EFTA02435950.pdf
To: Jeffrey Epsteinfieeyacation©gmail.com] From: story cowles Sent: Thur 11/19/2009 8:47:41 PM Subject: Daliah Weiss Daliah Weiss Tuesday deposition is cancelled. EFTA_R1_01508223 EFTA02435950
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EFTA02412969.pdf
To: jeeyacationtegmail.com[jeeyacation@gmail.corn] From: story cowles Sent: Wed 4/15/2009 6:38:24 PM Subject: Depositions I spoke to Sandy (David Spicers paralegal) who informed me that they need a signed "Stipulation for Substitution of Counsel" which I have here waiting for you to sign. They will take care of the deposition scheduled for tomorrow. The next one is scheduled for next Thursday the 23rd and then another the following Thursday the 30th. story EFTA_R1_01474950 EFTA02412969
EFTA00803855.pdf
AO 884 (Rev. 12/13) Subpoena to Testify at a Deposition in a Civil Action UNITED STATES DISTRICT COURT for the Southern District of New York Plaintiff v. Civil Action No. 17-cv-00616 (JGK) Jeffre Epstein, Ghislaine Maxwell Lesley Groff and Defendant SUBPOENA TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION To: Igor Zlnoviev (Name ofperson to whom this subpoena is directed) "(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: Place: Soles Schiller Flexner, LLP Date and Time: 575 Lexington Avenue, 7th Floor 11/15/2018 10:00 am New York, NY 10022 The deposition will be recorded by this method: Stenographically and Videotaped Cl Production: 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: 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 of not doing so. Date: 10/15/2018 CLERK OF COURT OR Signature ofClerk or Deputy Clerk At ney's signature The name, address, e-mail address, and telephone number of the attorney representing (name ofpony) , who issues or requests this subpoena, are: Sigrid McCawley, Boles Schiller Flexner LLP, 401 E. Las Olas Boulevard Suite 1200, Fort Lauderdale, FL 33301, E-mail: , Telephone: Notice to the person who issues or requests this subpoena if this subpoena commands the production of documents, electronically stored information, or tangible things, 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. Fcd. R. Civ. P. 45(a)(4). EFTA00803855 AO SSA (Rev. I V13) Subpoena to Testify at a Deposition in a Civil Action (Page 2) Civil Action No. 17-cv-00616 (JGK) PROOF OF SERVICE (This section should not be filed with the court unless required by Fed. R. Civ. P. 45.) I received this subpoena for (name ofindividual and title. ifany) on (dare) 0 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 the 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 Printedname and title Server's address Additional information regarding attempted service, etc.: EFTA00803856 AU S,SA (fir•._ :: 'A$, .1 lc. Tcsufy at a Deposition in a Civil Action (Page 3) Federal Rule of Civil Procedure 45 (c), (d), (e), 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) Fore Trial. Heating, or Deposition. A subpoena may command a (II) disclosing an unrctained expert's opinion or information that does person to attend a trial, hearing, or deposition only as follows: not describe specific occurrences in dispute and results from the expert's (A) within 100 miles of where the person resides, is employed, or study that was not requested by a party. regularly transacts business in person; or (C)Specihttg Conditions as an Alternative. In the circumstances (B) within the state where the person resides, is employed, or regularly described in Rule 45(d)(JXB), the court may, instead of quashing or transacts business in person, if the person modifying a subpoena, order appearance or production under specified (i) is a 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 fill ensures that the subpoenaed person will be reasonably compensated. (2) For Other Discovery. A subpoena may command: (A) production of documents, electronically stored information, or (e) Duties in Responding to a Subpoena. tangible things at a place within 100 miles of where the person resides, is employed, a regularly transacts business in person; and (I) Producing Documents or £lectronlealiy StoredInformation These (B) inspection of premises 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) Documents A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or (I ) Avoiding Undue Burden or Expense; Sanctions. A party or attorney must organize and label them to correspond to the categories in the demand. responsible for issuing and serving a subpoena must take reasonable steps (B) Formfor Producing Electronically Stored Information Not Specified. to avoid imposing undue burden or expense on a person subject to the If a subpoena does not specify a form for producing electronically stored subpoena. The court for the district where 