EFTA00480826.pdf
From:
To: Jeffrey Epstein
EFTA00421164.pdf
From: Lesley Groff
To: Darren Indyke
Subject: Fwd: Reminder: Remind D: Fowler deferred setting the depositions of Edw... @ Thu Jan 26 4am -
5am
Date: Thu, 26 Jan 2012 12:37:12 +0000
Sent from my iPhone
Begin forwarded message:
From: Google Calendar
EFTA02043668.pdf
To: From: Bebe Sent Wed 9/7/2016 11:12:16 AM Subject: Re: jeffrey's deposition in FL on Friday... Yes. I will email you as soon as I get in office :) Sent from my iPhone > On Sep 6, 2016, at 8:06 PM, m> wrote: > do you have the information on Jeffrey's deposition in FL this friday...where, when, etc? If not, can you get from Darren so I can put in Jeffrey's itinerary... > > :) EFTA_R1_00573239 EFTA02043668
EFTA00673177.pdf
From: Martin Weinberg
To: Jeff Epstein
EFTA00286335.pdf
EFTA00286335 Epstein v. Rothstein & Edwards Case No.: 50-2009 CA 040800 AG SCHEDULE OF UPCOMING DEPOSITIONS DATE TIME LOCATION DESCRIPTION NOTES 5/17 (Tentative) 10:00am FWB -Miami Office Our Dego of 5/23 9:00am Los Angeles, CA Edwards' depo of We are filing a Motion (PST)/ Alfred Seckel to Quash the 12:00 pm Subpoena (EST) 5/25 10:30 am Dewey a LeBouef Our Deposition duces (NY) 1301 Avenue of the tecum of AJ DiScala Americas NY NY EFTA00286336 Epstein v. Rothstein Case No.: 50-2009 CA 040800 AG SCHEDULE OF UPCOMING HEARINGS DATE TIME DESCRIPTION NOTES 5/10 1:30pm Bankruptcy Court Hearing on Qtask's Motion for Stay of Order Denying Reconsideration of Order Granting TTEE's Motion to Compel and Qtask's Compliance with Deposition EFTA00286337 5/19 9:30am Case Management Conference - Judge Crow will hear all (all day) pending discovery motions and motions re privilege issues as follows: Our Motions: 1). Motion to Compel/Motion to Determine if Priv Claims are Waived; 2). Motion for Protective Order re Video Depo of JEE; 3). Motion to Quash Subpoena and For Protective Order re Depo of Alfred Seckel; 4). Amended and Supplemental Motion to Overrule Objections and Compel Edwards to Answer Questions and Appear for Further Deposition; 5). Motion for Protective Order to Preclude Scarola Et Edwards from making Extra Judicial Statements and Commentary to the Media and Press (Judge Crow) Edwards' Motions: 1). Motion to Dismiss the Amended Complaint; 2). Motion for Protective Order and Objections to Canceled Notice of Taking Deposition and Appointment of Special Master; 3). Motion to Assert Punitive Damage Claims; EFTA00286338 4). Motion for Reconsideration of Order Sustaining Plaintiff's Objections to Discovery dated December 22, 2010; 5). Motion to Compel and Impose Sanctions for Epstein's Failure to Appear for Deposition; Non-Party Motions: 1). Spencer Kuvin's Motion for Protective Order and Objection to Subpoena for Joint Privilege Documents; 2). Non-Party Podhurst a Orseck, P.A.'s Motion for Protective Order and Stay Order. EFTA00286339 Epstein v. Rothstein Case No.: 50-2009 CA 040800 AG CALENDARED DEADLINES DATE DEADLINE DESCRIPTION NOTES 5/2 Epstein must file and serve his response to Edwards' Addt'l Interrogatory served by fax on 4/1/11 5/2 All parties must file any addt'l motions relating to discovery or privilege issues per Case Management Order 5/6 All parties must deliver an updated list on all motions to be heard at the 5/19 Case Managment Conference 5/9 All parties must file their responses to any addt'l motions relating to discovery or privilege issues which were filed by 5/2 and will be heard at the 5/19 Case Mgmt. Conference 5/11 Each party must deliver a copy of each of their motions and any responses filed thereto to the court in advance of the 5/19 Case Management Conference 5/16 Epstein's Response to Edwards RTP due (Faxed 4/15)
EFTA00750930.pdf
AO SSA (Rev. 01109) Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action UNITED STATES DISTRICT COURT for the Southern District of Florida JANE DOE Plaintiff V. Civil Action No. 08-90893CIV-MARRAMOHNSO JEFFREY EPSTEIN (If the action is pending in another district, state where: Defendant SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION To: New York, NY Testimony: YOU ARE COMMANDED to appear at the time, date, and place set forth below to testify at a deposition to be taken in this civil action. If you are an organization that is not a party in this case, you must designate one or more officers, directors, or managing agents, or designate other persons who