gov.uscourts.nysd.447706.363.5.pdf

Case 1:15-cv-07433-LAP Document 363-5 Filed 08/11/16 Page 1 of 6 Exhibit E  Case 1:15-cv-07433-LAP Document 363-5 Filed 08/11/16 Page 2 of 6 District Court Fremont County, Colorado Court Address: 136 Justice Center Rd Canon City, CO 81212 Plaintiff(s)/Petitioner(s): Edwards, et al. COURT USE ONLY v. Case Number: Defendant(s)/Respondent(s): Dershowitz Division: Courtroom: SUBPOENA TO ‰ATTEND ??ATTEND AND PRODUCE To: __Jane Doe #3_(address redacted for purpose of court filing) You are ordered to attend and give testimony at the District Court of Fremont County, located at: 136 Justice Center Road, Canon City, CO 81212, Room # ___, on Tuesday, May 12, 2015, at 9:30 a.m. as a witness for the ‰Plaintiff(s)/Petitioner(s) _Defendant(s)/Respondent(s) in this action. At that time and place, you also shall produce the following items now in your custody or control: See attached Schedule A ______ Names, addresses and telephone numbers of all counsel of record in this action and of any party represented by counsel are as follows: Name Address Telephone Number For Plaintiffs Bradley J. Edwards 2139 Palm Beach Lakes Blvd. (561) 686-6300 and Paul G. Cassell West Palm Beach, FL 33409 Jack Scarola, FL Bar No. 169440 Searcy Denney Scarola Barnhart & Shipley, PA For Defendant Alan M. Dershowitz 9150 South Dadeland Blvd., (305) 350-5381 Thomas E. Scott, Florida Bar No. 149100 #1400 Steven R. Safra, Florida Bar No. 057028 Miami, FL 33156 Cole, Scott & Kissane, PA Date: _________________________ _____________________________________ Clerk/Deputy Clerk or Attorney JDF 80.2 COUNTY COURT SUBPOENA TO ATTEND OR ATTEND AND PRODUCE 1/13 © 2012 Colorado Judicial Department for use in the Courts of Colorado  Case 1:15-cv-07433-LAP Document 363-5 Filed 08/11/16 Page 3 of 6 AFFIDAVIT OF SERVICE I declare under oath that, I am 18 years or older and not a party to the action and that I served this Subpoena to ‰Attend ‰Attend and Produce to the Witness in ____________________(County)_____________________(State) on ____________(date)at the following location: ______________________________________________________ Check one: ‰ By handing it to a person identified to me as the Witness or by leaving it with the Witness who refused service. ‰ I attempted to serve the Witness on _______ occasions but have not been able to locate the Witness. ‰ Private process server ‰ Sheriff, _________________________County Fee $ ____________ Mileage $ ________ __________________________________ Signature of Process Server ___________________________________ Name (Print or type) My Commission Expires: ______________________ _________________________________________ Notary Public /Deputy Clerk Date JDF 80.2 COUNTY COURT SUBPOENA TO ATTEND OR ATTEND AND PRODUCE 1/13 © 2012 Colorado Judicial Department for use in the Courts of Colorado  Case 1:15-cv-07433-LAP Document 363-5 Filed 08/11/16 Page 4 of 6 SCHEDULE “A” 1. All documents that reference by name, Alan M. Dershowitz, 1 which support and/or confirm the allegations set forth in Paragraphs 24-31 of your Declaration dated January 19, 2015 and/or Paragraph 49 of your Declaration dated February 5, 2015, which were filed with the United States District Court for the Southern District of Florida, in Jane Doe #1 and Jane Doe #2 v. United States of America, Case No. 08-80736-CIV- MARRA/JOHNSON, [ECF No. 291-1] (the “Federal Action”). 2. All photographs and video in the original, native format in which they were taken (not a paper copy) of you with Alan M. Dershowitz. 3. All photographs and video in the original, native format in which they were taken (not a paper copy) not produced in response to Request No. 2, above, of Alan M. Dershowitz at (i) Jeffrey Epstein’s Manhattan home in New York City, New York; (ii) Mr. Epstein’s home in Palm Beach, Florida; (iii) Mr. Epstein’s Zorro Ranch in Santa Fe, New Mexico; (iv) Little Saint James island in the U.S. Virgin Islands; and (v) Mr. Epstein’s airplane, on the same date and time that you were also present at such location. 4. All photographs and video in the original, native format in which they were taken (not a paper copy) of you not produced in response to Request No. 3, above, that evidence and/or show you were present at the same location as Alan M. Dershowitz on that same date and time. 5. Any documents and information that support and/or confirm your presence at the various locations named in Paragraphs 24-31 of your Declaration on the particular dates and times when Alan M. Dershowitz was also present. 6. Any documents and information that show Alan M. Dershowitz was present at the various locations named in Paragraphs 24-31 of your Declaration on the particular dates and times when you allege to have been present in your response to Request No. 5, above. 