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 forms. lost earnings and reasonable attorney's fees—on a party or attorney who (C) Electronicalb, StoredInformation Produced in Onty One Form. The fails to comply. person responding need not produce the same electronically stored information in more than one form (2) Command to Produce Materials or Perndt Inspection. (1)) Inaccessible Electronically Stored Information. The person (A) Appearance Not Required A person commanded 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 of premises, need not appear in person at the place of of undue burden or cost. On motion to compel discovery or for a protective production or inspection unless also commanded to appear for a deposition, order, the person responding must show that the information it not hearing, or trial. reasonably accessible because of undue 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 serve on the party or attorney designated requesting party 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 served before the earlier of the time specified for (A) Information Withheld. A person withholding subpoenaed information compliance or 14 days after the subpoena is served. If an objection is made, under a claim that it is privileged or subject to protection as trial•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 court for the district where compliance is required for an Oil describe the nature of the withheld documents, communications, or order compelling production or inspection. tangible things in a manner that, without revealing intonation itself (ft) These acts may be required only as directed in the order, and the privileged or protected, will enable the parties to assess the claim. order must protect a person who is neither a pasty nor a parry's officer from (B) Information Produced If information produced in response to a significant expense resulting from compliance. subpoena is subject to a claim of privilege or of protection as trial•preparation material, the person making the claim may notify any party (3) Quaking or Modifying 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 court 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; and 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(e); produced the information must preserve the information until the claim is (iii) requires disclosure ofprivileged or other protected matter, if no resolved. exception or waiver applies; or (Iv) subjects a person to undue burden. (g) Contempt (B) Mien Permitted To protect a person subject to or affected by a The court for the district where compliance is required-and 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 requires: who, having been served, 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) Committee Note (2013). EFTA00803857
EFTA01824330.pdf
To: story cowles From: Jeffrey Epstein Sent Tue 2/16/2010 5:47:25 PM Subject Re: Virginia Alverez deposition no On Tuc, Feb 16, 2010 at 10:43 AM, story cowles wrote: 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. *t*t*t*t*t*t*t*****t*t*t*t*t*t***t***t*t***t*t*t*t*t*t*t*t* The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Jeffrey Epstein Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to jeevacation®gmail.com and destroy this communication and all copies thereof, including all attachments. EFTA_R1_00198349 EFTA01824330
EFTA02438352.pdf
To: Jeffrey Epsteinfleevacationagmail.comj Fran: story cowles Sent Wed 10/7/2009 5:24:03 PM Subject Deposition Jessica just received an email from Brad Edwards office requesting a date for my deposition. Story EFTA_R1_01511519 EFTA02438352
EFTA02433855.pdf
To: Jeffrey Epsteinfleevacation@gmail.comj From: story cowles Sent Fri 12/4/2009 3:10:01 PM Subject: Deposition They have not begun yet and CMA is not in the room yet. EFTA_R1_01505228 EFTA02433855
EFTA01154306.pdf
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. Plaintiff, vs. JEFFREY EPSTEIN, Defendant. NOTICE OF TAKING VIDEOTAPED DEPOSITION PLEASE TAKE NOTICE that the Plaintiff, will take the deposition of Mark Epstein on Monday, September 21, 2009, at 11:00 a.m., at: Esquire Court Reporters One Penn Plaza Suite 4715 New York, NY 10119 The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure and shall continue day to day, weekends and holidays excepted, until completed. I HEREBY CERTIFY that a true and correct copy of the foregoing has been served by U.S. Mail and email transmission this //4'day of August, 2009 to all those on the attached Service List. EFTA01154306 I cc: Esquire Court Reporters EFTA01154307
EFTA00433436.pdf
From: Lesley Groff
To: "Lisa B. Toney" •cl
Subject: Re: Tomorrow's deposition
Date: Tue, 24 May 2011 14:19:14 +0000
ah! good to know— lobby on 23rd floor...thanks so much. Jeffrey will be there.