consent to testify on your behalf about the following matters, or those set forth in an attachment: Place: Esquire Court Reporters, One Penn Plaza Date and Time: Suite 4715, New York, NY 09/03)2009 11:00 am The deposition will be recorded by this method: O Production: You, or your representatives, must also bring with you to the deposition the following documents, electronically stored information, or objects, and permit their inspection, copying, testing, or sampling of the material: The provisions of Fed. R. Civ. P. 45(c), relating to your protection as a person subject to a subpoena, and Rule 45 (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, are attached. Date: CLERK OF COURT OR Signature of Clerk or Deputy Clerk Attorney's signature The name, address, e-mail, and telephone number of the attorney representing (name ofparty) , who issues or requests this subpoena, are: Brad Edwards, Esq., Rothstein Rosenfeldt Adler, 401 E. Las Olas Blvd., Suite 1650, Fort Lauderdale, Florida 33301 Bedwards@rra-law.com. (954) 522 2346 EFTA00750930 AO 88A (Rev. 01/09) Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action (Page 2) Civil Action No. 08-90893CIV-MARRAIJ0HNS0 PROOF OF SERVICE (This section should not be filed with the court unless required by Fed. R. Civ. P. 45.) This subpoena for (name ofindividual and title, if any) was received by me on (date) O I personally served the subpoena on the individual at (place) on (date) ; or O I left the subpoena at the individual's residence or usual place of abode with (name) , a person of suitable age and discretion who resides there, on (date) , and mailed a copy to the individual's last known address; or O I served the subpoena on (name ofindividual) , who is designated by law to accept service of process on behalf of (name oforganization) on (date) ; or O I returned the subpoena unexecuted because ; or O Other (specify): Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness fees for one day's attendance, and the mileage allowed by law, in the amount of My fees are $ for travel and $ for services, for a total of $ 0.00 I declare under penalty of perjury that this information is true. Date: Server's signature Printed name and title Server's address Additional information regarding attempted service, etc: Print Save As... Attach Reset EFTA00750931 AO SSA (Rev. 01109) Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action (Page 3) Federal Rule of Civil Procedure 45 (c), (d), and (e) (Effective 12/1/07) (c) Protecting a Person Subject to a Subpoena. (d) Duties in Responding to a Subpoena. ( I ) Avoiding Undue Burden or Expense; Sanctions. A party or (1) Producing Documents or Electronically Stored Information. attorney responsible for issuing and serving a subpoena must take These procedures apply to producing documents or electronically reasonable steps to avoid imposing undue burden or expense on a stored information: person subject to the subpoena. The issuing court must enforce this (A) Documents. A person responding to a subpoena to produce duty and impose an appropriate sanction — which may include lost documents must produce them as they are kept in the ordinary earnings and reasonable attorney's fees — on a party or attorney course of business or must organize and label them to correspond to who fails to comply. the categories in the demand. (2) Command to Produce Materials or Permit Inspection. (B) Formfor Producing Electronically Stored Information Not (A) Appearance Not Required. A person commanded to produce Specified. If a subpoena does not specify a form for producing documents, electronically stored information, or tangible things. or electronically stored information, the person responding must to permit the inspection of premises, need not appear in person at the produce it in a form or forms in which it is ordinarily maintained or place of production or inspection unless also commanded to appear in a reasonably usable form or forms. for a deposition, hearing, or trial. (C) Electronically Stored Information Produced in Only One (B) Objections. A person commanded to produce documents or Form. The person responding need not produce the same tangible things or to permit inspection may serve on the party or electronically stored information in more than one form. attorney designated in the subpoena a written objection to (D) Inaccessible Electronically