein entity
754
00:52:51.380 --> 00:52:56.489
to Glenn or Eva Incorporated Anderson Dubin. Request number 12.
755
00:52:56.489 --> 00:53:02.849
All documents and communications regarding Arda Beskardas. Request number 13.
756
00:53:02.849 --> 00:53:06.659
All documents and communications related to or reflecting any trust
757
00:53:06.719 --> 00:53:11.780
established by or for Jeffrey Epstein. This document was signed
758
00:53:11.800 --> 00:53:15.320
by Denise George and it was dated September 30th, 2020.
759
00:53:15.320 --> 00:53:19.800
All right, folks. Well, the crawl through the underbelly of
760
00:53:19.900 --> 00:53:23.639
Epstein's enterprise most certainly continues. But that's going to do
761
00:53:23.699 --> 00:53:26.389
it for this one. All the information that goes with
762
00:53:26.449 --> 00:53:29.320
this episode can be found in the description box.