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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: Mark Epstein, IIIIMPINOMMIIIIIM
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. Es Rothstein Rosenfeldt Adler, 401 E. Las Olas Blvd., Suite 1650, Fort Lauderdale, Florida 33301
EFTA00730327
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
EFTA00730328
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.
EFTA00730329
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From: Lesley Groff <1
To: "Harry Beller, I." -1
Subject: Fwd: JE Deposition Corrections
Date: Thu, 19 May 2011 15:13:48 +0000
Attachments: Epsteindepo.PDF; 1558172_1.DOC
Harry, please print both attachments for Darren (our printed is down over here so it must be printed on one of the
printers in your office. I would do it, but I am not set up to print over there) Darren would like as soon as
possible.
Please confirm receipt of this email and that you will print! thanks, Les
Begin forwarded message:
From: Darren Indyke <
Date: May 19, 2011 11:06:42 AM EDT
To: Lesley Groff <
Subject: Fwd: JE Deposition Corrections
Darren K. Indyke
Darren K. Indyke, PLLC
301 East 66th Street, 10B
New York, New York 10065
Telephone:
Direct:
Fax:
email:
*Mt*** ************************* ********************* ******** Irk ************************** ***it
The information contained in this communication is confidential, may be attorney-client
privileged, and is intended only for the use of the addressee. It is the property of
Darren K. Indyke, PLLC. 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, and destroy this
communication and all copies thereof, including all attachments.
Copyright of Darren K. Indyke, PLLC - © 2011 Darren K.
Indyke, PLLC —All rights reserved.
Begin forwarded message:
From: "Harry Susman" <
Date: May 18, 2011 1:06:07 PM EDT
To: "Bill Dunseth" < , "Darren Indyke" c >, "Harry
Susman" < , "Jeff Epstein" "Jill
McCrary" < , "Jonathan J. Ross"
EFTA00433642
>, "Seth Ard" < >, "Steve Susman"
>
Subject: JE Deposition Corrections
See the attached memo and a copy of your deposition.
EFTA00433643
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To: Jeffrey Epsteinrjeeyacationagmail.comj
From: story cowles
Sent Tue 2/16/2010 3:43:09 PM
Subject: deposition
Is there any reason we should be setting up the video feed for deposition
tomorrow at 10am?
You are being deposed at I lam at US Legal.
EFTA_R1_01500235
EFTA02430344
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To: psteinueevacationagmail.com]
From:
Sent: Sun 3/13/2011 12:50:32 AM
Lawyers drag prince into underage
sex scandal
The deposition of a model who worked for Jeffrey Epstein raises questions about the
prince's judgement
MichaelDillon, Kale Mansey and John Harlow
Published 13 March 2011
Recommend (0)
Comment (0)
Print
Follow News
efirey Epstein hired to work at his
mansion (Neil Rasmuss)
A former top model who worked for a paedophile friend of Prince Andrew has been questioned
under oath about whether the royal was involved with underage girls.
Legal documents obtained by The Sunday Times show that was asked if the Duke of
York was linked to the scandal surrounding his billionaire friend Jeffrey Epstein. is one of
four women who worked for the US financier who were named as "potential co-conspirators"
when Epstein was convicted of sex offences involving a minor. In a videotaped interview during
subsequent civil proceedings, lawyers asked M: "Has Prince Andrew ever been involved with
underage minor females to your knowledge?"
InvokhLthe US constitution's fifth amendment, which protects against self-incrimination, Polish-
born M, 27, replied: "I refuse to answer." She was also asked "Have you ever met Prince
Andrew?" and "Have you ever flown on [Epstein's] plane with Prince Andrew?" refused to
answer.
EFTA_R1_00220365
EFTA01838319
Flight logs show that Andrew was a passenger on Epstein's jet in May 2000. In interview it
was alleged that the former Elite agency model travelled on the aircraft more than so times. It
has been claimed that Epstein abused young girls on the jet.
There is no suggestion that Andrew had sexual contact with any of the girls or that he knew
Epstein abused them.
deposition will raise more questions about the prince's judgment after he met the
billionaire in New York in December following Epstein's release from prison.
Allegations have been made against Epstein by up to 4o girls, with at least 17 races settled out of
court. Epstein is said to have abused girls as young as 12. He secured pIotection
, for his associates
through a non-prosecution agreement. The federal document names as a possible co-
M
conspirator.
Lawyers acting for Epstein's victims in the civil courts are challenging the agreement and claim it
may lead to Andrew being asked to give evidence.
In an interview with Bradley Edwards, a lawyer who represents some of the victims, M said she
moved to Florida in 2002 after Elite obtained a visa for her to work in America. The model was
then hired to work in Epstein's Palm Beach mansion and organised his diary. She was at his side
in 2005 at a New York launch party for one of Epstein's magazines. name was found on
messages and notes seized by detectives from the Florida property.
During the interview, she refused to answer any questions about her involvement with Epstein.
The other "potential co-cons irators", who are thou ht to have helped to procure girls for
Epstein, are named as and Lesley Groff.
Epstein, 38, served 13 months in prison for soliciting a minor for prostitution and soliciting
prostitution. He will remain on the sex offenders' register for life.
His friend Ghislaine Maxwell, 49, the daughter of Robert Maxwell, the late media tycoon, was one
of Epstein's closest aides and is alleged in le al a rs to have hired underage girls for him,
joining in the sex games, which she denies. , one victim, told how she was kept as
Epstein's paid sex slave for four years from the age of 13.
She said Epstein introduced her to Andrew, who she says she met three times.
It emerged last week that Epstein paid f15,cioo to settle a debt for the Duchess of York. Royal
sources said Andrew was "unwise" to have remained in contact with Epstein but state he has now
severed ties.
Neither MI nor her lawyer responded to questions put by The Sunday Times.
EFTA_R1_00220366
EFTA01838320
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From: J
To:
Subject: Re: I was asked 10 years ago many times to write deposition against me
Date: Thu, 18 Oct 2018 06:07:37 +0000
Inline-Images: IMG_1303.jpg
Not me
On Wed, Oct 17, 2018 at 11:48 PM wrote:
EFTA01019384
please note
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
JEE
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 jeevacation@gmail.com, and
destroy this communication and all copies thereof,
including all attachments. copyright -all rights reserved
EFTA01019385
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To: Jeffrey Epsteinfleevacationagmail.comj
From: story cowles
Sent Tue 10/6/2009 2:47:36 PM
Subject Deposition scheduling
I spoke to Jessica and Kim (Bruce's assistant) regarding depositions. The overall deposition
schedule from each office will be sent directly to me each week so I may put it on the schedule
and update as necessary . In addition, each office will send me a list of scheduled depositions for
the following week (even if they think it will be rescheduled). Kim also notified me that Janusz
is scheduled for deposition tomorrow at 2pm. I will make sure to stay on top of the deposition
schedule from Bruce and Bob's office, make sure you are better informed as to what is scheduled
and make sure that each office knows the importance of informing us as to deposition schedule.
I am sorry for the inconvenience.
Story
EFTA_R1_01511127
EFTA02438092
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To: Jeffrey Epsteinueevacation©gmailcom]
From: Lesley Groff
Sent Wed 9/18/2009 2:38:59 PM
Subject: deposition
Reminder: 1:00 deposition, Jane Doe #4, by video today.
Reminder: tomorrow, Plaintiff: CMA, Deponent: Igor Zinoviev at 10am ...says (SERVICE???)
EFTA_R1_01509925
EFTA02437181
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AO SBA (Rev. 02/14) Subpoena to Testify at a Deposition in a Civil Action
UNITED STATES DISTRICT COURT
for the
Southern District ofNew York
Phis:tiff
v. Civil Action No. 15-cv-07433-RVVS
Ghlslaine Maxwell
Defendant
SUBPOENA TO TESTIFY AT A DEPOSITION IN A CIVIL. ACTION
To: LUCIANO FONTANILLA (a/k/a JO JO FONTANILLA)
18 Teneyck Ave., Valley Stream, NY 11580-4016
(Name °Jarman to whom this subpoena 4 directed)
gf
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, 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:
IPlace: Boles, chiller & Flexner LLP I Date and Time:
06/092016 9:00 am
i
The deposition will be recorded by this method: Stenographically and Videotaped
dProduction: You, or your representatives, must also bring with you to the deposition the following documents,
electronically stored information, or objects, and must permit inspection, copying, testing, or sampling of the
material: See Schedule A attached.
The following provisions of Fed. R. Civ. P. 45 are attached — Rule 45(c), relating to the place of compliance;
Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to
respond to this subpoena and the potential consequences ofnot doing so.
Date: 05/17/2016
CLERK OF COURT
OR
Signature ofClerk or Deputy Clerk Allem SS (WC
The name, address, e-mail address, and telephone number of the attorney representing (name of parry)
, who issues or requests this subpoena, are:
Sigrid S. McCawley, Boles, Schiller & Flexner LLP, 401 E. Las Olas Blvd., Suite 1200, FL Lauderdale, FL 33301; Tel:
(9") 356 0011;-^ cav-wv4-yebettir•-en.
