EFTA01082332.pdf

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and individually, Defendants. NOTICE OF TAKING DEPOSITION *Duces Tecum TO: All counsel on the attached Counsel List PLEASE TAKE NOTICE that the undersigned attorneys will take deposition(s) of: NAME AND ADDRESS DATE AND TIME LOCATION Representative(s) of The September 6, 2011 Searcy Denney Scarola Barnhart & Wackenhut Corporation with 10:00 AM. Shi le PA the most knowledge of the matters set forth below pursuant to Fla. R. Civ. P. 1.310(bX6) *DUCES TECUM: TO HAVE AND BRING WITH YOU AT THE TIME OF THE DEPOSITION THE FOLLOWING: Any and all documents** reflecting or relating to services rendered: 1. at or in the general vicinity of 358 El Brillo Way, Palm Beach, FL 33480-4730; and 2. for the benefit of or at the direction of Jeffrey Epstein and/or Jack Goldberger including but not limited to documents reflecting when the services were performed, how long they were performed, the nature of the services, and by whom they were performed. EFTA01082332 upon oral examination before Signature Court Reporting, Inc., a Notary Public, or any other officer authorized by law to take depositions in the State of Florida. The oral examination is being taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted under the applicable Statutes or Rules. **"Documents" shall include, but not be limited to all non-identical copies of writings, drawings, graphs, charts, photographs, phono-records, recordings, and/or any other data compilations from which information can be obtained, translated, if necessary, by the party to whom the request is directed through detection devices into reasonably usable form. "Documents" also include all. electronic data as well as application metadata and system metadata. All inventories and rosters of your information technology (IT) systems—e.g., hardware, software and data, including but not limited to network drawings, lists of computing devices (servers, PCs, laptops, PDAs, cell phones, with data storage and/or transmission features), programs, data maps and security tools and protocols. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail to all Counsel on the attached list, this h f August 2011. lack Attorney for Defendant Edwards cc: Signature Court Reporting E-TRANSCRIPT. ASCII. CD AND/OR DVD REOUESTED EFTA01082333  COUNSEL LIST Jack A. Goldber er, Es uire Atterbury, Goldberger & Weiss, Attorneys for Jeffrey Epstein Bradley Edwards Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL Jose h L. Ackerman, Jr., Es uire w Whi Burnett ttorneys or e rey pstem Marc S. Nurik Es uire Law Offices of Marc S. Nurik Attorneys or cott o stein Martin Weinberg, Es uire Martin Weinber Attorneys for Jeffrey Epstein EFTA01082334  IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, CASE NO: 502009CA040800XXXXMBAG Plaintiffs, vs. SCOTT ROTHSTEIN, individually, OV[Ei r BRADLEY J. EDWARDS, individually, and M., individually, icic 1 5 2011 Defendants. SUBPOENA DUCES TECUM FOR DEPOSITION THE STATE OF FLORIDA TO: The Representative(s) of The Wackenhut Corporation with the most knowledge of the matters set forth below pursuant to Fla. R. Civ. P. 1.310(b)(6) YOU ARE COMMANDED to appear before a person authorized by law to take depositions at the offices of undersigned counsel on Tuesday, September 6, 2011, at 10:00 AM, for the taking of your deposition in this action. You are to have with you at the above place and time the following: DUCES TECUM: Any and all documents* reflecting or relating to services rendered: 1. at or in the general vicinity of 358 El Brillo Way, Palm Beach, FL 33480-4730; and 2. for the benefit of or at the direction of Jeffrey Epstein and/or Jack Goldberger including but not limited to documents reflecting when the services were performed, how long they were performed, the nature of the services, and by whom they were performed. EFTA01082335 Epstein adv. Edwards Case No.: 502009CA040800XXXXMBAG Subpocna Duces Tecum for Deposition Page 2 of 2 "Documents" shall include, but not be limited to all non-identical copies of writings, drawings, graphs, chans, photographs, phono-records, recordings, and/or any other data compilations from which information can be obtained, translated, if necessary, by the party to whom the request is directed through detection devices into reasonably usable form. "Documents" also include all electronic data as well as application metadata and system metadata. All inventories and rosters of your information technology (IT) systems---e.g., hardware, software and data, including but not limited to network drawings, lists of computing devices (servers, PCs, laptops, PDAs, cell phones, with data storage and/or transmission features), programs, data maps and security mols and protocols. If you fall to appear, you may be in contempt of Court. You are subpoenaed to appear by the following attomcy and unless excused from this subpoena by this attorney or the Court, you shall respond to this subpoena as directed. DATED this (t i day of August 2011. Jack a On If of the Court Jack Scarola Florida Bar No.: 169440 Searcy Denney Scarola Barnhan & Shipley, Attomeys for Defendant Edwards EFTA01082336 "If you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact Krista Garber, Americans with Disabilities Act Coordinator, at least 7 days before your scheduled court appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711." "Si usted es una persona minusysilida que necesita algan acomodamiento para poder participar en este procedimiento, usted tiene derecho, sin tener gastos propios, a que se le provea cierta ayuda. Tenga la amabilidad de ponerse en contacto con Krista Garber Americans with Disabilities Act Coordinator, por lo menos 7 dias antes de la cita fijada para su comparecencia en los tribunales, o inmediatamente despuis de recibir esta notificacion si el tiempo antes de la comparecencia que se ha programado es menos de 7 dias; si usted tiene discapacitacion del oido o de la voz, llame al 711." "Si ou se yon moun ki enfim ki bezwen akomodasyon pou w ka patisipe nan pwosedi sa, ou kalifye san ou pa gen okenn lajan pou w peye, gen pwovizyon pou jwen kik id. Tanpri kontakte nan 7 jou anvan dat ou gen randevou pou paret nan tribinal la, oubyen imedyatman apre ou fin resevwa konvokasyon an si li ou gen pou w parit nan tribinal la mwens ke 7 jou; si ou gen pwoblem pou w tande oubyen pale, rele 711." 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