Case Document Filed Page of EXHIBIT Case Document Filed Page of AO Rev Subpoena to Testify at a Deposition in a Civil Action UNITED STATES DISTRICT COURT for the Southern District ofNew York Virginia Giuffre Plaintiff Civil Action No Ghislaine Maxwell Defendant SUBPOENA TO TESTIFY AT A DEPOSITION IN A CIVIL ACTION To RINALDO RIZZO c/o Robert Lewis Freeman Lewis LLP 45th Street 17th Floor New York NY Name of person to whom this subpoena is directed Testimony YOU ARE COMMANDED to appear at the time a te and place set forth below to stify at a deposition to be taken in this civil action If ou are an or aniz a tion you must designate one or more officers di ect rs or managing agents or designate other persons who consent to testify on your behalf ab ut the following matters or those set forth in an attachm nt PLEASE SEE ATTACHED EXHIBIT A Place Boies Schiller Flexner LLP Main Street Armonk NY Date and Time a The deposition wi11 be recorded by this method te g,_ra p_h.e.y Production You or your rep esentatives must also bring with you to the deposition the following docum nts electronically stored information or objects and must permit inspection copying testing or sampling of the material The following provisions of Fed Civ are attached Rule relating to the place of ompliance Rule relating to your protection as a person subject to a subpoena and Rule and rel a ting your duty to respond to this subpoena and the po ential consequences of not doing so Date CLERK CO URT OR Signature of Clerk or Deputy Clerk Attorn ys sig ature The name address e-mail address and telephone number the a ttorney repre enting a party Virginia Giuffre wh issues or re ue hi subpoena are Sigrid McCawley BSF LLP Las Olas Blvd Ft Lauderdale FL smccawley bsfllp.com Notice to the person who issues or reques this subpoena If his subpoen a mm an the pr duction of oc uments ele tronically stored information or tangible thin a notice and a cop of the subpoena must be erved on eac party in this as efo it is served on the rson to whom it is directed Fed Civ a Case Document Filed Page of AO SSA Rev Subpoena to Testify at a Deposition in a Civil Action Page Civil Action No PROOF OF SERVICE This section should not be filed with the court unless required by Fed Civ I received this subpoena for name of individual and title if any a te I served the subpoena by delivering a copy to the named individual as follows on date or 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 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 infonnation is true Date Server signature Printed name and title SelVer address Additional information regarding attempted service etc Case Document Filed Page of AO Rev Subpoena to Testily at a Deposition in a Civil Action Page Federal Rule of Civil Procedure and Effective Place ofComplhmce For a Trial Hearing or Deposition A subpoena may command a person to attend a trial hearing or deposition only as follows A within I miles of where the person resides is employed or regularly transacts business in person or within the state where the person resides is employed or regularly transacts business in person if the person i is a party or a partys officer or ii is commanded to attend a trial and would not incur substantial expense For Other Discovery A subpoena may command A production of documents electronically stored infonnation or tangible things at a place within miles of where the person resides is employed or regularly transacts business in person and inspection of premises at the premises lo be inspected Protecting a Person Subject to a Subpoena Enforcement Ai 225oidlng 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 court for the district where compliance is required must enforce this duty and impose an appropriate sanction-which may include lost eamings and reasonable attorneys a party or altomey who fails to comply Command to Produce Materials ar Permit Inspection A Appearance Not Required A person commanded to produce documents electronically stored infonnation or tangible things or to pennit the inspection of premise 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 fonns 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 court for the district where compliance is required for an order compelling production or inspection ii TI1ese acts may be required only as directed in the ordt.T and the order must protect a person who is neither a party nor a partys officer from significant expense resulting from compliance Q11ashlng or Modifying a Subpoena A When Requir On timely motion th court for the district where compliance is required must quash or modify a subpoena that i fails to allow a reasonable time to comply ii requires a person to comply beyond the geographical limits specified in Rule i requires disclosure of privileged or other protected matter if no exception or waiver appli or iv subject a person to undue burden When Permitted To protect a person subject to or affected by a subpoena the court for the is trict where compliance is required may on motion quash or modify the subpoena if it require i disclosing a trade secret or other confidential research development or commercial infonnation or ii disclosing an unretained experts opinion or informat i on that oes not describe specific occurrences in dispute and results from the experts study that was not requested by a party 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 spec i fied 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 Pro,l11c/11g Doc11ments or Electronically Stored Information These procedures apply to producing documents or ectronically st red infonuation 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/or Producing Electro ically Stored Information Not Specified If a subpoena does not specify a fonn for producing electronically stored infonnation the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable fom1 or fonns Electronically Stored Informal/on Produced In Only One Form The person responding need not produce the san1e electronically stored information in more than one fonn Inaccessible Electronically Stored Inf rmation The person responding need not provide discovery of electronically stored information from sou ces 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 i nfonnation 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 Gaiming Privilege or Protection A Information Withheld A person withholding subpo naed 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 withou revealing information itself privileged or