Notice to the person who issues or requests this subpoena
If this subpoena commands the production of documents, electronically stored information, or tangible things before
trial, a notice and a copy of the subpoena must be served on each party in this case before it is served on the person to
whom it is directed. Fed. R. Civ. P. 45(a)(4).
EFTA01125871
AO 88A (Rev. 021:,l) Sunpoene to 'it'll& :: a Deposition in a Civil Action (I.•,ZC
Federal Rule of Civil Procedure 45 (c), (d), (c), and (g) (Effective 12/1/13)
(c) Place of Compliance. (I) disclosing a trade secret or other confidential research development,
or commercial information; or
(I) For a Trief. Dearing. or Deposition. A subpoena may command a (II) disclosing an unrciained expert's opinion or information that does
person to attend a trial, hearing, or deposition only as follows: not dcsaihe specific occurrences in dispute and results tom the expert's
(A) within 100 miles otwhere the person resides, is employed, or study that was not requested by a party.
regularly transacts business in person; or (C)Spectlying Conditions as an Alternative. In the circumstances
(B) within the state where the person resides, S employed, or regularly described in Rule 4S(d)(3XD), the court may, instead of quashing or
transact business in person, if the person modifying a subpoena, order appearance or production under specified
(pis o party or a party's officer, or conditions if the serving party:
(II) is commanded to attend a trial and would not incur substantial 0) shows a substantial need for the testimony or material that cannot be
expense. otherwise met without undue hardship; and
(II) ensures that the subpoenaed person will be reasonably compensated.
(2) For Other Discovery. A subpoena may command:
(A) production of dorAmoents, clonionitally stored information, or (e) Dudes In Responding to a Subpoena.
tangible things at a place within 100 miles of where the person resides, is
employed, or regularly transacts business in person; and (I) Producing Documenu or Electronically Stored Information. These
(B) inspection ofpremises at the premises to be inspected. procedures apply to producing documents or electronically stored
Information:
(d) Protecting a Person Subject to a Subpoena; Enforcement. (A) Dextintenu. A person responding to a subpoena to produce documents
must produce them Si they are kept in the ordinary course of business or
(1) Avoiding Undue Burden or Expense; Sanctions. A party or attorney must organize and label them to correspond to the categories in the demand.
responsible fa issuing and serving • subpoena must take reasonable steps (B) Formfor Producing Electronically StoredInformation Not Specified
to avoid imposing undue burden or expense on a person subject to the If a subpoena does no: specify a form for producing electronically stored
subpoena The court for the district wbere compliance is required must information, the person responding must produce it in a form or forms in
enforce this duty and impose an appropriate sanction—which may include which it is ordinarily maintained or in a reasonably usable form or fonns.
lost earnings and reasonable attorney's has--on a party or attorney who (C) Electronically StoredInformation Produced in Only One Font. lin
fails to comply. person responding need not produce the same electronically stored
information in mom than one form.
(2) Conunarul to Produce Materials or PermitInspection. (D) Inaccessible Electronically Stored Information. The person
(A) Appearance Not Required A person commended to produce responding need not provide discovery of electronically stored information
documents, electronically stored information, or tangible things, or to from sources that the person identifies as not reasonably accessible because
permit the inspection ofpremises, need not appear in person at the place of ofundue burden or cost. On motion to compel discovery or foe a protective
production or inspection unless also conunanded to appear for a deposition, order, the penal responding must show that the locomotion is not
hearing, or trial. reasonably accessible because ofundue burden or cost. If that showing Is
(B) Objections. A person commanded to produce documents or tangible made, the court may nonetheless order discovery from such sources if the
things or to permit inspection may save on the patty or attorney designated requesting puny shows good cause, considering the limitations of Rule
in the subpoena a written objection to inspecting, copying, testing. or 26(b)(2XC). The court may specify conditions for the discovery.
sampling any or all of the materials or to inspecting the premises—or to
producing electronically stored information in the form or forms requested. (2) Claiming Privilege or Protection.
The objection must be saved before the earlier of the time specified for (A)Infonnation Withhold A person withholding subpoenaed information
compliance or 14 days after the subpoena is served. lien objection is made, under a claim that it is privileged or subject to protection as Intl-preparation
the following rules apply: material must
(I)At any time, on notice to the commanded person, the serving party (I) expressly make the claim; and
may move the coup for the district where compliance is required for an (10 describe the nature of the withheld documents, communications, or
order compelling production or inspection. tangible things in a manner that, without revealing Information itself
01) These acts may be required only as directed in the order, and the privileged or protected, will enable the parties to assess the chair.
order must protect a Krum who is neither a party nor a party's officer fiom (B) Information Produced If information produced in response to a
significant expense resulting from compliance. subpoena is subject to a claim ofprivilege or ofprotection as
trial-preparation material, the person making the claim may nobly any party
(3) Quashing or Mothlying a Subpoena. that received the information of the claim and the basis for it. After being
notified, a party must promptly return, sequester, or destroy the specified
(A) When Required On timely motion, the coat for the district where information and any copies it has: must not use or disclose the information
compliance is required must quash or modify a subpoena that until the claim is resolved; must take reasonable steps to retrieve the
information if the party disclosed it before being notified: end may promptly
(I) fails to allow a reasonable time to comply: present the information under seal to the court for the district where
(II) requires a person to comply beyond the geographical limits compliance is required for a determination of the claim. The person who
specified in Rule 45(c); produced the information must preserve the information until the claim is
requires disclosure of privileged or other protected matter, if no resolved.
exception or waiver applies; or
(Iv) subject, a person to undue burden (g) Contempt.
(B) When Permitted To protect a person subject to a affected by a The court for the district where compliance is required—end also, after a
subpoena, the court for the district where compliance is required may, on motion is transferred. the issuing court—may hold in contempt a person
motion, quash or modify the subpoena if it inquires: who, having beat seised, fails without adequate excuse to obey the
subpoena or an order related to it
For access to subpoena materials, see Fed. R. Civ. P. 45(a) Commiuee Note (2013).
EFTA01125872
To:
EXHIBIT A
DEFINITIONS
Wherever they hereafter appear the following words and phrases have the following
meanings:
"Agent" shall mean any agent, employee, officer, director, attorney, independent
contractor or any other person acting, or purporting to act, at the discretion of or on behalf of
another.
2. "Correspondence" or "communication" shall mean all written or verbal
communications, by any and all methods, including without limitation, letters, memoranda,
and/or electronic mail, by which information, in whatever form, is stored, transmitted or
received; and, includes every manner or means of disclosure, transfer or exchange, and every
disclosure, transfer or exchange of information whether orally or by document or otherwise,
face-to-face, by telephone, telecopies, e-mail, text, modem transmission, computer generated
message, mail, personal delivery or otherwise.
3. "Document" shall mean all written and graphic matter, however produced or
reproduced, and each and every thing from which information can be processed, transcribed,
transmitted, restored, recorded, or memorialized in any way, by any means, regardless of
technology or form. It includes, without limitation, correspondence, memoranda, notes,
notations, diaries, papers, books, accounts, newspaper and magazine articles, advertisements,
photographs, videos, notebooks, ledgers, letters, telegrams, cables, telex messages, facsimiles,
contracts, offers, agreements, reports, objects, tangible things, work papers, transcripts, minutes,
reports and recordings of telephone or other conversations or communications, or of interviews
or conferences, or of other meetings, occurrences or transactions, affidavits, statements,
EFTA01125873
summaries, opinions, tests, experiments, analysis, evaluations, journals, balance sheets, income
statements, statistical records, desk calendars, appointment books, lists, tabulations, sound
recordings, data processing input or output, microfilms, checks, statements, receipts, summaries,
computer printouts, computer programs, text messages, c-mails, information kept in computer
hard drives, other computer drives of any kind, computer tape back-up, CD-ROM, other
computer disks of any kind, teletypes, telecopies, invoices, worksheets, printed matter of every
kind and description, graphic and oral records and representations of any kind, and electronic
"writings" and "recordings" as set forth in the Federal Rules of Evidence, including but not
limited to, originals or copies where originals are not available. Any document with any marks
such as initials, comments or notations of any kind of not deemed to be identical with one
without such marks and is produced as a separate document. Where there is any question about
whether a tangible item otherwise described in these requests falls within the definition of
"document" such tangible item shall be produced.
4. "Employee" includes a past or present officer, director, agent or servant, including
any attorney (associate or partner) or paralegal.
5. "Including" means including without limitations.
6. "Jeffrey Epstein" includes Jeffrey Epstein and any entities owned or controlled by
Jeffrey Epstein, any employee, agent, attorney, consultant, or representative of Jeffrey Epstein.
7. "You" or "Your" hereinafter means Luciano Fontanilla and any employee, agent,
attorney, consultant, related entities or other representative of Luciano Fontanilla.
