gov.uscourts.nysd.447706.1331.35.pdf

Case 1:15-cv-07433-LAP Document 1331-35 Filed 01/05/24 Page 1 of 11 (;+,%,7,  Case 1:15-cv-07433-LAP Document 1331-35 Filed 01/05/24 Page 2 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ---------------------------- -~--------------X VIRGINIA L. GIUFFRE, Plaintiff, v. GIDSLAINE MAXWELL, tS-ar-07433-RWS Defendant. ----------------------------------------X NOTICE OF SERVICE OF RULE 45 SUBPOENA AND NOTICE OF DEPOSfflON OF SARAH RANSOME PLEASE TAKE NOTICE that on February 17, 1017 at 9:00 Lm., pursuant to Rule 30 of the Federal Rules of Civil Procedw-e, counsel for the defendant will take the deposition of Sarah Ransome at 575 Lexington Ave., FJ. 4, New York, NY 10022, before a certified court reporter or other officer duly authorized to administer oaths. The deposition will be recorded by stenographic means. Pursuant to Rule 45, Defendant Ghislaine Maxwell also hereby provides Notice of Service of Subpoena upon Sarah Ransome. A copy of the Subpoena is attached to this Notice. EXHIBIT (] J L } )_ / l7 l /7 JEREMY RICHMAN  Case 1:15-cv-07433-LAP Document 1331-35 Filed 01/05/24 Page 3 of 11 Dated: February 6, 2017 Respectfully submitted, sf Laura A. Menninger Laura A. Menninger (LM-1374) Jeffiey S. Pagliuca HADDON, MORGAN AND FOREMAN, P.C. 111 150 East 10 Avenue Denver, CO 80203 Phone: 303.831.7364 Fax: 303.832.2628 [email protected] Attorneys for Ghislaine Maxwell CERTIFICATE OF SERVICE I certify that on February 6, 2017, I electronically served this NOTICE OF SERVICE OF RULE 45 SUBPOENA AND NOTICE OF DEPOSITION OF SA.RAH RANSOME via Email on the folJowing: Sigrid S. McCawley Paul G. Cassell Meridith Schultz 383 S. University Street Borns, SCHILLER & FLEXNER., LLP Salt Lake City, UT 84112 401 East Las Olas Boulevard, Ste. 1200 [email protected] Ft Lauderdale, FL 33301 [email protected] [email protected] Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 42S North Andrews Ave., Ste. 2 Ft. Laudeniale, FL 33301 [email protected] Isl Nicole Simmons Nicole Simmons 2  Case 1:15-cv-07433-LAP Document 1331-35 Filed 01/05/24 Page 4 of 11 AO 88A ( Rev. 12113) Subpoena to Testify at a Deposi1ion m a Civil Action UNITED STATES DISTRJCT COURT for the Southern District of New York Virginia Giuffre ) Plaintiff ) V. ) Civil Action No. 15--cv-07433-RWS Ghislaine Maxwell ) - - - - -- -- - - ----- ) ~fondant ) SUBPOENA TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION To: Sarah Ransome {Name ofperson to whom this sub{JOena is directed) ff! Testimony: YOU ARE COMMANDED to appear at the time, date, and pJace set forth below to testify at a deposition to be taken in this civil action. Jfyou 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: Date and Time: 575 Lexington Avenue, 4th Floor February 17 at 9:00 a.m. New York. New York 10022 The deposition will be recorded by this method: stenography ffl Production: You, or your representatives, must also bring with you to the deposition the following documents, electronically stored infonnation, or objects, and must pennit inspection, copying, testing, or sampling of the material: See Attachment A 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: 02/06/2017 CLERK OF COURT Signature ofCleric or Deputy Clerk The name, address, e-mail address, and telephone number of the attorney representing /Mme ofporty) _ _ __ _ _ _ _ _ _ _ _ __ __ _ _ _ _ _ __ _ __ , who issues or requests this subpoena, are: Laura A. Menninger, 150 E. 10th Ave., Denver, CO 80203, [email protected], 303-831 -7364. Notice to the penon 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. Fed. R. Civ. P. 45(a)(4).  Case 1:15-cv-07433-LAP Document 1331-35 Filed 01/05/24 Page 5 of 11 AO 88A (Rtv 12/13) Subpoena 10 Tesufy at a Ocposi1ion in a Civil Action (Page 2) Civil Action No. 15-cv-07433-RWS PROOF OF SERVICE (This section should not be flied with the court unless require,/ by Fed. R. Civ. P. .f5.) I received this subpoena for (name ofindividual and title, ifany) on (dote) a I served the subpoena by delivering a copy to the named individual as follows : on (date) ; or - - -- - -- - ------ a 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: &rwr's signotlll'e Printed name and title &r-ver 's address Additional information regarding attempted service, etc.:  Case 1:15-cv-07433-LAP Document 1331-35 Filed 01/05/24 Page 6 of 11 AO 88A (Rev. 12/13) Subpoena to Testify al a Deposition in a Civil Action (Page 3) Federal Rule of Civil Procedure 45 (c), (d), {e), and (g) (Effective 12/1/13) (c) PIRce of Compliance. (i) disclosing a trade secret or other confidential research, development or commercial information; or ' (l) Fora Trial, /fe11ring, or Depositfon. A subpoena may command a (ii) disclosing an unretained expett's opinion or i11fom1ation that docs per$t>n to Attend a trial, hearing, or deposition only as follows: not describe specific occurrences in dispute and results from the expert's (A) wi1l1in 100 miles of where the person resides. is employed, or study that was not requested by a party. regularly tnmsacts business in person; or (C) Specifying Conditions os on Alternative In the circumstances (8) within the state