Stored Information. The person inspecting, copying. testing or sampling any or all of the materials or responding need not provide discovery of electronically stored to inspecting the premises — or to producing electronically stored information from sources that the person identifies as not reasonably information in the form or forms requested. The objection must be accessible because of undue burden or cost. On motion to compel served before the earlier of the time specified for compliance or 14 discovery or for a protective order, the person responding must show days after the subpoena is served. If an objection is made. the that the information is not reasonably accessible because of undue following rules apply: burden or cost. If that showing is made, the court may nonetheless (i) At any time, on notice to the commanded person. the serving order discovery from such sources if the requesting party shows party may move the issuing court for an order compelling production good cause, considering the limitations of Rule 26(b)(2)(C). The or inspection. court may specify conditions for the discovery. (ii) These acts may be required only as directed in the order, and (2) Claiming Privilege or Protection. the order must protect a person who is neither a party nor a party's (A) Information Withheld. A person withholding subpoenaed officer from significant expense resulting from compliance. information under a claim that it is privileged or subject to (3) Quashing or Modifying a Subpoena. protection as trial-preparation material must: (A) IVhen Required. On timely motion, the issuing court must (i) expressly make the claim: and quash or modify a subpoena that: (ii) describe the nature of the withheld documents, (i) fails to allow a reasonable time to comply: communications, or tangible things in a manner that, without (ii) requires a person who is neither a party nor a party's officer revealing information itself privileged or protected. will enable the to travel more than 100 miles from where that person resides, is parties to assess the claim. employed, or regularly transacts business in person — except that. (B) Information Produced. If information produced in response to a subject to Rule 45(c)(3)(B)(iii), the person may be commanded to subpoena is subject to a claim of privilege or of protection as trial- attend a trial by traveling from any such place within the state where preparation material, the person making the claim may notify any the trial is held; party that received the information of the claim and the basis for it. (iii) requires disclosure of privileged or other protected matter, if After being notified, a party must promptly return, sequester. or no exception or waiver applies; or destroy the specified information and any copies it has; must not use (iv) subjects a person to undue burden. or disclose the information until the claim is resolved: must take (B) When Permitted. To protect a person subject to or affected by reasonable steps to retrieve the information if the party disclosed it a subpoena, the issuing court may. on motion, quash or modify the before being notified: and may promptly present the information to subpoena if it requires: the court under seal for a determination of the claim. The person (i) disclosing a trade secret or other confidential research. who produced the information must preserve the information until development, or commercial information; the claim is resolved. (ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from (e) Contempt. The issuing court may hold in contempt a person the expert's study that was not requested by a party: or who, having been served, fails without adequate excuse to obey the (iii) a person who is neither a party nor a party's officer to incur subpoena. A nonparty's failure to obey must be excused if the substantial expense to travel more than 100 miles to attend trial. subpoena purports to require the nonparty to attend or produce at a (C) Specifying Conditions as an Alternative. In the circumstances place outside the limits of Rule 45(c)(3)(AXii). described in Rule 45(c)(3)(B), the court may. instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party: (i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship: and (ii) ensures that the subpoenaed person will be reasonably compensated. EFTA00750932
EFTA02437655.pdf