2
EFTA01125874
INSTRUCTIONS
1. Production of documents and items requested herein shall be made at the offices
of Boles Schiller & Flexner, LLP,
no later than five (5) days before the date noticed for your deposition, or, if an alternate
date is agreed upon, no later than five (5) days before the agreed-upon date.
2. Unless indicated otherwise, the Relevant Period for this Request is from 1996 to
the present. A Document should be considered to be within the relevant time frame if it refers or
relates to communications, meetings or other events or documents that occurred or were created
within that time frame, regardless of the date of creation of the responsive Document.
3. This Request calls for the production of all responsive Documents in your
possession, custody or control without regard to the physical location of such documents.
4. If any Document requested was in your possession or control, but is no longer in
its possession or control, state what disposition was made of said Document, the reason for such
disposition, and the date of such disposition.
5. For the purposes of reading, interpreting, or construing the scope of these
requests, the terms used shall be given their most expansive and inclusive interpretation. Tbis
includes, without limitation the following:
a) Wherever appropriate herein, the singular form of a word shall be
interpreted as plural and vice versa.
b) "And" as well as "or" shall be construed either disjunctively or
conjunctively as necessary to bring within the scope hereof any
information (as defined herein) which might otherwise be construed to be
outside the scope of this discovery request.
c) "Any" shall be understood to include and encompass "all" and vice versa.
d) Wherever appropriate herein, the masculine form of a word shall be
interpreted as feminine and vice versa.
3
EFTA01125875
To
e) "Including" shall mean "including without limitation."
6. If you are unable to answer or respond fully to any document request, answer or
respond to the extent possible and specify the reasons for your inability to answer or respond in
full. If the recipient has no documents responsive to a particular Request, the recipient shall so
state.
7. Unless instructed otherwise, each Request shall be construed independently and
not by reference to any other Request for the purpose of limitation.
8. The words "relate," "relating," "relates," or any other derivative thereof, as used
herein includes concerning, referring to, responding to, relating to, pertaining to, connected with,
comprising, memorializing, evidencing, commenting on, regarding, discussing, showing,
describing, reflecting, analyzing or constituting.
9. "Identify" means, with respect to any "person," or any reference to the "identity"
of any "person," to provide the name, home address, telephone number, business name, business
address, business telephone number and a description of each such person's connection with the
events in question.
10. "Identify" means, with respect to any "document," or any reference to stating the
"identification" of any "document," provide the title and date of each such document, the name
and address of the party or parties responsible for the preparation of each such document, the
name and address of the party who requested or required the preparation and on whose behalf it
was prepared, the name and address of the recipient or recipients to each such document and the
present location of any and all copies of each such document, and the names and addresses of all
persons who have custody or control of each such document or copies thereof
4
EFTA01125876
11. In producing Documents, if the original of any Document cannot be located, a
copy shall be produced in lieu thereof, and shall be legible and bound or stapled in the same
manner as the original.
12. Any copy of a Document that is not identical shall be considered a separate
document.
13. If any requested Document cannot be produced in full, produce the Document to
the extent possible, specifying each reason for your inability to produce the remainder of the
Document stating whatever information, knowledge or belief which you have concerning the
portion not produced.
14. If any Document requested was at any one time in existence but are no longer in
existence, then so state, specifying for each Document (a) the type of document; (b) the types of
information contained thereon; (c) the date upon which it ceased to exist; (d) the circumstances
under which it ceased to exist; (e) the identity of all person having knowledge of the
circumstances under which it ceased to exist; and (1) the identity of all persons having
knowledge or who had knowledge of the contents thereof and each individual's address.
15. All Documents shall be produced in the same order as they are kept or maintained
by you in the ordinary course of business.
16. You are requested to produce all drafts and notes, whether typed, handwritten or
otherwise, made or prepared in connection with the requested Documents, whether or not used.
17. Documents attached to each other shall not be separated.
18. Documents shall be produced in such fashion as to identify the department,
branch or office in whose possession they were located and, where applicable, the natural person
in whose possession they were found, and business address of each Document's custodian(s).
5
EFTA01125877
To:
19. If any Document responsive to the request is withheld, in all or part, based upon
any claim of privilege or protection, whether based on statute or otherwise, state separately for
each Document, in addition to any other information requested: (a) the specific request which
calls for the production; (b) the nature of the privilege claimed; (c) its date; (d) the name and
address of each author; (e) the name and address of each of the addresses and/or individual to
whom the Document was distributed, if any; (0 the title (or position) of its author; (g) type of
tangible object, e.g., letter, memorandum, telegram, chart, report, recording, disk, etc.; (h) its title
and subject matter (without revealing the information as to which the privilege is claimed); (i)
with sufficient specificity to permit the Court to make full determination as to whether the claim
of privilege is valid, each and every fact or basis on which you claim such privilege; and (j)
whether the document contained an attachment and to the extent you are claiming a privilege as
to the attachment, a separate log entry addressing that privilege claim.
20. If any Document requested herein is withheld, in all or part, based on a claim that
such Document constitutes attorney work product, provide all of the information described in
Instruction No. 19 and also identify the litigation in connection with which the Document and the
information it contains was obtained and/or prepared.
21. Plaintiff does not seek and does not require the production of multiple copies of
identical Documents.
22. This Request is deemed to be continuing. If, after producing these Documents,
you obtain or become aware of any further information, Documents, things, or information
responsive to this Request, you are required to so state by supplementing your responses and
producing such additional Documents to Plaintiff.
6
EFTA01125878
DOCUMENTS TO BE PRODUCED PURSUANT TO THIS SUBPOENA
1. All documents related to Jeffrey Epstein.
2. All documents relating to Ghislaine Maxwell.
3. All documents relating to
4. All documents related tolla, a/k/a a/kla
5. All documents related t a/lc/a
6. All documents related to anyone giving massage to Jeffrey Epstein and Ghislaine
Maxwell.
7. All documents related to any massages that took place on Jeffrey Epstein's
residences.
7
EFTA01125879
TD BANK
AMERICAS mato' COtivonNT SANK
13344
t-1761260
EXECPROTECT INC 964
DBA ALPHA GROUP
5/17/2016
PAY TO THE
ORDER OF $ **69.16
Sixty-Nine and 16/100 DOLLARS a
S ka
MEMO
civil action# 15-cv-07433-RWS
ALITHORZED SCINAIIJRE
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EFTA01125880
DataSet-10
Unknown
1 pages
From: "Story Cowles"
To: "Jeffrey Epstein"
Date: Tue, 09 Feb 2010 15:16:28 +0000
Deposition has begun
Sent from Story's iPhone
EFTA00764724
DataSet-10
Unknown
8 pages
AO 88A (Rev. 06 09) Subpoena to Testify at a Deposition in a Civil Action
UNITED STATES DISTRICT COURT
for the
Southern District of New York
Jane Doe No. 2
Maimiff
v. Civil Action No. 08-CV-80119-Marra/Johnson
Jeffrey Epstein
(If the action is pending in another district, state where:
Defendant Southern District of Florida
SUBPOENA TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION
To: Richard Kahn,
ti 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: Veritext Corp Date and Time:
1250 Broadway, Suite 2400 04/20/2010 10:00 am
New York, New York 10001
The deposition will be recorded by this method: Court Reporter
1 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:
See document request attached as Schedule A.
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, arc
attached.
Date: 5
CLERK OF COURT
OR
Signature ofClerk or Deputy Clerk f I Attorney's signature
The name, address, e-mail, and telephone number of the attorney representing (name ofparty) Jane Doe No. 2
, who issues or requests this subpoena, are:
Stuart Mermelstein, Adam Horowitz Jessica Arbour. Mermelstein & Horowitz 18205 Bisc ane Blvd., Suite 2218,
Miami, FL, 33160
EFTA00730334
AO 88A (Rev. 06/09) Subpoena to Testify at a Deposition in a Civil Action (Page 2)
Civil Action No. 08-CV-80119-Marra/Johnson
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. It Civ. P. 45.)
This subpoena for (name ofindividual and tide. if any) Richard Kahn
was received by me on (dare)
O I served the subpoena by delivering a copy to the named individual as follows:
on (date) ; or
0 I returned the subpoena unexecuted because:
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
50.00
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 side
Server s address
Additional information regarding attempted service, etc:
EFTA00730335
AO SSA (Rev. O&09) Subpoena to Testify at a Deposition 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 StoredInformation 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 StoredInformation 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 (0) 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)(2XC). 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) When 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)(3XBXiii), 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.
(if) 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(cX3)(A)(ii).
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.
EFTA00730336
SCHEDULE A
DEFINITIONS
1. All documents produced pursuant hereto are to be produced as they are kept in the
usual course of business or shall be organized and labeled (without permanently marking the
item produced) so as to correspond with the categories of each numbered request hereof.