where !he person resides, is employed, or regularly described in Rule 45(dXl)(B), the court may, instead of quashing or transac!S business in pe,son, 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 ,uend a trial and would not incur substantial (i) shows a substantial need for the testimony or material that cannot be cxpense- otherwise met without undue hardship; and (ii) ensures that the subpoenaed person will be reasonably compensated_ (2) For Othu Discovery. A subpoena may comm.and: (A) production of documents, electro.nically stored information, or (e) Outio in Responding to a Subpoena. tangible things at a place within 100 miles of where the person resides, is employed, or reguhuly transacts business in pcnon; and (1) Protl#cu,g Doc111tKnts or Efulrrmicnlly Stored lnflmnntion. These (B) inspection of premises at the premises to be inspec1ed. procedun:s apply to producing documents or electronically stored information: (d) Protccliqc, a Pcrso■ Subject co• S..bp~H; Eafortemcol (A) Documen/1. A person responding lo a subpoena to produce documents must produce them as they are kept in the ordinary course of business or (l)Avo/dlng U11due B11rden or E.xpense; Sanctions. A party oc attorney mllSt organiu and label them to correspond to the categories in the demand. responsible for issuing and serving a subpoena must take reasonable steps (B) Form/or Producing Electronically Stor,d lnfor,no1io,, Not Specified. 10 avoid imposing undue burden or expense on a person sul!ject to tbe IC. subpoena does not specify a fi>nn for producing electronically stored subpoena. The court for the distrie1 where rompliance is required must information, the pason responding mllSl 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 fonn or fonns. loSI earnings and reasonable attorney's f ~ n a party or attorney who (C) Electronlcof/y Stored /riformotfon Prodllctd In Only Ont Form. The fails to comply. penon responding need not produce the same elcctronicelly stored information in more than one form. (l) Command to Pratblce Materials or Puntlt l11Sptctllln. (D) lnact:essible Electronically Stored l,iformalion. The person (A) Appeqra,,a Not Rtqu;red A person commanded to produce responding need not provide discovery of electronically stored information documents, electronically stored infoJT11Stion, or tangible things, or to from sources that the person identifies as not reasonably accessible because pennit the inspec.tion of premises, need not appear in person at the place of of undue burden or cost. On motion to compel discovef}' or for a protective production or inspection unless also commanded to appear for a deposition, order, the person responding must show that the infonnation is not hearing. or trial. reasonably accessible because of undue burden or cost. tr that showing is (B) Obj«fiOIU. A person commanded to produce documents or tangible made, the court may nonetheless onler discovery from such sources if the things or to pennit inspection may serve on the party or attorney designated requesting party shows good c&IISe, considering the limitations of Rule in the subpo~• a written objection to inspecting, copying. testing. or 26(bX2XC). The court may specify conditions fur the discovery. sampling any or all of the materials or 10 inspecting the pmn~r IO producing electrOflically stored infonnation in the form or forms requested. (2) Qauning PrMJe,e or Proll!ction. The objection must be served before the earlier oflhe time specified for (A) Informat/oll WithMld. A person withholding subpoenaed information compliance or 14 days after the subpoena h, served. lfan objection is made; under a claim that it is privileged or subjec1 10 protection as trial-preparation the following rules apply: material must: (I) At any time, on notice to the commanded person, die serving party (i) expressly make the daim; and may move the cour1 for the district where compliance is ~uired for an (ii) d=ibc the nature of the withheld documents, communications, or OJder compelling prodlldion or inspection. tangible things in a manner that, without revealing information itself (ii) These acts may be reqtJired only as directed in the order, and the privileged or protected, will enable the parties to asses.~ the claim. order must protect a person who is neither a party nor a pa.r ty's officer fiom (B> Jnforma1ion Produced. If information produced in response: to a sig,,ificant expense resulting from compliance. subpoena is subject to a claim of privilege or of protection as trial-preparation material. the person mating the claim may ootify any perty (3) Qunst,ing ,,, Motflbin1 • Sllbpoeno. that received the infocmation of the claim and the basis for ii. After being notified, a par1y must promptly retum, scqUC$ter, or destroy the specified (A) When Required. On timely !ftOtion, the court for the district where lnfonnation and any copies it has; must not use or disclose the infonnation compliance is required must quash or modify a subpoena that: until tbe claim is molved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly (i) tails to allow a reasonable time to comply; present Ille infonnation under seal to