EFTA00088990¶
(Grand Jury Subpoena to Richard Kahn, dated October 18, 2019)¶
Instructions and Definitions:¶
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This Subpoena calls for the production of categories of documents, records, correspondence, and other material (including electronically stored material), as specified below, in the possession, custody, or control of Richard Kahn.
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This subpoena covers all responsive documents wherever they may be found, including on computers, servers, and personal electronic devices, whether in the United States or any foreign jurisdiction.
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The “Will” means the Last Will and Testament of Jeffrey E. Epstein, executed on August 8, 2019.
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Where possible, please produce the records requested herein in electronic form (native format where necessary to view the material in its full scope) in a manner that is OCR-searchable, and with all available electronic metadata.
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This subpoena does not call for the production of any documents protected by a valid claim of privilege, although any responsive document over which privilege is being asserted must be preserved. Any documents withheld on grounds of privilege may be required to be specifically identified on a privilege log with descriptions sufficient to identify their dates, authors, recipients, and general subject matter.
Materials To Be Produced:¶
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Any documents relating to “The 1953 Trust,” described in the Will, executed on August 8, 2019, including but not limited to The 1953 Trust agreement itself, and any trust documents referenced or referred to within The 1953 Trust, including but not limited to any such trust agreements themselves for any such trusts referenced or referred to in The 1953 Trust (collectively and in total, the “Trust Documents”);
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Any drafts or notes of the Trust Documents; and
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Any communications relating to the Trust Documents.
N. B.: Personal appearance is not required if the requested records are (1) produced by on or before the return date to Assistant U.S. Attorney at: U.S. Attorney’s Office, Southern District of New York, 1 St. Andrew’s Plaza, New York, NY 10007, telephone: , or via email at ; and (2) accompanied by an executed copy of the attached Declaration of Custodian of Records. PLEASE PROVIDE IN ELECTRONIC FORMAT IF POSSIBLE.¶
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EFTA00088991¶
IMPORTANT: REQUEST FOR NON-DISCLOSURE¶
Due to the ongoing nature of the investigation, it is requested that you do not disclose any information relating to this Grand Jury subpoena request to any third party.¶
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