2. Each draft, final document, original, reproduction, and each signed and unsigned
document and every additional copy of such document where such copy contains any
commentary, note, notation or any change whatsoever that does not appear on the original or on
the copy of the one document produced shall be deemed and considered to constitute a separate
document.
3. As used herein, the singular shall always include the plural, and the present tense
shall always include the past tense.
4. All references to any Person (as defined below) includes his/her/its employees,
agents, servants, subsidiaries, parent company, affiliated company and any other person or entity
or Representative (as defined below) acting or purporting to act on behalf or under his/her/its
control.
5. "You", "Your" refers to the Person (as defined below) to whom this request is
addressed, including his/her/its employees, agents, servants, subsidiaries, parent company,
affiliated company, and other persons acting or purporting to act on your behalf, including your
representative.
6. "Person" means any natural individual in any capacity whatsoever or any entity or
organization, including divisions, departments, and other units herein, and shall include, but not
be limited to, public or private corporations, partnerships, joint ventures, voluntary or
unincorporated associations, organizations, proprietorships, trust, estates, governmental agencies,
EFTA00730337
commissions, bureaus, or departments, and the agents, servants and employees of same.
7. "Materials" shall mean all "Documents", "Writings", "Agreements", and
Communications" as those terms are defined herein.
8. As used herein, "and" as well as "or" shall be construed disjunctively and
conjunctively in order to bring within the scope of this request all responses which might
otherwise be construed to be outside its scope.
9. "Document" shall mean letters, correspondence, memoranda, notes, opinions,
work papers, charts, reports, ledgers, drawings, plans, specifications, schematics, blueprints,
block diagrams, contracts or photographs, and shall include but shall not be limited to, any
written, printed, typed or other graphic matter of any kind or nature, all mechanical, magnetic,
and electronic sound recordings or transcripts thereof; any microfilm, microfiche, or other
reproductions, and any data, information or statistics contained within any data storage modules,
tapes, discs or other memory devices or other information retrieval storage systems (including
computer-generated reports and printouts) in the possession and/or control of you and/or your
counsel or agents, or known by you to exist. It shall also mean all drafts and/or copies of
documents by whatever means made.
10. The terms "related", "relating", "reflecting" and "in relation to" shall mean
referring to, or having any relationship with whatsoever, or regarding or pertaining to, or
comprising, or indicating, or constituting evidence of, in whole or in part.
11. The term "communication" means any oral or written statement, dialogue,
colloquy, discussion, or conversation, and also means any transfer of thoughts or ideas between
persons by means of documents and includes any transfer of data from one location to another by
electronic or similar means.
12. The term "representative" means any and all agents, employees, servants, officers,
EFTA00730338
directors, attorneys, or other persons acting or purporting to act on behalf of the person in
question.
13. The term "control" means in your possession custody or control or under your
direction, and includes in the possession, custody or control of those under the direction of you
or your employees, subordinates, counsel, accountant, consultant, expert, parent or affiliated
corporation, and any person purporting to act on your behalf.
14. The term "ownership" shall mean any interest whether owned or possessed,
vested or contingent, partial or full, and whether title is held legally in your name, subsidiary, or
other related company and shall include any beneficial interest.
15. The term "statement" shall mean a written statement, signed or otherwise adopted
or approved by the person making it, or a stenographic, mechanical, electrical, or other
recording, or a transcription thereof, which is substantially a verbatim recital or an oral statement
by the person making it and contemporaneously recorded.
16. Privilege. If any document would be required to be produced in response to any
request except for the fact that a privilege against production is claimed, set forth for each
document:
a. its date, title of document (e.g., letter), and length;
b. its writer, preparer, sender, and addressee or copies;
c. a general description of its subject matter;
d. the exact grounds on which the objection to production is based;
e. the identity of all persons, in addition to those identified as required by section
(b), supra, known to you who have seen or had access to the document; and
f. identify the person now in possession of the document.
17. Documents no longer in existence or no longer under possession, custody or
EFTA00730339
control. If any document requested herein was at one time in existence and under your
possession, custody or control but has been lost, discarded or destroyed or has been removed
from your possession, custody or control, with respect to each such document:
a. identify and describe such document by date, title and type of document;
b. state when each such document was most recently in the possession or subject of
your control and what disposition was made of such document, including an
identification of the person, if any presently in possession or control of such
document;
c. state when such document was transferred or destroyed, identify the person who
transferred or destroyed such document and the persons who authorized or
directed that the document be transferred or destroyed or having knowledge of its
transfer or destruction and state the reason such document was transferred or
destroyed; and
d. identify all persons having knowledge of the contents thereof.
18. Unless otherwise specified, the time period of these requests is 2001-present.
EFTA00730340
REQUESTED DOCUMENTS
1. All documents referring or relating to any business or transaction involving
Jeffrey Epstein.
2. All documents referring or relating to contracts or agreements between or among
you and Jeffrey Epstein.
3. All documents referring or relating to transfers of property or interests in property
to or from Jeffrey Epstein.
4. All documents referring or relating to any ownership interest in property of
Jeffrey Epstein.
5. All documents referring or relating to any and all trusts, corporations, limited
partnerships, partnerships, limited liability companies and any other entities created or existing
pursuant to law, in which Jeffrey Epstein owns any stock, membership, share or beneficial
interest.
6. All financial statements or documents of Jeffrey Epstein for any period of time
from 2005 to present, including, without limitation, any and all balance sheets, credit
applications, income statements, cash flow statements, statements of changes in financial
position and statements of net worth.
7. All statements for any bank, brokerage or investment account in which Jeffrey
Epstein holds any ownership interest or beneficial interest.
8. All documents referring or relating to any investments of Jeffrey Epstein.
9. All documents referring or relating to any hedge fund owned or managed by
Jeffrey Epstein.
10. All documents referring or relating to any investment fund owned or managed by
Jeffrey Epstein.
EFTA00730341
DataSet-10
Unknown
1 pages
To: Jeffrey Epsteinfleeyacation©gmail.corn]
From: Story Cowles
Sent Tue 2/9/2010 3:16:28 PM
Deposition has begun
Sent from Story's iPhone
EFTA_R1_01501460
EFTA02431266
DataSet-10
Unknown
84 pages
AU itK A (Re. (Al es!,c ala Deposition in a Civil Action
UNITED STATES DISTRICT COURT
for the
Southern District of Florida
M.J.
P mg,
Civil Action No. CASE NO.: 9:10-cv-81111
JEFFREY EPSTEIN and WM
(If the action is pending in another district, state %%here:
Defendant
SUBPOENA TO TESTIFY AT A DEPOSITION IN A CIVIL
ACTION
To: JEFFREY EPSTEIN, 9 East 71st Street, New York, NY
10021
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 organi
zation that is not a party in this case, you must designate
one or more officers, directors, or managing agents, or design
ate other persons who consent to testify on your behalf
about the following matters, or those set forth in an attachment:
I—Plitce: US LEGAL SUPPORT
I_ 444 West Railroad Avenue, Suite 300 Date and Time:
West Palm Beach, FL 33401 11/10/2010 10:00 am
The deposition will be recorded by this method:
VIDEQDEPOSITION / COURT REPORTER
O Production: You, or your representatives, must also bring
with you to the deposition the following doctiments,
electronically stored information, or objects, and permit their
inspection, copying, testing, or stimpjjgg of the
material:
is
The provisions of Fed. R. Civ. P. 45(c), relating to your protec
tion 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: te." / 7:24 1
,
CLERK OF COURT
OR
Signature of Clerk or Deputy Clerk Amor s signature
The name, address, e-mail, and telephone number of the attorne
y representing (name ofparty) PLAINTIFF, M.J.
, who issues or requests this subpoena, are:
BRADLEY J. EDWARD W ' g, Edwards, Fistos & Lehrman, 425 N. Andrews Avenue,
Lauderdale, FL 33301, Suite 2. Fort
telephone: 954-524-2820.
EFTA00729603
AO BSA (Rev. 06/09) Subpoena to ic.t .11 .i /cro.nion in a Ci‘i! An
Civil Action No. CASE NO.. 9.10-cv-81111
PROOF OF SERVICE
(This section should not befiled with the court unless required by Fed. R. Civ. P. 45.)
This subpoena for (name ofindividual and title. Vat& JEFFREY EPSTEIN
was received by me on (date)
O I served the subpoena by delivering a copy to the named individual as follows:
on (date) ; or
0 I returned the subpoena unexecuted because:
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
Primed name and tide
Server's address
Additional information regarding attempted service, etc:
EFTA00729604
Intentionally Left Blank
EFTA00729605
Case 9:10-cv-81111-WPD Document 3 Entered on FLSD Docket 09/17/2010 Page 1 of 2
AO 4411 (Rev I 2.(9) Summons m a
Civil Aclion
UNITED STATES DISTRICT COURT
for the
Southern District of Florida
M.J.
Plaintiff
v. Civil Action No.