the court for ,~e district where (ii) requires a person to comply beyond the geographical limits compliance is required for a detcnnination of the claim. The person who specified in Rule 45(c); produced the information n1uSI prtserve the information until the claim is (iii) requires disclosure of privileged or other protected matter, if no resolved. exception or waiver applies; or (iv) subjects a person 10 undue burden. (g) Coatempt. (B) When Permi11ed. To protect a person subject to or affected by a The cour1 for the district where compliance is required-and also, aller a subpoena, the court tor the district where compliance is required may, on motion is transferred, die issuing cour1-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 acce,;s to subpoena materials, see Fed K. C,v. P. 45(a) Comm11tec Note (2013).  Case 1:15-cv-07433-LAP Document 1331-35 Filed 01/05/24 Page 7 of 11 ATIACHMENT A DEFINITIONS 1. "Any'' means any and all. 2. "You" or "Your" means Sarah Ransome, and anyone acting on Your behalf, and any employee, agent, attorney, consultant, assignee, related entities or other representative of You. 3. "Agent'' shall mean any agent, employee, officer, director, attorney, independent contractor or any other person acting, or pwporting to act, at the discretion of or on behalf of another. 4. "Document" is intended to be defined as broadly as permitted by Rule 34 and includes every writing or record of every type and description that is or has been in Your possession, custody or control, or of which You have knowledge, including but not limited to, emails, text messages, instant messages, videotapes, photographs, notes, letters, memoranda, forms, books, magazines, resumes, notebooks, ledgers, journals, diaries, calendars, appointment books, papers, agreements, contracts, invoices, analyses, transcripts, plaques, correspondence, telegrams, drafts, data processing or computer diskettes and CD disks, tapes of any nature and computer interpretations thereof, instructions, announcements, and sound recordings of any nature. "Docwnent" also means all copies which are not identical to the original document as originally written, typed or otherwise prepared. The term "Document" shaU also include alJ documents of any nature that have been archived or placed in permanent or temporary storage including electronic storage. 5. "Communication" means any transmission or exchange of information between two or more persons, orally or in writing or otherwise, and includes, but is not limited to, any correspondence, conversation or discussion, whether face-to-face, or by means of telephone, email, text message, electronic message via apps such as Facebook, What's App, Snapchat, Linked.IN or similar, or other media or Documents. 6. "Virginia Ro eans Virginia Giuffre, formerly known as Virginia Roberts, date of birth the Plaintiff in the above captioned matter. 7. "Identify" means to specify as to a "Person," the name, address, telephone number and any other identifying information possessed by You. 8. "Person" means any natural person, individual, firm, partnership, association,joint venture, estate, trust, receiver, syndicate, enterprise or combination, corporation or other legal, business or government entity. 9. Regardless of the tense employed, all verbs should be read as applying to the past, present and future, as is necessary to make any paragraph more, rather than less, inclusive.  Case 1:15-cv-07433-LAP Document 1331-35 Filed 01/05/24 Page 8 of 11 I0. With respect to any Documents withheld on the basis of a privilege, provide a log consistent with Local Rule 26.2 of the Federal Rules of Civil Procedure for the Southern District of New York. INSTRUCTIONS I. Production of documents and items requested herein shaU be made to Laura Menninger, Haddon, Morgan & Foreman, PC, I SO E. I0th Ave., Denver, CO 80220, no later than February 13, 2017, at 9:00 a.m. Alternatively, you may provide the records electronically by that date and time to Laura Menninger at [email protected] or by such other method as agreed upon with counsel for the subpoenaing party. 2. 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. 3. If any Document was in your possession or control, but is no longer, state what disposition was made of said Docmnent, the reason for the disposition, and the date of such disposition. 4. 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. 5. Any copy of a Document that is not identical shall be considered a separate document 6. All Documents shall be produced in the same order as they are kept or maintained by you in the ordinary course of business. 7. Responsive electronically stored information (ESI) shall be produced in its native form; that is, in the form in which the information was customarily created, used and stored by the native application employed by the producing party in the ordinary course of business. 8. Defendant does not seek and does not require the production of multiple copies of identical Documents. 9. Unless otherwise specified, the time frame of this request is from 1999 to present. I 0. 