EFTA00726285.pdf

NAQP (Rev rol Subverts ip Cam Issued by the UNITED STATES DISTRICT COURT Southern Florida DISTRICT OF Albert G. `ill SUBPOENA IN A CIVIL CASE V. Tom Hunt, et al. Carr N umber:: 07-cv-02020-O TO: Jeffrey Epstein 358 El Brillo Way Palm Beach, FL 33480-4730 YOU ARE COMMANDED to appear in the United States District court at the place, date, and time specified below to testify in the above case: PLACE OE TESTIMONY COURTROOM DATE MD TIME t YOU ARE COMMANDED to appear at the place, date, and time specified below to testify at the taking of a deposition in the above ease. PLACE OF DEPOSITION DATE AND TIME Regus - Phillips Point, 777 S. Fleger Drive, Suite 800 West Tower, Went Palm Beach. FL 33401 1/26/2010 9:30 am YOU ARE COMMANDED to produce and permit inspection and copying of the following documents or objects at the place, date, and time specified below (list documents or objects): See attached Exhibit A PLACE DATE AND TIME YOU ARE COMMANDED to permit inspection of the following premises at the date and time specified below. PREMISES DATE AND TIME Any organization not a party to this suit that is subpoenaed for the taking of a deposition shall designate one or more officers, directors, or managing agents, or other persons who consent to testify on its behalf, and may set forth, for each person designated, the matters on which the person will testify. F,pderal Rules of Civil Procedure, 30(bX6). TF4tfor 1-0A3 eb_rPt ncta, ETTORNEY IMIt Pli NTIF e ti %Lq_ I EF MANE) 444 DATE 12128 /09 ISSUING OFFICER'S NAME, ADDRESS AND PHO 'E NUMBER Bruce Bowman, Jr., Godwin Ronquillo , 1201 Elm Street, Suite 1700, Dallas, TX 75270-2041 (214) 939-8679 ATTORNEY FOR DEFENDANT ALINDA WIKERT (Sot Rule 45, Federal Rule of Civil Prot:eta Subdivilices (C. (ek on Page) ' If action pending in Mono other than astnct of imance. stoic chsinct under case flUnter. EFTA00726285 uagaas:61232faSuboacouloseiaCtic PROOF OF SERVICE DATE PLACE SERVED Na,ligNotx, . SERVED ON (PRINT NAME) MANNER OF SERVICE Sec •(tra-4t-- SERVED BY (PRINT NAME) TITLE OCy „ E'S CA44- a fia: Cgt SIINA-re DECLARATION OP SERVER I declare under penalty ofperj ury under the laws ofthe United States ofAmerica that the foregoing information contained in the Proof of Service is true and correct. Executed on 1Z(2% (0 5 DATE SIG, RE OF SbItVE.R ADDRESS OF SERVER Rule 45. Fedtral Rules or Civil Procedure. 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Ago teed wand (m)omens &drat ofPrivileged a other prattled inter end no cacao, or a pany man meetly ream% scqutAla, n iittrvy ese specified information and any copier it new aPPIte4 or Ins aid may net a at diAdalt ofooneima and the ChM ri MICAH: A receiving pay (iv) mitteco o paten to undue burden may pranpdy present the ingninfire m rho court ran seal fag darrrninbon of theelan (B)If umbra= If the rectivkig petty disclosed the is Monne before being notified, is mutt take tearonable niquito disclosure ofa codeine-re or OthrfOnraclaitial inkra.flaveloproall stops as reteme it Ile pence who Featured the information nag simian the information a oarsman, Warne/re. or acid AOCIlial is tescived. (ii) renultes disctosure of an uregamed mixt' prom or gramma, not donating specific events ce occormlices in dispose rod foulest from the expert's duty node (elCowtsaarl. I:MN/co/nay past without aiecaue co:ute mWeyer subpoena served oPre nods; mina awry piety, or that person nay be deemed a contenpt of Die court from *huh the subpoena timed. AA (ti) tepees a pawns alto as nor a pony or an &erneof. pony paces substantial adequate case for linen to obey mina what a sublimes perpms to mount a nonparty to engem: la bawl =RC than I CO mitt so and etial, the court meg to Facet • pence labial attend ce potter tinplate noe winos the limits punted by clause (incest:pangs* (c)(3)(A) EFTA00726286  EXHIBIT A Instructions: (a) "Jeffrey Epstein" shall refer to Jeffrey Epstein, as well as his employees (current and former), portfolio managers, analysts, agents, associates, partners, trustees, limited partners, companies related by common ownership or agreement, affiliated organizations, subsidiaries, consultants, accountants, advisors, directors, officers, predernsors or successors in interest, attorneys, and all other authorized representatives acting on its behalf or otherwise subject to his control. (b) The term "document" or "documents" shall broadly mean and include all originals or, if not available, all copies of originals, and all non-identical copies of all written, typed, recorded or graphic matter, as well as all attachments, agenda, and appendices thereto, of any nature or description whatsoever, wherever located, and in whatever form or condition, including but not limited to all letters, correspondence, telegrams, faxes, e-mails, electronic communications, cd- roms, hard drives, memoranda, notes, fee statements, records of legal services rendered, summaries, diaries, diary entries, calendars, appointment books, time records, visitor records, work records, telephone bills and records, expense records, travel and entertainment records, inspections, estimates, reports, journals, journal entries, ledgers, ledger entries, worksheets, work papers, accounting records, bank records, bank statements, cancelled checks, check stubs, check books, deposit receipts, employee records, payroll records, drafts, invoices, fee statements, books, articles, magazines, circulars, trade letters, press clippings, surveys, statistical data, graphs, maps, charts, transcripts, microfilm, microfiche, voice recordings, video recordings, tape or disc recordings, film, photographs, punch cards, programs, electronic recordings, any other data compilations for which information can be obtained or translated, and any summaries or drafts of the foregoing. (c) "Communications" includes, without limitation, every manner or means of statement, utterance, notation, disclaimer, transfer, or exchange of information of any nature whatsoever, by or to whomever, whether oral or written or whether face to face, by telephone, mail, personal delivery or otherwise, including but not limited to, letters, correspondence, conversations, memoranda, dialogue, discussions, meetings, interviews, consultations, agreements and other understandings. (d) The time period for these Requests for Production is January 1, 2000 to the present, unless otherwise stated. Document Requests: 1. Any all documents evidencing or relating to communications by and between Jeffrey Epstein and or Albert G. III, as well as their empire. current and former), attorneys, including any lawyer from the law firm of Bickel & entities or companies related by common ownership or agreement, including but not limited to Al-ITrey Investments, affiliated organizations, and all other authorized representatives acting on their behalf or otherwise subject to their control. D 1528188 v1-23444/0004 PLEADINGS EFTA00726287 2. Any and all documents provided to Jeffrey Epstein by ■ or Albert G. IN, HI, as well as theirfinkees (current and former), attorneys, including any lawyer from the law firm of Bickel & entities or companies related by common ownership or agreement, affiliated organizations, including but not limited to AHTrey Investments, and all other authorized representatives acting on their behalf or otherwise subject to their control. 3. Any and all documents provided to or Albert G.., III, as well as their ees (current and former), attorneys, including any lawyer from the law firm of Bickel & S entities or companies related by common ownership or agreement, affiliated organizations, including but not limited to AHTrey Investments, and all other authorized representatives acting on their behalf or otherwise subject to their control, by Jeffrey Epstein. D 1528188 v1-23444/0004 PLEADINGS EFTA00726288