On May 24, 2011, at 10:19 AM, Lisa B. Toney wrote:
Lesley,
The main reception lobby for Dewey & LeBoeuf is located on the 23rd floor. This will confirm that they will meet at
10:00 am in the lobby of Dewey & LeBoeuf.
Please let me know if you need anything further.
Best regards,
Lisa
EFTA02437411.pdf
To: Jeeyacation[jeeyacation@gmail.com] From: Lesley Groff Sent: Tue 9/15/2009 2:44:02 PM Subject: deposition reminder Fyi- I show tomorrow, Sept. 16th, at I pm, Jane Doc itzt (= will have a deposition by video EFTA_R1_01510223 EFTA02437411
EFTA02437340.pdf
To: Jeffrey Epsteinfleevacationagmail.comj From: story cowles Sent Thur 9/17/2009 7:37:17 PM Subject City file Video from deposition: http://cityfile.com/dailyfile/7274 Story EFTA_R1_01510139 EFTA02437340
EFTA01827588.pdf
To: Sandy Hugh From: Jeffrey Epstei Sent Thur 4/16/2009 2:44:24 PM Subject: Re: Depositions good work On Thu, Apr 16, 2009 at 10:41 AM, Sandy Hughes wrote: The attached, hearing held today Judge Hafele ruled no depo today, depo rc-set within 30 days. Sandy Hughes, Paralegal Office Administrator Law Office of David Palm Beach Gardens, FL 33410-3477 IRS Circular 230 Disclosure: Please note that the views expressed herein or in any attachments hereto are not intended to constitute a "reliance opinion" under applicable Treasury Regulations, and accordingly are not intended or written to be used, and may not be used or relied upon, for the purpose of (i) avoiding tax-related penalties that may be imposed by the Internal Revenue Service, or (ii) promoting, marketing or recommending to another party any tax-related matters addressed herein. Disclaimer: This E-mail is covered by the Electronic Communications Privacy Act, 18 U.S.C. § 2510-2521 and is legally privileged. The information contained in this E-mail is intended only for use of the individual or entity named above. If the reader of this message is not the intended recipient, or the employee or agent responsible for delivering it to the intended recipient, you are hereby notified that any dissemination, distribution, or copying of this communication is strictly prohibited. If you receive this E-mail in error, please notify the sender immediately at the phone number above and delete the information from your computer. Please do not copy or use it for any purpose nor disclose its contents to any other person Confidentiality Notice: This e-mail message including attachments, if any, is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail, destroy all copies of the original message, and do not disseminate it father. If you are the intended receipient but do not wish to receive communications through theis medium, please advise the sender immediately. Original Messa e From: story cowles Sent: Thursday, Ap • EFTA_R1_00202772 EFTA01827588 To: Sandy Hughes Subject: Depositions Sandy, What was filed to reschedule todays deposition? Story EFTA_R1_00202773 EFTA01827589
EFTA01154318.pdf
AO SSA (Rev. 01109) Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action UNITED STATES DISTRICT COURT for the Southern District of Florida Plaintiff V. Civil Action No. JEFFREY EPSTEIN (If the action is pending in another district, state where: Defendant SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION To: Mark Epstein, 301 E. 66th Street, New York, NY Testimony: YOU ARE COMMANDED to appear at the time, date, and place set forth below to testify at a deposition to be taken in this civil action. If you are an organization that is not a party in this case, you must designate one or more officers, directors, or managing agents, or designate other persons who consent to testify on your behalf about the following matters, or those set forth in an attachment: Place: Esquire Court Reporters, One Penn Plaza Date and Time: Suite 4715, New York, NY 09/21/2009 11:00 am The deposition will be recorded by this method: O Production: You, or your representatives, must also bring with you to the deposition the following documents, electronically stored information, or objects, and permit their inspection, copying, testing, or sampling of the material: The provisions of Fed. R. Civ. P. 45(c), relating to your protection as a person subject to a subpoena, and Rule 45 (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, are attached. Date: CLERK OF COURT OR Signature of Clerk or Deputy Clerk Attorney's signature The name, address, e-mail, and telephone number of the attorney representing (name ofparty) EFTA01154318 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 EFTA01154319 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. EFTA01154320
