Case Document Entered on FLSD Docket Page of UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CIV MARRA/JOHNSON JANE DOE Plaintiff vs JEFFREY EPSTEIN Defendant __ NOTICE OF TAKING VIDEOTAPED DEPOSITION PLEASE TAKE NOTICE that the Plaintiff JANE DOE will take the deposition of Jean Luc Bruhel on Tuesday September at a.m at Esquire Court Reporters One Penn Plaza Suite New York NY The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure and shall continue day to day weekends and holidays excepted until completed I HEREBY CERTIFY that a true and correct copy of the foregoing has been served by U.S Mail and email transmission this t/!aay of August to all those on the attached Service List Case Document Entered on FLSD Docket Page of cc Esquire Court Reporters ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff East Las Olas Blvd Suite Fort Lauderdale Florida Tel Fax Email bedwards rra-law.com SQ By Florida Bar No Case Document Entered on FLSD Docket Page of AO SSA Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action UNITED STATES DISTRICT COURT JANE DOE Plaintiff JEFFREY EPSTEIN Defendant for the Southern District of Florida Civil Action No 08-90893CIV-MARRA/JOHNSO If the action is pending in another district state where SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION To Jean Luc Bruhel 66th Street New York NY I Testimony YOU ARE COMMANDED to appear at the time date and place set forth below to testify at a deposition to be take.i in this civil action If you are an organization that is not a party in this case 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 Esquire Court Reporters One Penn Plaza Suite New York NY The deposition will be recorded by this method Date and Time am Production You or your representatives must also bring with you to the deposition the following documents electronically stored infonnation or objects and permit their inspection copying testing or sampling of the material The provisions of Ped Civ relating to your protection as a person subject to a subpoena and Rule and relating to your duty to respond to this subpoena and the potential consequences of not doing so are attached Date CLERK OF COURT OR Signature a/Clerk or Deputy Clerk Attorneys signature The name address e-mail and telephone number of the attorney representing name of party who issues or requests this subpoena are Brad Edwards Esq Rothstein Rosenfeldt Adler Las Olas Blvd Suite Fort Lauderdale Florida Bedwards rra-law.com Case Document Entered on FLSD Docket Page of AO Rev Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action Page Civil Action No 08-90893CIV-MARRAIJOHNSO PROOF OF SERVICE This section should not be filed with the court unless required by Fed Civ This subpoena for name of individual and title if any was received by me on date I personally served the subpoena on the individual at place on date I left the subpoena at the individuals residence or usual place of abode with name or a person of suitable age and discretion who resides there on date and mailed a copy to the individuals last known address or I served the subpoena on name of individual who is designated by law to accept service of process on behalf of name of organization on date or I returned the subpoena unexecuted because Other specify 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 fees for one days attendance and the mileage allowed by law in the amount of My fees are for travel and for services for a total of I declare under penalty of perjury that this information is true Date Servers signature Printed name and title Servers address Additional information regarding attempted service etc or Case Document Entered on FLSD Docket Page of AO Rev Subpoena to Testify at a Deposition or to Produce Documents in a Civi Action Page Federal Rule of Civil Procedure and Effective Protecting a Person Subject to a Subpoena Avoiding Undue Burden or Expense Sanctions A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena The issuing court must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorneys fees on a party or attorney who fails to comply Command to Produce Materials or Perl1Ut Inspection A Appearance Not Required A person commanded to produce documents electronically stored information or tangible things or to permit the inspection of premises need not appear in person at the place of production or inspection unless also commanded to appear for a deposition hearing or trial Objections A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting copying testing or sampling any or all of the materials or to inspecting the premises or to producing electronically stored information in the form or forms requested The objection must be served before the earlier of the time specified for compliance or days after the subpoena is served If an objection is made the following rules apply i At any time on notice to the commanded person the serving party may move the issuing comt for an order compelling production or inspection ii These acts may be required only as directed in the order and the order must protect a person who is neither a party nor a partys officer from significant expense resulting from compliance Quashing or Modifying a Subpoena A When Required On timely motion the issuing court must quash or modify a subpoena that i fails to allow a reasonable time to comply ii requires a person is neither a party nor a partys officer to travel more than I miles from where that person resides is employed or regularly transacts business in person except that subject to Rule i the person may be commanded to attend a trial by traveling from any such place within the state where the trial is held i requires disclosure of privileged or other protected matter if no exception or waiver applies or iv subjects a person to undue burden When Permitted To protect a person subject to or affected by a subpoena the issuing court may on motion quash or modify the subpoena if it requires i disclosing a trade secret or other confidential research development or commercial infonnation ii disclosing an unretained experts opinion or information that does not describe specific occurrences in dispute and results from the experts study that was not requested by a party or i a person who is neither a party nor a partys officer to incur substantial expense to travel more than miles to attend trial Specifying Conditions as an Alternative In the circumstances described in Rule the court may instead of quashing or modifying a subpoena order appearance or production under specified conditions if the serving party i shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship and ii ensures that the subpoenaed person will be reasonably compensated Duties in Responding to a Subpoena Producing Documents or Electronically Stored Information These procedures apply producing documents or electronically stored information 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 must organize and label them to correspond to the categories in the demand Form for Producing Electronically Stored Information Not Specified If a subpoena does not specify a form for producing electronically stored information the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms Electronically Stored Information Produced in Only One Form The person responding need not produce the same electronically stored information in more than one form Inaccessible Electronically Stored Information The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost On motion to compel discovery or for a protective order the person responding must show that the information is not reasonably accessible because of undue burden or cost If that showing is made the court may nonetheless order discovery from such sources if the requesting party shows good cause considering the limitations of Rule The court may specify conditions for the discovery Claiming Privilege or Protection A Information Withheld A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must i expressly make the claim and ii describe the nature of the withheld documents communications or tangible things in a manner that without revealing information itself privileged or protected will enable the parties to assess the claim Information Produced If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial preparation material the person making the claim may notify any party 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 infonnation and any copies it has must not use or disclose the information until the claim is resolved must take reasonable steps to retrieve the information if the party disclosed it before being notified and may promptly present the information to the court under seal for a determination of the claim The person who produced the information must preserve the information until the claim is resolved Contempt The issuing court may hold in contempt a person who having been served fails without adequate excuse to obey the subpoena A nonpartys failure to obey must be excused if the subpoena purports to require the nonparty to attend or produce at a place outside the limits ofRule A ii
10,309 characters
