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
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