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d-37215House OversightOther

Motion to Quash Subpoena Demanding Sensitive Epstein Victim Records

The passage reveals a legal filing seeking to block a subpoena that requests highly personal data about a minor victim of Jeffrey Epstein. While it references a high‑profile figure (Epstein) and a pot Defendant seeks diary, photos, videos, and cell‑phone records of a minor victim of Jeffrey Epstein. The filing argues the subpoena is oppressive, unreasonable, and unrelated to legitimate case needs.

Date
November 11, 2025
Source
House Oversight
Reference
House Oversight #015602
Pages
1
Persons
1
Integrity
No Hash Available

Summary

The passage reveals a legal filing seeking to block a subpoena that requests highly personal data about a minor victim of Jeffrey Epstein. While it references a high‑profile figure (Epstein) and a pot Defendant seeks diary, photos, videos, and cell‑phone records of a minor victim of Jeffrey Epstein. The filing argues the subpoena is oppressive, unreasonable, and unrelated to legitimate case needs.

Tags

victim-privacyjeffrey-epsteinprivacy-violationsubpoena-abusecivil-procedurelegal-filinglegal-exposurehouse-oversight

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Extracted Text (OCR)

EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
ARGUMENT 1. This Court Should Quash Defendant’s Abusive Subpoena In Its Entirety. Florida Rule of Civil Procedure 1.410(c)(1) provides that the Court may “quash or modify the subpoena if it is unreasonable and oppressive.” /d. The Court has discretion to evaluate the circumstances in determining whether the subpoena is “unreasonable and oppressive.” Matthews v. Kant, 427 So. 2d 369, 370 (Fla. 2d DCA 1983). “The sufficiency thereof is a factual determination for the trial judge who is vested with broad judicial discretion in the matter, and whose order will not be overturned absent a clear showing of abuse of discretion.” Jd.; see also Sunrise Shopping Center, Inc. v. Allied Stores Corp., 270 So. 2d 32 (Fla. 4th DCA 1972) (Fourth DCA quashing lengthy subpoena served on non-party who was not in control of documents as being “oppressive and unreasonable.”). It is undisputed that Jane Doe No. 3 was sexually trafficked as a minor child by Jeffrey Epstein and he was sentenced for his crimes. Allowing the Defendant in this case to force this non-party to provide discovery on this highly sensitive topic would be both oppressive and unreasonable and serves no purpose other than to foster Defendant’s publicly admitted and utterly baseless campaign to try to send Jane Doe No. 3 to “jail.” The documents requested in Defendant’s subpoena demonstrate the oppressive and unreasonable nature of the requests. Defendant, for example, seeks highly personal and sensitive information from this victim of sexual trafficking, including requesting her personal diary during the time when she was being sexually abused as a minor child. See Exhibit 6, Request no. 16. Defendant also demands that this non-party produce photographs and videos of her as a minor child while she was being sexually trafficked by convicted sex offender Jeffrey Epstein. See Exhibit 6, Request nos. 2, 3, 4 and 10. Defendant’s unreasonable subpoena even includes a demand for this non-party’s personal cell phone records for more than a three (3) year period during the time when she was a minor child being sexually trafficked. See Exhibit 6, Request no.

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(USAFLS)

(USAFLS) From: Roy Black < Sent: Wednesda , Februa 11, 2015 8:50 AM To: (USAFLS) Subject: RE: Your phone call Great. Speak to you then. Original Message From: (USAFLS) Imailt Sent: Wednesday, February 11, 2015 8:49 AM To: Roy Black Subject: Re: Your phone call Hi Roy. Thanks for your message. Dexter wants to participate in the call so it is helpful to have a roadmap of the discussion points. We will call your office at 2:00. If there is a better number to call, just shoot me an email. Talk to you soon. Assistant U.S. Attorney Southern District of Florida 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 On Feb 10, 2015, at 7:35 PM, "Roy Black" < mailto: wrote: Marie I was not calling you about the correspondence so don't worry about that. I called you to discuss the plaintiff's replies filed as dockets 310 and 311. We think there are serious misstatements by them in these pleadings. So I just wanted to let you know what our suggested responses are.

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