EFTA00793317.pdf
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
Plaintiff,
v. No. 17 Civ. 00616 (JGK)
JEFFREY EPSTEIN, GHISLAINE MAXWELL,
LESLEY GROFF and
Defendants.
PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION
OF
PLEASE TAKE NOTICE THAT, pursuant to Rule 30 of the Federal Rules of Civil
Procedure, counsel for Plaintiff, will take a videotaped deposition of the
Defendant as set forth below:
NAME:
DATE AND TIME: August 22, 2018 at 10:00 a.m.
LOCATION: Boies Schiller & Flexner, LLP
575 Lexington Avenue, Th Floor
New York, NY 10022
The videotaped deposition will be taken upon oral examination before Magna Legal
Services, or any other notary public authorized by law to take depositions. The oral examination
will continue from day to day until completed.
' Plaintiff originally filed this action under the pseudonym "Jane Doe 43," but is now proceeding
under her real name.
I
EFTA00793317
The video operator shall be provided by Magna Legal Services. This deposition is being
taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted
under the rules of this Court.
Dated: August 10, 2018.
BOLES SCHILLER FLEXNER LLP
By: /s/ Sigrid McCawley
Sigrid McCawley (Pro Hac Vice)
Meredith Schultz (Pro Hac Vice)
Boies Schiller Flexner LLP
401 E. Las Olas Blvd., Suite 1200
Ft. Lauderdale, FL 33301
Bradley J. Edwards, Esq. (Pro Hac Vice)
Stanley Pottinger, Esq.
EDWARDS POTTINGER LLC
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
Paul G. Cassell (Pro Hac Vice)
S.J. Quinney College of Law
University of Utah
383 University St.
Salt Lake Cit , UT 84112
2 This daytime business address is provided for identification and correspondence purposes only
and is not intended to imply institutional endorsement by the University of Utah for this private
representation.
2
EFTA00793318
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 10th day of August, 2018, I served the attached
PLAINTIFFS NOTICE OF TAKING VIDEOTAPED DEPOSITON OF WITNESS
via Email to the following counsel of record.
Michael Miller
Justin Y.K Chu
Michael A. Keough
STEPTOE & JOHNSON LLP
1114 Avenue of the Americas
SIM
Laura A. Menninger, Esq.
Jeffrey Pagliuca, Esq.
HADDON, MORGAN & FOREMAN, P.C.
150 East 10th Avenue
Denver, Colorado 80203
By: /s/ Sigrid McCawley
Sigrid McCawley
3
EFTA00793319
SOUTHERN DISTRICT OF NEW YORK
Plaintiff,
v. No. 17 Civ. 00616 (JGK)
JEFFREY EPSTEIN, GHISLAINE MAXWELL,
LESLEY GROFF and
Defendants.
PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION
OF
PLEASE TAKE NOTICE THAT, pursuant to Rule 30 of the Federal Rules of Civil
Procedure, counsel for Plaintiff, will take a videotaped deposition of the
Defendant as set forth below:
NAME:
DATE AND TIME: August 22, 2018 at 10:00 a.m.
LOCATION: Boies Schiller & Flexner, LLP
575 Lexington Avenue, Th Floor
New York, NY 10022
The videotaped deposition will be taken upon oral examination before Magna Legal
Services, or any other notary public authorized by law to take depositions. The oral examination
will continue from day to day until completed.
' Plaintiff originally filed this action under the pseudonym "Jane Doe 43," but is now proceeding
under her real name.
I
EFTA00793317
The video operator shall be provided by Magna Legal Services. This deposition is being
taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted
under the rules of this Court.
Dated: August 10, 2018.
BOLES SCHILLER FLEXNER LLP
By: /s/ Sigrid McCawley
Sigrid McCawley (Pro Hac Vice)
Meredith Schultz (Pro Hac Vice)
Boies Schiller Flexner LLP
401 E. Las Olas Blvd., Suite 1200
Ft. Lauderdale, FL 33301
Bradley J. Edwards, Esq. (Pro Hac Vice)
Stanley Pottinger, Esq.
EDWARDS POTTINGER LLC
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
Paul G. Cassell (Pro Hac Vice)
S.J. Quinney College of Law
University of Utah
383 University St.
Salt Lake Cit , UT 84112
2 This daytime business address is provided for identification and correspondence purposes only
and is not intended to imply institutional endorsement by the University of Utah for this private
representation.
2
EFTA00793318
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 10th day of August, 2018, I served the attached
PLAINTIFFS NOTICE OF TAKING VIDEOTAPED DEPOSITON OF WITNESS
via Email to the following counsel of record.
Michael Miller
Justin Y.K Chu
Michael A. Keough
STEPTOE & JOHNSON LLP
1114 Avenue of the Americas
SIM
Laura A. Menninger, Esq.
Jeffrey Pagliuca, Esq.
HADDON, MORGAN & FOREMAN, P.C.
150 East 10th Avenue
Denver, Colorado 80203
By: /s/ Sigrid McCawley
Sigrid McCawley
3
EFTA00793319