To: Jeffrey Epsteinheevacation©gmail.com] From: story cowles Sent Mon 9/28/2009 5:38:18 PM Subject: Wednesday deposition Do you want Jessica at our office again for the depo this Wednesday? Should I set it up the same? Story EFTA_R1_01510536 EFTA02437655
EFTA02438570.pdf
To: Jeffrey EpsteinUeevacationagmail.comj Fran: story cowles Sent Thur 10/15/2009 3:45:27 PM Subject Alan D deposition Jessica would like to know if you think Alan Deschowitz will be representing himself when he gets served? She just wants to know because she would like to unilaterally use that day to set one of the girls depos. Story EFTA_R1_01511819 EFTA02438570
EFTA02438413.pdf
To: Jeffrey Epsteinfleevacationagmail.comj From: story cowles Sent Thur 10/15/2009 2:58:56 PM Subject Depositions I just spoke to Jessica regarding and She told me that Brad's office has basically told Jessica that no matter when she sets their deposition dates they will file protective orders. Jessica may just set their dates but they will file protective orders. Jessica is also thinking about asking for dates to subpoena the girls family. There is a hearing on November 3rd to get an answer as to how much longer we can depose After the 3rd we will be able to set depo. tory EFTA_R1_01511594 EFTA02438413
EFTA00702628.pdf
From: "Martin G. Weinberg" <
To: "jeffrey E."
EFTA00750933.pdf
AO SSA (Rev. 01109) Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action UNITED STATES DISTRICT COURT for the Southern District of Florida JANE DOE Plaintiff V. Civil Action No. 08-90893CIV-MARRA/JOHNSO JEFFREY EPSTEIN (If the action is pending in another district, state where: Defendant SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION To: Mark Epstein, 301 E. 66th Street, New York, NY Testimony: YOU ARE COMMANDED to appear at the time, date, and place set forth below to testify at a deposition to be taken in this civil action. If you are an organization that is not a party in this case, you must designate one or more officers, directors, or managing agents, or designate other persons who consent to testify on your behalf about the following matters, or those set forth in an attachment: Place: Esquire Court Reporters, One Penn Plaza Date and Time: Suite 4715, New York, NY 09/21/2009 11:00 am The deposition will be recorded by this method: O Production: You, or your representatives, must also bring with you to the deposition the following documents, electronically stored information, or objects, and permit their inspection, copying, testing, or sampling of the material: The provisions of Fed. R. Civ. P. 45(c), relating to your protection as a person subject to a subpoena, and Rule 45 (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, are attached. Date: CLERK OF COURT OR Signature of Clerk or Deputy Clerk Attorney's signature The name, address, e-mail, and telephone number of the attorney representing (name ofparty) , who issues or requests this subpoena, are: Brad Edwards, Esq., Rothstein Rosenfeldt Adler, 401 E. Las Olas Blvd., Suite 1650, Fort Lauderdale, Florida 33301 Bedwards@rra-law.com. (954) 522 2346 EFTA00750933 AO 88A (Rev. 01/09) Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action (Page 2) Civil Action No. 08-90893CIV-MARRAIJ0HNS0 PROOF OF SERVICE (This section should not be filed with the court unless required by Fed. R. Civ. P. 45.) This subpoena for (name ofindividual and title, if any) was received by me on (date) O I personally served the subpoena on the individual at (place) on (date) ; or O I left the subpoena at the individual's residence or usual place of abode with (name) , a person of suitable age and discretion who resides there, on (date) , and mailed a copy to the individual's last known address; or O I served the subpoena on (name ofindividual) , who is designated by law to accept service of process on behalf of (name oforganization) on (date) ; or O I returned the subpoena unexecuted because ; or O Other (specify): Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness fees for one day's attendance, and the mileage allowed by law, in the amount of My fees are $ for travel and $ for services, for a total of $ 0.00 I declare under penalty of perjury that this information is true. Date: Server's signature Printed name and title Server's address Additional information regarding attempted service, etc: Print Save As... Attach Reset EFTA00750934 AO SSA (Rev. 01109) Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action (Page 3) Federal Rule of Civil Procedure 45 (c), (d), and (e) (Effective 12/1/07) (c) Protecting a Person Subject to a Subpoena. (d) Duties in Responding to a Subpoena. ( I ) Avoiding Undue Burden or Expense; Sanctions. A party or (1) Producing Documents or Electronically Stored Information. attorney responsible for issuing and serving a subpoena must take These procedures apply to producing documents or electronically reasonable steps to avoid imposing undue burden or expense on a stored information: person subject to the subpoena. The issuing court must enforce this (A) Documents. A person responding to a subpoena to produce duty and impose an appropriate sanction — which may include lost documents must produce them as they are kept in the ordinary earnings and reasonable attorney's fees — on a party or attorney course of business or must organize and label them to correspond to who fails to comply. the categories in the demand. (2) Command to Produce Materials or Permit Inspection. (B) Formfor Producing Electronically Stored Information Not (A) Appearance Not Required. A person commanded to produce Specified. If a subpoena does not specify a form for producing documents, electronically stored information, or tangible things. or electronically stored information, the person responding must to permit the inspection of premises, need not appear in person at the produce it in a form or forms in which it is ordinarily maintained or place of production or inspection unless also commanded to appear in a reasonably usable form or forms. for a deposition, hearing, or trial. (C) Electronically Stored Information Produced in Only One (B) Objections. A person commanded to produce documents or Form. The person responding need not produce the same tangible things or to permit inspection may serve on the party or electronically stored information in more than one form. attorney designated in the subpoena a written objection to (D) Inaccessible Electronically Stored Information. The person inspecting, copying. testing or sampling any or all of the materials or responding need not provide discovery of electronically stored to inspecting the premises — or to producing electronically stored information from sources that the person identifies as not reasonably information in the form or forms requested. The objection must be accessible because of undue burden or cost. On motion to compel served before the earlier of the time specified for compliance or 14 discovery or for a protective order, the person responding must show days after the subpoena is served. If an objection is made. the that the information is not reasonably accessible because of undue following rules apply: burden or cost. If that showing is made, the court may nonetheless (i) At any time, on notice to the commanded person. the serving order discovery from such sources if the requesting party shows party may move the issuing court for an order compelling production good cause, considering the limitations of Rule 26(b)(2)(C). The or inspection. court may specify conditions for the discovery. (ii) These acts may be required only as directed in the order, and (2) Claiming Privilege or Protection. the order must protect a person who is neither a party nor a party's (A) Information Withheld. A person withholding subpoenaed officer from significant expense resulting from compliance. information under a claim that it is privileged or subject to (3) Quashing or Modifying a Subpoena. protection as trial-preparation material must: (A) IVhen Required. On timely motion, the issuing court must (i) expressly make the claim: and quash or modify a subpoena that: (ii) describe the nature of the withheld documents, (i) fails to allow a reasonable time to comply: communications, or tangible things in a manner that, without (ii) requires a person who is neither a party nor a party's officer revealing information itself privileged or protected. will enable the to travel more than 100 miles from where that person resides, is parties to assess the claim. employed, or regularly transacts business in person — except that. (B) Information Produced. If information produced in response to a subject to Rule 45(c)(3)(B)(iii), the person may be commanded to subpoena is subject to a claim of privilege or of protection