JEFFREY EPSTEIN and
10-CV-81111-DIMITROULEAS/SNOW
Defendant
SUMMONS IN A CIVIL ACTION
To: (Defendant's name andaddress) JEFFREY EPSTE
IN
9 East 71st Street
New York, NY 10021
A lawsuit has been filed against you.
Within 21 days after service of this summons on you
(not counting the day you received it) — or 60 days if you
arc the United States or a United States agency, or an
officer or employee of the United States described in Fed.
P. 12 (a)(2) or (3)— you must serve on the plaintiff R. Civ.
an answer to the attached complaint or a motion under Rule
the Federal Rules of Civil Procedure. The answer or 12 of
motion must be served on the plaintiff or plaintiff's attorne
whose name and address arc: BRADLEY y,
J. EDWARDS
Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman
425 N. Andrews Avenue, Suite 2
Fort Lauderdale, FL 33301
If you fail to respond, judgment by default will be entere
d against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
SUMMONS
Date: SEPTEMBER 177 2010
s/Gregory Maestre
Steven M. Larimore Deputy Clerk
U.S. District Courts
Clerk of Court
EFTA00729606
Intentionally Left Blank
EFTA00729607
Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 1 of 29
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.:
Plaintiff,
vs.
JEFFREY EPSTEIN and
Defendants.
COMPLAINT
Plaintiff, M.J., by and through her undersigned counsel, sues the Defendants, Jeffrey
Epstein and and alleges:
I. This is an action in an amount in excess of $15,000.00, exclusive of interest and costs and
is within the jurisdictional limits of this Court.
2. This Complaint is brought under a fictitious name in order to protect the identity of the
Plaintiff because this Complaint makes allegations of sensitive nature of offenses against a then
minor child.
3. At all times material to this cause of action, the Plaintiff, M.J. (hereinafter referred to as
"Plaintiff"), was a resident of Palm Beach County, Florida.
4. At all times material to this cause of action, Defendant, Jeffrey Epstein, had a residence
located at 358 El Brillo Way, West Palm Beach, Palm Beach County, Florida.
5. Defendant, Jeffrey Epstein, is currently a citizen of the United States Virgin Islands.
EFTA00729608
Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 2 of 29
6. At all times material to this cause of action, Defendant, Jeffrey Epstein, was an adult
male born in 1953.
7. Defendant,a , is currently a citizen of New York, where she currently resides.
8. At all times material, the Defendants Jeffrey Epstein andI. ME both owed a duty
unto Plaintiff to treat her in a non-negligent manner and to not commit or conspire to commit
intentional or tortious illegal acts against her.
FACTUAL ALLEGATIONS
9. At all times material, Defendant, Jeffrey Epstein, was an adult male, over 50 years old.
Defendant Epstein is known as a billionaire, yet even those closest to him, including family
members, long time employees and those that he considers his closest friends have no idea what
he does or did to earn money to support his lifestyle.
10. Defendant Epstein owns, directly or through nominee individuals used to conceal his
interests, a fleet of airplanes, motor vehicles, boats and a helicopter. He owns numerous
properties and homes, including a 51,000-square-foot mansion in Manhattan, a $30 Million
7,500-acre ranch in New Mexico, a 70-acre private island formerly known as Little St. James in
St. Thomas, U.S. Virgin Islands (he is alleged to have renamed this island Little St. Jeff's after
himself), a mansion in London, England, a home in Paris, France, and a mansion in Palm Beach
County, FL. The allegations herein primarily concern the defendant's conduct while at his
mansion in Palm Beach County, FL.
I. Defendant Epstein has a sexual preference and obsession for underage minor females,
specifically targeting female children age 12 to 17, and Defendant Epstein acts on that obsession
by luring underage minor females to him where he attempts to sexually molest and batter these
2
EFTA00729609
Case 9:10-cv-81111-XXXX Document 1 Entered on FLSD Docket 09/17/2010 Page 3 of 29
underage minor females on an everyday basis, oftentimes 2 or 3 different underage minor
females on one day.
12. Sometime prior to 1998, Defendant Epstein devised a complex plan, scheme and criminal
enterprise to gain access to countless underage minor females, some as young as 12 years old, for
the purpose of coercing the minor females into various acts of sexual misconduct that he
committed upon them. His enterprise operated with a definite hierarchal structure with his
various employees/assistants and associates, including Defendana, Jean Luc Brunel,
Ghislaine Maxwell, IS In; Ma a a a, various housekeepers,
butlers and pilots, performing their respective roles to ensure the goals of the enterprise: operate
an organized and efficient system to maximize the number of underage minor females for
Defendant Epstein (and others) to sexually abuse and exploit while avoiding law enforcement
detection.
13. Defendant Epstein, with help from his assistants and associates, recruited and procured
underage minor females, lured them to one of his mansions, had the underage minor female
taken to a room to be alone with him, then he would appear naked or wearing only a towel and
sexually batter or otherwise sexually exploit the underage minor female. He would then pay the
underage minor female for the sex acts he committed against her (typically between $200 and
$300 per molestation session, or as his criminal enterprise commonly refers to it — per
"massage"). Prior to leaving, Defendant Epstein's assistant would get the phone number of the
underage minor female and input it into his computer system or otherwise keep it on file. He
would then offer the underage minor female to return to his house to make money in exchange
for him committing sexual acts against her, and he also typically informed her of another option -
make more money recruiting and procuring other underage minor females for him to sexually
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abuse. He would tell the underage minor female that he will pay her for each underage minor
female that she brings to him (again, typically between $200 and $300), and he encouraged, and
oftentimes forcefully demanded, her to bring him as many underage minor females as she was
able. Through this general pitch, Defendant Epstein created a vast pyramid of underage minor
females recruiting and procuring other underage minor females for his purpose of coercing these
underage females into sexual acts for money.
14. Defendants Epstein and and the criminal enterprise specifically targeted
underprivileged and economically disadvantaged children to sexually exploit and molest and
otherwise prey upon the vulnerabilities of these young girls.
15. It is unknown exactly how long Defendant Epstein's aforementioned criminal enterprise
operated, although information and belief indicates that it was continuously and actively in
operation from at least 1998 through Defendant Epstein's criminal arrest in 2006.
16. The complete list of underage minor females that were sexually abused by Defendant
Epstein over the years is believed to have been kept on a computer system controlled by
Defendant Epstein and accessible by several of his employees, including Defendant
It is also known that much of the data regarding the names, addresses and whereabouts
of each underage minor female was input by one of his assistants, including Defendant
17. Defendant was listed in the Federal Non-prosecution Agreement related to
Defendant Epstein's criminal plea on sex charges against minors as a criminal co-conspirator for
her role in the criminal activity that was committed by Defendant Epstein against many underage
minor females. She was employed by Defendant Epstein to maintain his schedule, arrange for
underage minor females to be with Defendant Epstein, maintain contact with the underage minor
females, schedule the underage minor females' transportation to and from Defendant Epstein's
4
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mansion, and greet the underage minor female at the house before taking her upstairs to be alone
with Mr. Epstein. Upon information and belief, Defendant remains employed by
Defendant Epstein and continues to work for Defendant Epstein in furtherance of the goals
of the
criminal enterprise.
18. Defendant Epstein used his vast wealth and power to lure underprivileged minor females
to him, and to coerce them into prostitution once he was alone with the underage minor female.
He sexually battered, molested, committed lewd and lascivious acts upon and otherwise
exploited numerous underage minor females and then gave them money. So long as the
underage minor female followed his demands and advances, he assumed the role of a friend or
mentor or father figure to the minor female in an attempt to groom the minor female; however, if
any minor female resisted his sexual advances, Defendant Epstein became frustrated, angry and
threatening towards the underage minor. His intent was to groom each minor female into
engaging in sexual acts with him as well as to "work" for him, i.e. bring him other underage
minor females to sexually molest, batter and exploit. He was masterful in his exploitation and
grooming of these minor females with an additional intent of gaining trust and cooperation from
these minors to prevent any one of them from reporting his criminal acts to law enforcement.
Certain of his many co-conspirator associates, including Ghislane Maxwell and Jean Luc Brunel,
helped in this recruiting process by creating the impression that legitimate modeling
opportunities were available for the minor females.
19. Through information and belief, Defendant Epstein has been successful in luring
hundreds of underage minor girls to him for the purpose of him (and sometimes others) sexually
abusing them. He intentionally preys upon underage minor females that are middle school or
high school children who are not working prostitutes, and he takes pleasure in using his power
5
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and influence to coerce these minor females into acts of prostitution with him personally and
sometimes with his friends and associates as well, including but not limited to Ghislaine
Maxwell and
20. Over time, Defendant Epstein fine-tuned his operation to further his goals of gaining
access to a greater number and variety of underage girls while avoiding detection by law
enforcement. He also provided the roadmap for his enterprise should the illegal sexual
exploitation of the enterprise be detected — he or the criminal enterprise would (and did) retain
legal representation for each criminal enterprise member who would instruct each member to
invoke his/her 5th amendment rights, they would hide behind the 5th amendment to avoid turning
over incriminating materials (i.e. computer system that logged information about the underage
sexual molestation victims, scheduling books, message pads, and tangible items such as vibrators
and dildos), they would destroy evidence and refuse all cooperation with law enforcement.