7. All statements, written or recorded, which you have provided to anyone that reference by name, Alan M. Dershowitz. 8. All notes of, or notes prepared for, any statements or interviews in which you referenced by name or other description, Alan M. Dershowitz. 9. All documents concerning any communications by you or on your behalf with any media outlet concerning Alan M. Dershowitz or the Federal Action, whether or not such communications were “on the record” or “off the record.” 1 For purposes of this Schedule “A”, reference to “Alan M. Dershowitz” herein shall mean and refer to any reference to the Defendant in this action, including but not limited to, as “Alan”, “Alan M. Dershowitz”, “Professor Dershowitz”, or “Dershowitz”, and the like. JDF 80.2 COUNTY COURT SUBPOENA TO ATTEND OR ATTEND AND PRODUCE 1/13 © 2012 Colorado Judicial Department for use in the Courts of Colorado  Case 1:15-cv-07433-LAP Document 363-5 Filed 08/11/16 Page 5 of 6 10. All notes, writings, photographs, and/or audio or video recordings made or recorded by or of you on the dates on which you allege you were present with Alan M. Dershowitz, including but not limited to your calendar, diary or journal entries on those dates, regardless whether the notes, writings, photographs, and/or audio or video recordings refer to Mr. Dershowitz. To the extent that any responsive materials are photographs or video recordings, please provide them in the original, native format in which they were taken (not a paper copy). 12. All documents relating to your travel to or from locations for those occasions when you allege you were present with Alan M. Dershowitz. 13. To the extent not produced in response to the above list of requested documents, all notes, writings, photographs, and/or audio or video recordings made at any time that refer or relate in any way to Alan M. Dershowitz. 14. All drafts of declarations or affidavits by you that relate in any way to Alan M. Dershowitz and/or Jeffrey Epstein. 15. All documents relating to any telephone, including any cellular telephone, used by you between January 1, 1999 and December 31, 2002. 16. Any diary, journal or calendar concerning your activities between January 1, 1999 and December 31, 2002. 17. All documents concerning any actual or potential book, television or movie deals concerning your allegations about being a sex slave. 18. All documents concerning any monetary payments or other consideration received by you from any media outlet in exchange for your statements (whether “on the record” or “off the record”) regarding Jeffrey Epstein, Alan M. Dershowitz, Prince Andrew, Duke of York, and/or being a sex slave. 19. All documents showing, concerning, relating or referring to when you were at or on (i) Jeffrey Epstein’s Manhattan home in New York City, New York; (ii) Mr. Epstein’s home in Palm Beach, Florida; (iii) Mr. Epstein’s Zorro Ranch in Santa Fe, New Mexico; (iv) Little Saint James island in the U.S. Virgin Islands; and (v) Mr. Epstein’s airplane from January 1, 1999 through December 31, 2002. 20. All documents showing any payments or remuneration of any kind made by Jeffrey Epstein or any of his agents or associates to you from January 1, 1999 through December 31, 2002. 21. All travel records of any kind, including but not limited to tickets, hotel room receipts or other documents concerning, relating or referring to any travel undertaken by you between January 1, 1999 and December 31, 2002. JDF 80.2 COUNTY COURT SUBPOENA TO ATTEND OR ATTEND AND PRODUCE 1/13 © 2012 Colorado Judicial Department for use in the Courts of Colorado  Case 1:15-cv-07433-LAP Document 363-5 Filed 08/11/16 Page 6 of 6 22. All records of any interviews given by you to any party concerning, relating or referring to Jeffrey Epstein or any of his agents or associates. 23. All manuscripts and/or other writings, whether published or unpublished, created in whole or in part by you, concerning, relating or referring to Jeffrey Epstein and any of his agents or associates. 24. All documents concerning, relating or referring to your assertions that you met former President Bill Clinton, former Vice President Al Gore and/or Mary Elizabeth “Tipper” Gore on Little Saint James island in the U.S. Virgin Islands. 25. All documents concerning your retention of the law firm Boies, Schiller & Flexner LLP, including but not limited to: signed letter of retainer, retention agreement, explanation of fees, and/or any documents describing the scope of retention. JDF 80.2 COUNTY COURT SUBPOENA TO ATTEND OR ATTEND AND PRODUCE 1/13 © 2012 Colorado Judicial Department for use in the Courts of Colorado