as trial- attend a trial by traveling from any such place within the state where preparation material, the person making the claim may notify any the trial is held; party that received the information of the claim and the basis for it. (iii) requires disclosure of privileged or other protected matter, if After being notified, a party must promptly return, sequester. or no exception or waiver applies; or destroy the specified information and any copies it has; must not use (iv) subjects a person to undue burden. or disclose the information until the claim is resolved: must take (B) When Permitted. To protect a person subject to or affected by reasonable steps to retrieve the information if the party disclosed it a subpoena, the issuing court may. on motion, quash or modify the before being notified: and may promptly present the information to subpoena if it requires: the court under seal for a determination of the claim. The person (i) disclosing a trade secret or other confidential research. who produced the information must preserve the information until development, or commercial information; the claim is resolved. (ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from (e) Contempt. The issuing court may hold in contempt a person the expert's study that was not requested by a party: or who, having been served, fails without adequate excuse to obey the (iii) a person who is neither a party nor a party's officer to incur subpoena. A nonparty's failure to obey must be excused if the substantial expense to travel more than 100 miles to attend trial. subpoena purports to require the nonparty to attend or produce at a (C) Specifying Conditions as an Alternative. In the circumstances place outside the limits of Rule 45(c)(3)(AXii). described in Rule 45(c)(3)(B), the court may. instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party: (i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship: and (ii) ensures that the subpoenaed person will be reasonably compensated. EFTA00750935
EFTA01154308.pdf
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. Plaintiff, vs. JEFFREY EPSTEIN, Defendant. NOTICE OF TAKING VIDEOTAPED DEPOSITION PLEASE TAKE NOTICE that the Plaintiff, , will take the deposition of on Thursday, September 3, 2009, at 10:00 a.m., at: Esquire Court Reporters One Penn Plaza Suite 4715 New York, NY 10119 The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure and shall continue day to day, weekends and holidays excepted, until completed. I HEREBY CERTIFY that a true and correct copy of the foregoing has been served by U.S. Mail and email transmission this jzgday of August, 2009 to all those on the attached Service List. 1 EFTA01154308 ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale, Florida 33301 Tel: (954) 522-3456 Fax: (954) 527-8663 Email: bedwards rra-law.com By: BRAD EDWARDS, ESQ. Florida Bar No.: 542075 cc: Esquire Court Reporters EFTA01154309
EFTA00634776.pdf
From: Martin Weinberg
To: Jeff Epstein
EFTA02043752.pdf
To: Bebe From: Lesley Groff Sent: Wed 9/7/2016 11:38:27 AM Subject: Re: jeffrey's deposition in FL on Friday... Thx Sent from my iPhone > On Sep 7, 2016, at 7:12 AM, Bebe > wrote: > Yes. I will email you as soon as I get in office :) > Sent from my iPhone >> On Sep 6, 2016, at 8:06 PM, > wrote: >> >> do you have the information on Jeffrey's deposition in FL this friday...where, when, etc? If not, can you get from Darren so I can put in Jeffrey's itinerary... >> :) Imola EFTA_R1_00573483 EFTA02043752
EFTA02427879.pdf
To: Jeffrey Epstein(jeevacation©gmail.comj From: story cowles Sent Mon 3/29/2010 2: PM Subject: Friday Deposition Would you like me to set up video feed at FSF for deposition this coming Friday at 9am? EFTA_R1_01497189 EFTA02427879
EFTA01819180.pdf
To: story cowlesill From: Jeffrey Epst Sent Mon 9/28/2009 5:52:10 PM Subject: Re: Wednesday deposition yes On Mon, Scp 28, 2009 at 1:38 PM, story cowles wrote: Do you wantiMpat our office again for the depo this Wednesday? Should I set it up t e same? Story *t*t*t*t*t*t*t*****t*t*t*t*t*t***t***t*t***t*t*t*t*t*t*t*t* The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Jeffrey Epstein Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to jecvacation®gmail.com and destroy this communication and all copies thereof, including all attachments. EFTA_R1_00191646 EFTA01819180
EFTA00480825.pdf
From: "Jeffrey E."