21. The plan and scheme was developed by Defendant Epstein, and he and his assistants and
associates carried it out with each underage minor female in a well-planned and ritualistic
manner; Epstein ran this criminal enterprise as an experienced Mob boss would run any
organized crime family — in a well-planned, organized, arrogant and ruthless manner, with
complete cooperation from his co-conspirator associates and underlings and an absolute
dedication to carrying out the illegal operations of the criminal enterprise.
22. Defendant Epstein frequently traveled between his various mansions and either he or an
authorized agent would call to inform a recruiter, assistant, or scheduler at his next destination as
to his arrival time. His scheduler, usually Defendant la, would then contact an
underage minor female and schedule her to be at Defendant Epstein's mansion or to bring
another underage minor female to his mansion at a particular time. Once the minor female was
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of 29
brought to Defendant Epstein's residence, she was greeted at the door of the mansion and lead
inside by one of Defendant Epstein's employees, oftentimes Defendant
23. Defendant would lead the underage minor female up to Defendant Epstein's
room and leave the underage minor alone in the room. Defendant, Jeffrey Epstein, himself would
then appear naked or wearing only a towel. He would then demand a massage and during the
massage he would attempt, usually successfully, to perform one or more lewd, lascivious, and
sexual acts, including, but not limited to, masturbation, touching of the underage minor female's
sexual organs, coercing or forcing the underage minor female to perform sex acts with him,
using vibrators or sexual toys on the underage minor female, coercing the underage minor female
into sexual intercourse with himself or others, and digitally penetrating the underage minor
female. He would then give the Plaintiff money for engaging in this sexual activity.
24. Consistent with Defendants Epstein and foregoing scheme or plan, in or around
the summer of 2002, Plaintiff, an economically poor and vulnerable child, was told by another
one of Epstein's underage minor sex abuse victims, that she could make $300 cash by giving an
old man a massage on Palm Beach.
25. Plaintiff's then minor acquaintance (also a sexual abuse victim of Epstein) telephoned
Defendant Epstein and scheduled for Plaintiff to go to Defendant Epstein's house to give him a
massage. During that call, Defendant Epstein himself got on the phone and spoke with Plaintiff
MJ and asked her personally to come to his mansion in Palm Beach.
26. Plaintiff then took a taxicab to Defendant Epstein's mansion and was greeted by
Epstein's top assistant, Defendant
27. Defendant in furtherance of the scheme to exploit Plaintiff, escorted Plaintiff
upstairs to Defendant Jeffrey Epstein's large bathroom, where Defendant set up the
7
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massage table and showed Plaintiff different massage lotions to use. Defendant Illlithen left
Plaintiff alone in the room. Plaintiff was alone in Defendant Epstein's bathroom until Defendant
Jeffrey Epstein emerged wearing only a towel.
28. Defendant Epstein then walked to the massage table that was already open in the room.
He lied face down on the table and told Plaintiff to start massaging him, at which time he
engaged in a conversation with Plaintiff. During the conversation, Defendant Epstein asked
Plaintiff her age and she told him she had recently turned 16.
29. Consistent with all of Defendant Epstein's known underage minor female victims,
Plaintiff had no massage experience whatsoever and she informed him of that, and Defendant
Epstein began instructing Plaintiff on how he liked his massage.
30. After approximately 15 minutes, Defendant Epstein turned over onto his back, and he
commanded Plaintiff to massage his chest.
31. Defendant Epstein then suddenly removed his towel and his penis was already erect. He
then commanded Plaintiff to remove her shirt and bra and to begin "pinching his nipples" as he
began masturbating with his right hand.
32. As he was masturbating, Defendant Epstein began fondling Plaintiff's breasts.
33. Defendant Jeffrey Epstein, while masturbating with his right hand, reached out his left
hand and grabbed Plaintiff's vagina and butt over her clothes. Plaintiff pushed Defendant's hand
away and told him repeatedly not to touch her like that. Epstein was persistent in his attempt to
grab Plaintiff's vagina and continued to grab her vagina and butt on multiple occasions after she
told him not to.
34. Defendant Epstein continued to masturbate his exposed penis until he ejaculated in front
of the then minor Plaintiff.
8
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35. Plaintiff was shocked and embarrassed by the events and Defendant Epstein talked to her
to persuade her that everything he was doing with he was normal.
36. Epstein paid Plaintiff $300 for allowing him to grope her and masturbate in her presence.
37. Plaintiff returned to Epstein's home on approximately 20 occasions. On each occasion
Epstein grabbed Plaintiff's bare breasts, exposed his penis, masturbated and ejaculated in
Plaintiff's presence, and paid her $300 each time.
38. Defendant Epstein coerced Plaintiff into acts of prostitution, preying on her low
economic status and troubled upbringing, complimenting Plaintiff for being "special" to him and
having a "very pretty body" and making promises to Plaintiff such as — he told Plaintiff that if
she graduated high school, then he would buy her a computer, something that she wanted yet
could not afford.
39. On multiple occasions Defendant Epstein pressured Plaintiff to bring him other underage
minor females to abuse; he told Plaintiff that he would pay her $300 for each girl she brought
him, but Plaintiff refused to bring other girls.
40. Defendant Epstein told Plaintiff that he would pay her more money if she would give him
oral sex and that he would pay her $600 for actual sexual intercourse. Plaintiff refused.
41. Defendant Epstein personally called Plaintiff at least five times to tell her when she
should be at his house to "work" or give him a "massage" (Epstein's criminal enterprise's
learned code words for paying minors for Epstein and others to interact with them sexually).
42. Every other time (approximately 15) Defendant called to inform Plaintiff of the
date and time when she needed and was expected to be at Epstein's mansion to "work".
43. The acts referenced above, committed by Defendant, Jeffrey Epstein, against the then
minor Plaintiff were committed in violation of numerous State and Federal criminal statutes
9
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condemning battery, assault and the exploitation of minor children, contributing to the
delinquency of a minor and other crimes, specifically including, but not limited to, those criminal
offenses outlined in Chapters 796, 800, and 827 of the Florida Statutes, as well as those
designated in Florida Statutes §796.03, §796.07, §796.045, §796.04, §796.09, §39.01, §450.151,
and §827.04.
44. The above-described acts took place in Palm Beach County, Florida at the residence of
the Defendant, Jeffrey Epstein. Any assertions by Defendants, Jeffrey Epstein and
that they were unaware of the age of the then minor Plaintiff are belied by their actions and
rendered irrelevant by the provisions of applicable Florida Statutes concerning the sexual
exploitation and abuse of a minor child. The Defendants, Jeffrey Epstein and at all
times material to this cause of action, knew and should have known of the Plaintiffs minority as
Plaintiff specifically told Epstein her age and Defendant Epstein and criminal organization has a
history of seeking out underage minor children to sexually abuse. In fact, one primary goal of
the organization is to sexually abuse females who are under the age of 18, and oftentimes
Defendant Epstein has turned away females (i.e. refused to engage in sexual acts with them) for
being "too old" once she reaches 18 years of age, and he has reprimanded girls for bringing him
other girls who are over the age of majority.
45. In June 2008, in the Fifteenth Judicial Circuit in Palm Beach County, Florida, Defendant
Epstein entered pleas of "guilty" to various Florida State crimes related to his exploitation of
minors for sex.
46. As a condition of that plea and in exchange for the Federal Government entering into a
Non-Prosecution Agreement with Defendant Epstein, wherein the Federal Government agreed to
effectively stay any prosecution of Jeffrey Epstein, and other criminal co-
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of 29
conspirators a =Mt and Defendant Epstein agreed to admit that
a
approximately 40 underage minor females, whose names were provided to Defendant Epstein,
were his victims. Plaintiff was not included in that list as she moved away from the West Palm
Beach area in part to escape from Epstein, and she has lived in fear of Epstein and his
organization and has not yet been contacted by law enforcement.
47. Beginning in or about June 2008 and continuing to the present time, defendant Epstein
has been aware he faces significant financial liability for his sexual offenses, both to land to
many other similarly-situated girls whom he abused. I and these other girls are creditors of
Epstein, in that have filed and can file ton actions against him under both Florida and Federal
laws. Accordingly, Epstein has conveyed substantial assets and property into the names of other
persons and into overseas bank accounts and other financial institutions. These assets and
properties could have been attachable and used to pay the debts owed to ■and to the other girls
that Epstein has abused.
48. As an example of the fraudulent conveyances that Epstein has attempted, in
approximately October 2009, Epstein placed his personal 727 aircraft up for sale, with the intent
that the proceeds of that sale would be hidden so that Nand other creditors of Epstein would
not be able to secure payment from that substantial asset.
