EFTA01125871.pdf
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
0013 3 4
" .._slytK:triStathar. AraLOSIWIEtrabfstiftr./Niallt.datille
EFTA01125880
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.
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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
0013 3 4
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EFTA01125880