EFTA01154312.pdf
AO SSA (Rev. 01109) Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action UNITED STATES DISTRICT COURT for the Southern District of Florida Plaintiff V. Civil Action No. JEFFREY EPSTEIN (If the action is pending in another district, state where: Defendant SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION To: Jean Luc Bruhel, 301 E. 66th Street, New York, NY Testimony: YOU ARE COMMANDED to appear at the time, date, and place set forth below to testify at a deposition to be taken in this civil action. If you are an organization that is not a party in this case, you must designate one or more officers, directors, or managing agents, or designate other persons who consent to testify on your behalf about the following matters, or those set forth in an attachment: Place: Esquire Court Reporters, One Penn Plaza Date and Time: Suite 4715, New York, NY 09/22/2009 10:00 am The deposition will be recorded by this method: O Production: You, or your representatives, must also bring with you to the deposition the following documents, electronically stored information, or objects, and permit their inspection, copying, testing, or sampling of the material: The provisions of Fed. R. Civ. P. 45(c), relating to your protection as a person subject to a subpoena, and Rule 45 (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, are attached. Date: CLERK OF COURT OR Signature of Clerk or Deputy Clerk Attorney's signature The name, address, e-mail, and telephone number of the attorney representing (name ofparty) EFTA01154312 AO 88A (Rev. 01/)9) Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action (Page 2) Civil Action No. PROOF OF SERVICE (This section should not be filed with the court unless required by Fed. R. Civ. P. 45.) This subpoena for (name ofindividual and title, if any) was received by me on (date) O I personally served the subpoena on the individual at (place) on (date) ; or O I left the subpoena at the individual's residence or usual place of abode with (name) , a person of suitable age and discretion who resides there, on (date) , and mailed a copy to the individual's last known address; or O I served the subpoena on (name ofindividual) , who is designated by law to accept service of process on behalf of (name oforganization) on (date) ; or O I returned the subpoena unexecuted because ; or O Other (specify): Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also tendered to the witness fees for one day's attendance, and the mileage allowed by law, in the amount of My fees are $ for travel and $ for services, for a total of $ 0.00 I declare under penalty of perjury that this information is true. Date: Server's signature Printed name and title Server's address Additional information regarding attempted service, etc: Print Save As... Attach Reset EFTA01154313 AO SSA (Rev. 01109) Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action (Page 3) Federal Rule of Civil Procedure 45 (c), (d), and (e) (Effective 12/1/07) (c) Protecting a Person Subject to a Subpoena. (d) Duties in Responding to a Subpoena. ( I ) Avoiding Undue Burden or Expense; Sanctions. A party or (1) Producing Documents or Electronically Stored Information. attorney responsible for issuing and serving a subpoena must take These procedures apply to producing documents or electronically reasonable steps to avoid imposing undue burden or expense on a stored information: person subject to the subpoena. The issuing court must enforce this (A) Documents. A person responding to a subpoena to produce duty and impose an appropriate sanction — which may include lost documents must produce them as they are kept in the ordinary earnings and reasonable attorney's fees — on a party or attorney course of business or must organize and label them to correspond to who fails to comply. the categories in the demand. (2) Command to Produce Materials or Permit Inspection. (B) Formfor Producing Electronically Stored Information Not (A) Appearance Not Required. A person commanded to produce Specified. If a subpoena does not specify a form for producing documents, electronically stored information, or tangible things. or electronically stored information, the person responding must to permit the inspection of premises, need not appear in person at the produce it in a form or forms in which it is ordinarily maintained or place of production or inspection unless also commanded to appear in a reasonably usable form or forms. for a deposition, hearing, or trial. (C) Electronically Stored Information Produced in Only One (B) Objections. A person commanded to produce documents or Form. The person responding need not produce the same tangible things or to permit inspection may serve on the party or electronically stored information in more than one form. attorney designated in the subpoena a written objection to (D) Inaccessible Electronically Stored Information. The person inspecting, copying. testing or sampling any or all of the materials or responding need not provide discovery of electronically stored to inspecting the premises — or to producing electronically stored information from sources that the person identifies as not reasonably information in the form or forms requested. The objection