49. While Epstein is clearly distinct from the criminal enterprise that he oversees that asset,
as well as his other airplanes and helicopters and other assets, have been used continuously and
repeatedly to further the interest and endeavors of Epstein and his criminal enterprise.
50. As another example of the fraudulent transfers that Epstein has made, Epstein has titled a
Ford F-I50 Truck in the name of Larry Visoki (Epstein's personal pilot). Visoski was unaware
that the truck was titled in his name when he was questioned under oath in a deposition.
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51. In approximately 2009, Defendant Epstein purchased a $68,000 Land Rover and
registered it in Visoski's name with the intent to hide this asset fromUnd other creditors.
52. In approximately 2009, Defendant Epstein purchased a Mercedes-Benz 2005 by wiring
funds to Visoski and then placing the car in Visoski's name.
53. In approximately 2009, Defendant Epstein bought a Jaguar X-Type 2005 so that he
(Epstein) would have another car around Palm Beach available for his friends to use and then
placed the car in Visoski's name.
54. In approximately September 2009, Visoski attempted to sell a Ferrari owned by Epstein
for $159,000. Epstein intended for the sale to hide the value of this Ferrari and prevents and
other creditors from recovering from him.
55. Epstein is concealing substantial assets through a new corporation, Shmitka Air, Inc.,
whose representative is Larry Visoski. In September 2010, Epstein attempted to sell a 1999 Bell
Helicopter for approximately $1,900,000. This sale was an attempt to prevent sand other
creditors from recovering from him.
56. Epstein is also concealing substantial assets through an entity known at JEGE, Inc. He is
currently attempting to sell an aircraft for $10,000,000 through that entity in an attempt to
prevent Nand other creditors from recovering from him.
57. Through information and belief, Epstein and/or his criminal enterprise provides the
financial support for his various employees, co-conspirators, other criminal enterprise members
and associates.
58. In addition to Epstein's various houses, he owns or controls other condominiums,
including approximately 8 to 10 units at in New York City, where certain of
his or his Criminal Enterprise associates live or reside, including Jean Luc Brunel,
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ME'S= and at times various underage minor girls are stashed at this location
as well.
59. Defendant Epstein has numerous overseas contacts and accounts and sophistication in
international business transactions. He previously served as a trader at Bear Steams and founded
his own financial management firm. J. Epstein and Col. (later called Financial Trust Co.) located
on his private island in the U.S. Virgin Islands where, until his recent incarceration, according to
him he allegedly managed the assets of billionaire clients.
60. After extensive investigation into Epstein's employment history, including questioning of
Epstein's family, those whom Epstein considers friends and longtime employees of Epstein, the
only known client of Epstein was Limited, Inc. Founder Leslie Wexner, although it is believed
that even that relationship has been severed. No other legitimate means of income have been
reported.
COUNT I
BATTERY AGAINST DEFENDANT EPSTEIN
61. Plaintiff M.J. adopts and realleges paragraphs I through 60 above.
62. In the summer of 2002, just after Plaintiff turned 16 years old, Defendant Epstein
committed battery against Plaintiff when he intentionally touched intimate areas of her body and
person in an offensive manner while she was a minor child.
63. Defendant Epstein intentionally touched Plaintiff private areas multiple times
against the will of
64. Defendant Epstein's tortious commission of battery upon Plaintiff was done willfully.
65. As a direct and proximate result of the offenses committed by Defendant Epstein against
the then minor Plaintiff,■ she has in the past suffered and will in the future suffer injury, pain
13
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and suffering, emotional distress, psychological and psychiatric trauma, mental anguish,
humiliation, confusion, embarrassment, loss of self-esteem, loss of dignity, loss of enjoyment of
life, invasion of her privacy and other damages associated with Defendant's manipulation and
leading her into a perverse and unhealthy way of life. Plaintiff will incur medical and
psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn
income in the future, and loss of proper and complete education. These injuries are permanent in
nature and Plaintiff will continue to suffer these losses in the future.
WHEREFORE, Plaintiff demands judgment against Defendant Epstein for
compensatory damages, punitive damages and such other relief as this Court deems proper and
hereby demands trial by jury on all issues triable as of right by a jury.
COUNT II
INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
AGAINST DEFENDANT EPSTEIN
66. The Plaintiff adopts and realleges paragraphs I through 60 above.
67. Defendant Epstein's extreme and outrageous conduct towards the then minor Plaintiff
was intentional and reckless.
68. Defendant Epstein acted with the intent to cause severe emotional distress or with
reckless disregard for the high probability of causing severe emotional distress.
69. As a direct and proximate result of the offenses committed by Defendant Epstein against
the then minor Plaintiff, ■she has in the past suffered and will in the future suffer injury, pain
and suffering, emotional distress, psychological and psychiatric trauma, mental anguish,
humiliation, confusion, embarrassment, loss of self-esteem, loss of dignity, loss of enjoyment of
life, invasion of her privacy and other damages associated with Defendant's manipulation and
leading her into a perverse and unhealthy way of life. Plaintiff will incur medical and
14
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psychological expenses. Plaintiff has suffered a loss of income, a loss of the capacity to earn
income in the future, loss of proper and complete education. These injuries are permanent in
nature and Plaintiff MJ will continue to suffer these losses in the future.
WHEREFORE, Plaintiff ■ demands judgment against Defendant Epstein for
compensatory damages, punitive damages and such other relief as this Court deems proper and
hereby demands trial by jury on all issues triable as of right by a jury.
COUNT HI
C NSPIRACY TO COMMIT T In BATTERY AGAINST
DEFENDANT
70. The Plaintiff adopts and realleges paragraphs I through 60 above.
71. Defendant = is one of Defendant Epstein's top assistants, as referenced previously
in this Complaint. Defendant Epstein, Defendant = and others reached an agreement
amongst and between them and otherwise conspired for the purpose of allowing Defendant
Epstein and others to commit the tortious and illegal acts described above against Plaintiff.
72. Defendant aided, abetted and assisted Defendant Epstein in his organized scheme
and plan to sexually exploit Plaintiff and commit battery against her and/or commit or attempt to
commit numerous other crimes against her, including coercing her into prostitution.
73. Defendant conspired with Defendant Epstein to commit tortious and illegal
conduct against Plaintiff, and in furtherance of the conspiracy specifically engaged in
overt acts such as contacting Plaintiffs on many occasions, scheduling the then minor
Plaintiff's appointment for a "massage" knowing that Defendant Epstein was going to commit
battery against Plaintiff, attempt sexual battery against Plaintiff, and force her into prostitution
and otherwise did everything in her ability to conceal the illegal operation and refuse cooperation
with law enforcement.
15
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74. Additionally, Defendant greeted Plaintiff on the occasions when Plaintiff arrived
at Epstein's home and personally lead Plaintiff to Defendant Epstein's bathroom where Epstein
appeared for the purposes of committing crimes against Plaintiff
75. Defendant Epstein's battery against Plaintiff was facilitated by Defendant and the
conspiracy resulted in the various aforementioned crimes being committed against Plaintiff ■
as well as many other underage minor females.
76. As a direct and proximate result of Defendant, participation in the
aforementioned conspiracy, Plaintiff,. she has in the past suffered and will in the future suffer
injury, pain and suffering, emotional distress, psychological and psychiatric trauma, mental
anguish, humiliation, confusion, embarrassment, loss of self-esteem, loss of dignity, loss of
enjoyment of life, invasion of her privacy and other damages associated with Defendant's
manipulation and leading her into a perverse and unhealthy way of life. Plaintiff will incur
medical and psychological expenses. Plaintiff has suffered a loss of income, a loss of the
capacity to earn income in the future, loss of proper and complete education. These injuries are
permanent in nature and Plaintiff■ will continue to suffer these losses in the future.
WHEREFORE, Plaintiff■ demands judgment against Defendant for
compensatory damages, punitive damages and such other relief as this Court deems proper and
hereby demands trial by jury on all issues triable as of right by a jury.
COUNTS IV THROUGH XXIII
CAUSES OF ACTION AGAINST DEFENDANTS EPSTEIN AND PURSUANT
TO 18 USC 82255 IN VIOLATION OF VARIOUS ENUMERATED OFFENSES
CONTAINED WITHIN THAT FEDERAL STATUTE
77. Plaintiff,. adopts and realleges paragraphs I through 60 above.
78. The allegations contained herein in Counts IV through XXIII are separate and distinct
legal remedies.
I6
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79. As a condition of Defendant, Jeffrey Epstein's criminal plea, and in exchange for the
Federal Government not prosecuting the Defendant for numerous federal offenses, the
Defendant, Jeffrey Epstein, entered into a Non-Prosecution Agreement with the Federal
Government; that agreement governed not only Defendant Epstein's conduct but also the
conduct of his "co-conspirators" including Defendant as she played an essential and
criminal role in the commission of these offenses.