EFTA02437922.pdf
To: Jeffrey Epsteinfleevacationagmail.comj From: story cowles Sent Mon 10/5/2009 10:15:12 PM Subject: Deposition Thursday I just spoke to Jessica who informed me that she did not set this depo. Kuvins office set it. It is a continuation from the last one you walked out on. Jessica also informed me that there is a court hearing in the morning before the depo regarding our motion for protective order against Kuvin as to the scope of how it is to happen. Story EFTA_R1_01510880 EFTA02437922
EFTA01991120.pdf
From: Jean Luc Brunel > Date: 2012/9/19 Subject oct 4th To: ' jeevacation©gmail.com " < jeevacation©gmail.com > n deposition — The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for EFTA_R1_00483991 EFTA01991120
EFTA02085653.pdf
To: PC[■ From: Sent Wed 2/4/2015 6:11:00 PM Subject Jeffrey Epstein Hi Erika...Jeffrey needs to take a deposition for the Sitrick case he is involved in on Feb. 25th at 2pm STT time...I'm thinking you are probably aware of this? Chet Brewer is representing him...Jeffrey and Chet want him to take the depo at your office. Chet says you do not need to be there, but he would like to make sure that someone is watching your door (he is concerned about press) If you wanted to speak to Chet he is happy to talk with you. We wanted to make sure that Feb. 25th at 2pm would work on your end. Please let me know. Chet Brewer: Thanks! EFTA_R1_00674948 EFTA02085653
EFTA01019344.pdf
From: J
EFTA00730313.pdf
AO 88A (Rev. 01/09) 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: H' 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 ofClerk or Deputy Clerk Attorney's signature The name, address, e-mail, and telephone number of the attorney representing (name ofpony) , who issues or requests this subpoena, are: Brad Edwards. Es Rothstein Rosenfeldt Adler, 401 E. Las Olas Blvd., Suite 1650, Fort Lauderdale, Florida 33301 EFTA00730313 AO 88A (Rev. 01/09) Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action (Page 2) Civil Action No. 08-908930 IV-MARRA/JOHNSO PROOF OF SERVICE (This section should not befiled with the cour► unless required by Fed. R. Civ. P. 45.) This subpoena for (name ofindividual and title. ?fatty) 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: EFTA00730314 AO 88A (Rev. 01/09) 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. (1) 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 Nor (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 StoredInformation. 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)(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)(3XB), 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 othenvise met without undue hardship; and (Ii) ensures that the subpoenaed person will be reasonably compensated. EFTA00730315
EFTA02264021.pdf
To: J 'e
lkeilationepgmail.comi
From:
Sent Fri 11/23/2018 8:01:23 PM
Subject Re: Deposition Wed Nov 28?
Ok thanks
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On Nov 23, 2018, at 3:00 PM J
EFTA00730322.pdf
AO SSA (Rev. 01109) Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action UNITED STATES DISTRICT COURT for the Southern District of Florida JANE DOE Plaintiff V. Civil Action No. 08-90893CIV-MARRA/JOHNSO JEFFREY EPSTEIN (If the action is pending in another district, state where: Defendant SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION To: Jean Luc Bruhel, 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. Es Roth dler, 401 E. Las Olas Blvd., Suite 1650, Fort Lauderdale, Florida 33301 EFTA00730322 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 EFTA00730323 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. EFTA00730324
EFTA01122773.pdf
Jeffrey Epstein v. Bradley Edwards, Scott Rothstein Case No.: DEPOSITION SCHEDULE (As of 2/23/11) Date Deponent Location Set By Served/Confirmed 2/25 RC Depo of Donnie Ingraham Scarola Yes (Wackenhut employee) 2/28 RC Depo of Christopher Schmidt Scarola Yes (Wackenhut employee 3/10 A.J. DiScala Dewe LeBouef FWB Yes 3/11 Michael Legamaro Moran Lewis FWB Yes EFTA01122773