must be accessible because of undue burden or cost. On motion to compel served before the earlier of the time specified for compliance or 14 discovery or for a protective order, the person responding must show days after the subpoena is served. If an objection is made. the that the information is not reasonably accessible because of undue following rules apply: burden or cost. If that showing is made, the court may nonetheless (i) At any time, on notice to the commanded person. the serving order discovery from such sources if the requesting party shows party may move the issuing court for an order compelling production good cause, considering the limitations of Rule 26(b)(2)(C). The or inspection. court may specify conditions for the discovery. (ii) These acts may be required only as directed in the order, and (2) Claiming Privilege or Protection. the order must protect a person who is neither a party nor a party's (A) Information Withheld. A person withholding subpoenaed officer from significant expense resulting from compliance. information under a claim that it is privileged or subject to (3) Quashing or Modifying a Subpoena. protection as trial-preparation material must: (A) IVhen Required. On timely motion, the issuing court must (i) expressly make the claim: and quash or modify a subpoena that: (ii) describe the nature of the withheld documents, (i) fails to allow a reasonable time to comply: communications, or tangible things in a manner that, without (ii) requires a person who is neither a party nor a party's officer revealing information itself privileged or protected. will enable the to travel more than 100 miles from where that person resides, is parties to assess the claim. employed, or regularly transacts business in person — except that. (B) Information Produced. If information produced in response to a subject to Rule 45(c)(3)(B)(iii), the person may be commanded to subpoena is subject to a claim of privilege or of protection as trial- attend a trial by traveling from any such place within the state where preparation material, the person making the claim may notify any the trial is held; party that received the information of the claim and the basis for it. (iii) requires disclosure of privileged or other protected matter, if After being notified, a party must promptly return, sequester. or no exception or waiver applies; or destroy the specified information and any copies it has; must not use (iv) subjects a person to undue burden. or disclose the information until the claim is resolved: must take (B) When Permitted. To protect a person subject to or affected by reasonable steps to retrieve the information if the party disclosed it a subpoena, the issuing court may. on motion, quash or modify the before being notified: and may promptly present the information to subpoena if it requires: the court under seal for a determination of the claim. The person (i) disclosing a trade secret or other confidential research. who produced the information must preserve the information until development, or commercial information; the claim is resolved. (ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from (e) Contempt. The issuing court may hold in contempt a person the expert's study that was not requested by a party: or who, having been served, fails without adequate excuse to obey the (iii) a person who is neither a party nor a party's officer to incur subpoena. A nonparty's failure to obey must be excused if the substantial expense to travel more than 100 miles to attend trial. subpoena purports to require the nonparty to attend or produce at a (C) Specifying Conditions as an Alternative. In the circumstances place outside the limits of Rule 45(c)(3)(AXii). described in Rule 45(c)(3)(B), the court may. instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party: (i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship: and (ii) ensures that the subpoenaed person will be reasonably compensated. EFTA01154314
EFTA02437076.pdf
To: Jeffrey Epsteinueevacation@gmailcom] From: Lesley Groff Sent Thur 9/17/2009 1:25:35 PM Subject: deposition On the deposition list today: Plaintiff: CMA Deponent: Igor Zinoviev 10am (SERVICE???) EFTA_R1_01509789 EFTA02437076
EFTA01826344.pdf
To: story cowles( From: Jeffrey Epstein Sent Mon 3/29/2010 5:01:23 PM Subject: Re: Friday Deposition (Wild) ok On Mon, Mar 29, 2010 at 11:52 AM, story cowles e > wrote: The weather has not allowed the electricians to start the work on the outdoor sconces today. I thought that if you arc at the FSF Friday watching the depo it would be a good day to reschedule them? --- On Mon, 3/29/10, Jeevacation teracation@gmaiLcom> wrote: From: Jeevacation leevacation©grnail.com> Subject: Re: Friday Deposition (Wild To: "story cowles" Date: Monday, March 29, 2010, 10:47 AM Yes Sent from my iPhone On Mar 29, 2010, at 10:44 AM, story cowles e > wrote: Would you like me to set up video feed at FSF for deposition this coming Friday at 9am? The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Jeffrey Epstein Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to jgg.acation@gmail.com, and destroy this communication and all copies thereof, including all attachments. EFTA_R1_00201118 EFTA01826344