80. The Plaintiff,■was in fact a victim of one or more offenses enumerated in Title 18,
United States Code, Section 2255, and as such asserts a cause of action against the Defendant,
Jeffrey Epstein, and against Defendant pursuant to this Section of the United States Code
and the agreement between the Defendant, Jeffrey Epstein, and the United States Government.
81. Specifically, Defendants Epstein and
(a) knowingly conspired with others known and unknown to use a facility or
means of interstate commerce to knowingly persuade, induce, or entice minor females,
including Plaintiff MJ, to engage in prostitution, in violation of title 18, United States
Code, Section 2422(b).
(b) knowingly and willfully conspired with others known and unknown to travel
in interstate commerce for the purpose of engaging in illicit sexual conduct with minors,
including Plaintiff MJ, as defined in 18 U.S.C. § 2423(f), with minor females, in violation
of Title 18, United States Code, Section 2423(b); all in violation of Title 18, United
States Code, Section 2423(e);
(c) used a facility or means of interstate or foreign commerce to knowingly
persuade, induce, or entice minor females, including Plaintiff MJ, to engage in
prostitution; in violation of Title 18, United States Code, Section 2422(b);
17
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(d) traveled in interstate commerce for the purpose of engaging in illicit sexual
conduct, as defined in 18 U.S.C. § 2423(0, with minor females, including Plaintiff MJ; in
violation of Title l8, United States Code, Section 2423(b).
82. As a direct and proximate result of the aforementioned criminal offenses enumerated in
Title 18, United States Code, Section 2255, being committed against the then minor Plaintiff,
Plaintiff, MJ, she has in the past suffered and will in the future suffer injury, pain and suffering,
emotional distress, psychological and psychiatric trauma, mental anguish, humiliation,
confusion, embarrassment, loss of self-esteem, loss of dignity, loss of enjoyment of life, invasion
of her privacy and other damages associated with Defendant's manipulation and leading her into
a perverse and unhealthy way of life. Plaintiff will incur medical and psychological expenses.
These injuries are permanent in nature and PlaintiffEwill continue to suffer these losses in the
future. Plaintiff= has also incurred attorneys' fees.
83. With regard to each of the following counts, Plaintiff suffered personal injury, as outlined
above from the acts above, as a result of the violations of federal criminal law by Defendant
Epstein enumerated in paragraph 33, on approximately 20 occasions, and while the dates are not
all precisely documented or diaried by Plaintiff, Defendants Epstein and committed these
crimes and inflicted said injuries on or about the following dates:
COUNT IV August 2002
COUNT V September 2002
COUNT VI October 2002
COUNT VII November 2002
COUNT VIII December 2002
COUNT IX January 2003
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COUNT X February 2003
COUNT Xi
DataSet-10
Unknown
5 pages
Epstein v. Rothstein &
Case No.: 50-2009 CA 040800 AG
SCHEDULE OF UPCOMING DEPOSITIONS
DATE TIME LOCATION DESCRIPTION NOTES
5/17 (Tentative) 10:00am FWB -Miami Office igro 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 Our Deposition duces
(NY) tecum of AJ DiScala
EFTA00614736
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
EFTA00614737
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 ■
3). Motion to Quash Subpoena and For Protective Order re
Depo of Alfred Seckel;
4). Amended and Supplemental Motion to Overrule
Objections and Compel to Answer Questions and
Appear for Further Deposition;
n for Protective Order to Preclude Scarola Et
from making Extra Judicial Statements and
Commentary to the Media and Press (Judge Crow)
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;
EFTA00614738
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.
EFTA00614739
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 t.
Interrogatory served by fax on 4/1/11
5/2 All parties must file any 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 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 t0(TP due (Faxed 4/15)
EFTA00614740
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To: JearacationUeeyacationegmaitcom]
Fran: Lesley Groff
Sent Tue 9/1/2009 7:18:22 PM
Subject: reminder
You have a deposition tomorrow at 10am by video- Jack's office
EFTA_R1_01508617
EFTA02436224
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To: jeeyacationtOgmail.com[jeeyacation@gmail.com]
From: Lesley Groff
Sent: Wed 9/2/2009 12:52:10 PM
Subject: Reminder
Deposition at 10 today. Jack's office
EFTA_R1_01508644
EFTA02436239
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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:
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)
EFTA01154315
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
EFTA01154316
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.
EFTA01154317
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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
GEORGE PETRIDES,
Plaintiff,
-against-
Defendant.
NOTICE TO TAKE DEPOSITION
DOBRISH MICHAELS GROSS LLP
Attorneys for
Plaintiff
New York, Ncw York 10017
Pursuant to 22 NYCRR B0-1.1, the undersigned. an attorney admitted ro practice in the courts of
New York State, certifies that, upon
information and beliefand reasonable inquiry, the contentions contained in the annexed
document are notfrivolous.
Dated: January 9, 2013
Allison Berea, Esq.
Service of a copy of the within is herein' admitted.
Dated.•
Attorneysfor
EFTA00314177
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
X
GEORGE PETRIDES,
Index No.:
Plaintiff, NOTICE TO TAKE
DEPOSITION
-against -
Defendant.
X
PLEASE TAKE NOTICE, that pursuant to N.Y. C.P.L.R. 3101(a)(4) and N.Y. C.P.L.R.
3107, the deposition upon oral examination of JEFFREY EPSTEIN of the Epstein Foundation,
whose home address is 9 East 71st Street, New York, NY 10021, will be taken on the 29th day of
January, 2013 at 2:00 p.m. of that day, at the office of the attorney for the Plaintiff, DOBRISH
MICHAELS GROSS LLP at 757 Third Avenue, 15th Floor, New York; NY 10017. The
circumstances or reasons such disclosure is sought or required arc as follows:
Upon information and belief, the witness possesses information and documents, including
prepared records and backup schedules that are material and necessary to the prosecution of this
case not reasonably available from any of the other parties in this action.
JEFFREY EPSTEIN is required to produce at the examination the following records and
papers in his possession, custody, or control:
EFTA00314178
1. All records concerning the employment of including but not
limited to all contracts, correspondences, benefit records, compensation records
and/or reimbursements records.
Dated: New York, New York
January 9, 2013
DOBRISH MICHAELS GROSS LLP
By: Allison Berecz, Esq.
Attorneys for Plaintiff
757 Third Avenue, 15th Floor
New York, NY 10017
TO:
New York, NY 10016
2
EFTA00314179
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Lisa M. Rocchio Ph.D
Phone:
Disclosure of testimony as of 2/1/2021
• Deposition testimony on 12/11/2020 in the matter of CC v. County of Warren et aL
Superior Court of NJ, Warren NJ. Docket # WRN-L-000017-15
• Deposition testimony on 12/11/2020 in the matter of R.M. v County of Warren, a at
Superior Court of NJ, Warren, NJ. Docket # WRN-L-000328-16
• Deposition testimony on 8/23/2019 in the matter of: State of NH v. Hugh MacDonald
Rockingham Superior Court, Rockingham, NH Docket # 2182018CR00717
• Trial testimony on 6/12/2019 in the matter of: Commonwealth of MA v.. Erika Murray
Worcester Superior Court, Worcester, MA. Docket # WOCR2014-01393
• Deposition Testimony in 2011 in the matter of Donna MacAuliffe, Plaintiff, v. Leonard
Pompasello, JR. and Alexander Rubino, Sued Individually, Defendants
United States District Court, Southern District of New York, Docket # 10-cv-8721 (JSR)
• Trial testimony in 2002 in the matter of State of RI v. Joy Carter
Washington County District Court, South Kingstown, RI
*Docket number for this case is not available, and stenographer was not present
3502-002
Page I of I
EFTA_00001330
EFTA00156671
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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: 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)
, 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
EFTA00750927
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
EFTA00750928
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.
EFTA00750929
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From: Jeffrey Epstein
To: William Riley
Subject: Fwd: •. Deposition Transcript - Vol.1 - taken on September 24, 2009
Date: Tue, 29 Sep 2009 17:31:06 +0000
Attachments: 20090929103447436.pdf
Forwarded messa e
From: Connie Zaguirre
Date: Tue, Sep 29, 2009 at 11:25 AM
Subject: U. Deposition Transcript - Vol.1 - taken on September 24 2009
To: Jeffrey Epstein , Darren Indyke , Jack Goldberger
Enclosed please find ms 's deposition transcript, Volume 1, taken on September 24, 2009. There are
two volumes and I will be sending in two batches.
Connie L. Zaguirre, CP, FRP
Certified Paralegal
Florida Registered Paralegal
Assistant to Robert D. Critton,
Burman, Critton, Luttier & Coleman. I.LP
303 Banyan Boulevard, Suite 400
West Palm Beach, FL 33401
561-842-2820 Phone
561-253-0164 Fax
EFTA00740078
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 jeevacation@gmail.com, and
destroy this communication and all copies thereof,
including all attachments.
EFTA00740079