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 Defendant. Case 1:15-cv-07433-LAP Document 1331-35 Filed 01/05/24 Page 9 of 11 DQCUMENTSTOBEPRQDUCED I. All Documents containing Communications with Virginia Roberts Giuffre, or any of her attorneys, agents, investigators, from the period 1999-present. 2. All fee agreements for Your engagements with any attorneys for the purpose of pursuing any civil or criminal claims regarding Jeffrey Epstein, Ghislaine Maxwell, Natalya Malyshov, Sarah Kellen, and Nadia Marcincova. 3. All Documents that reference, relate to, or mention, whether by name or otherwise, the following individuals: Virginia Roberts, Ghislaine Maxwell, Jeffiey Epstein, Natalya Malyshov, Sarah Kellen, and Nadia Marcincova. 4. All Communications You have had in whatever form with any other female who you ever witnessed at or in a property, home, business, plane or automobile other vehicle owned or controlled by Jeffrey Epstein. S. All Communications You have had with Natalya Malyshov, Virginia Roberts, Ghislaine Maxwell, Jeffrey Epstein, Sarah Kellen, or Nadia Marcincova. 6. Any photographs containing any image of Virginia Roberts, Ghislaine Maxwell, Jefliey Epstein, Natalya Malyshov, Sarah Kellen, or Nadia Marcincova. 7. Any photographs taken by You, or containing any image of You, at, in or near any home, business, private vehicle (including airplane), or any other property owned or controlled by Jeffrey Epstein. 8. Any photographs that depict any home, business, private vehicle (including airplane), or any other property owned or controlled by Jeffrey Epstein. 9. All of Your passports, travel visas, or pennissions to live, work or study in a foreign country, related to the years 2005-present. 10. All Communications regarding any of Your passports, visas, visa applications, or other permission to live, work or study in a foreign country, for the years 2005-present. 11. All Documents referencing any commercial plane tickets, boarding passes, or any other mode of travel during the time period 2006-2007. 12. Any credit card receipt, canceled check, or any other Document reflecting travel by You during the time period 2006-2007. 13. All phone records for any cellphone owned, used or possessed by You during the years 2006-2007. 14. All Docwnents reflecting or relating to any Communications between Jeffrey Epstein or Ghislaine Maxwell and either of Your parents, step-parents or other family members. Case 1:15-cv-07433-LAP Document 1331-35 Filed 01/05/24 Page 10 of 11 15. All Documents reflecting any money, payment, valuable consideration or other remuneration re.ceived by You from Jeffrey Epstein or any person known by You to be affiliated with Jeffrey Epst.ein. 16. All bank statements, credit card statements, money transfer records, or other statements from any financial institution in Your name, in whole or in part, for the years 2006-2007. 17. Any Docwnents concerning Your residency during the years 2006-2007, including leases, rental agreements, rent payments, deeds, or trusts. 18. A copy of Yo\D' current driver's license. 19. Any Document reflecting any of Your post-secondary training or educational degree or course of study, to include transcripts, payments for tuition, courses taken, dates of attendance and grades received. 20. Any application for college, university, or any other post-secondary institution, or technical college, fashion college, modeling training or any similar institution, submitted by You or on Your behalf during the years 200S - present. 21. All Docwnents reflecting any moneys received by You in exchange for any ..modeling" byYou. 22. All modeling contracts signed or entered into by You. 23. Any calendar, receipt, Communication or Document reflecting your whereabouts during the calendar years 2006-2007. 24. Any Documents reflecting Your medical, mental health or emergency care or other treatment for any eating disorder, malnourishment, kidney malfimction, emotional problems, psychological or psychiatric disorders, sexually transmitted diseases, and therapy records, and any prescriptions for any of the above categories. 25. Any Documents containing any Communications You have had with any law enforcement agency. 26. Any Documents that reflect any criminal charges, tickets, summonses, arrests, investigations concerning You or witnessed by You. 27. Any Documents containing any statement regarding Your experience or contact with Virginia Roberts, Ghislaine Maxwell, Jeffrey Epstein, Natalya Malyshov, Sarah Kellen, and Nadia Marcincova, including without limitation any Communication with anyone, any diary, jownal, email, letter, witness statement, and summary. 28. Any civil complaint or civil demand filed by You or on Your behalf by which You have ever sought damages or compensation of any form or nature. Case 1:15-cv-07433-LAP Document 1331-35 Filed 01/05/24 Page 11 of 11 29. A copy of Your most recent paycheck, paycheck stub, earnings statement and any bank statement, credit card statement and any Document reflecting any money owed by You to anyone. 30. A copy of your Facebook:, Instagram, Twitter, and any other social media application or program for the years 2006-2007 and from 2015 - present