protected will enable the parties to assess the claim lriformation Produced Ifinfonnation produced in response a subpoena is subject to a aim of privilege or of protection as trial-p eparation material the pe son aking the claim may notify an 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 information 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 infonnation under al to the court for the district where compliance is required for a determination of the claim 1e erson who produced the infonnation must preserve th information unti the claim i resolved Contempt The court for th district where compliance is quired-and also after a motion is transferred the issuing court may ho in contempt a rson who having been rved fails without adequa ex use to be the subpoena or an order related to it For access to subpoena materials see Fed Civ a Committee No Case Document Filed Page of To Rinaldo Rizzo EXIDBIT A DEFINITIONS Wherever they hereafter appear the following words and phrases have the following meanings Agent shall mean any agent employee officer director attorney independent contractor or any other person acting or purporting to act at the discretion of or on behalf of another Correspondence or communication shall mean all written or verbal communications by any and all methods including without limitation letters memoranda and/or electronic mail by which information in whatever form is stored transmitted or received and includes every manner or means of disclosure transfer or exchange and every disclosure transfer or exchange of information whether orally or by document or otherwise face-to-face by telephone telecopies e-mail text modem transmission computer generated message mail personal delivery or otherwise Defendant shall mean the defendant Ghislaine Maxwell and her employees representatives or agents Document incorporates the definition as set forth in Rule Southern District of New York Local Rules and therefore is defined to be synonymous in meaning and equal in scope to the usage of the term documents or electronically stored information in Fed Civ a A A draft or non-identical copy is a separate document within the meaning of this term Employee includes a past or present officer director agent or servant including any attorney associate or partner or paralegal Including means including without limitations Case Document Filed Page of To Rinaldo Rizzo Jeffrey Epstein includes Jeffrey Epstein and any entities owned or controlled by Jeffrey Epstein any employee agent attorney consultant or representative of Jeffrey Epstein Ghislaine Maxwell includes Ghislaine Maxwell and any entities owned or controlled by Ghislaine Maxwell any employee agent attorney consultant or representative of Ghislaine Maxwell Person includes natural persons proprietorships governmental agencies corporations partnerships trusts joint ventures groups associations organizations or any other legal or business entity You or Your hereinafter means Rinaldo Rizzo and any employee agent attorney consultant related entities or other representative of Rinaldo Rizzo INSTRUCTIONS I Unless indicated otherwise the Relevant Period for this Request is from to the present A Document should be considered to be within the relevant time frame if it refers or relates to communications meetings or other events or documents that occurred or were created within that time frame regardless of the date of creation of the responsive Document 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 If any Document requested was in any defendants possession or control but is no longer in its possession or control st a te what disposition was made of said Document the reason for such disposition and the date of such disposition For the purposes of reading interpreting or construing the scope of these requests the terms used shall be given their most expansive and inclusive interpretation This includes without limitation the following Case Document Filed Page of To Rinaldo Rizzo a Wherever appropriate herein the singular form of a word shall be interpreted as plural and vice versa And as well as or shall be construed either disjunctively or conjunctively as necessary to bring within the scope hereof any information as defined herein which might otherwise be construed to be outside the scope of this discovery request Any shall be understood to include and encompass all and vice versa Wherever appropriate herein the masculine form of a word shall be interpreted as feminine and vice versa Including shall mean including without limitation If You are unable to answer or respond fully to any document request answer or respond to the extent possible and specify the reasons for Your inability to answer or respond in full If the recipient has no documents responsive to a particular Request the recipient shall so state Unless instructed otherwise each Request shall be construed independently and not by reference to any other Request for the purpose of limitation The words concern concerning concerns or any other derivative thereof as used herein is defined as meaning relating to referring to describing evidencing or constituting under Rule Southern District of New York Local Civil Rules ldentify with respect to persons incorporates the definition as set forth in Rule Southern District of New York Local Rules Therefore when referring to a person to identify means to give to the extent known the persons full name present or last known address and when referring to a natural person additionally the present or last known place of employment Identify with respect to documents incorporates the definition as set forth in Rule Southern District of New York Local Rules Therefore when referring to Case Document Filed Page of To Rinaldo Rizzo documents to identify means to give to the extent known the i type of documents ii general subject matter i date of the documents and iv author addressee and recipient In the alternative the responding party may produce the documents together with identifying information sufficient to satisfy Fed Civ 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 Any copy of a Document that is not identical shall be considered a separate document If any requested Document cannot be produced in full produce the Document to the extent possible specifying each reason for Your inability to produce the remainder of the Document stating whatever information knowledge or belief which You have concerning the portion not produced If any Document requested was at any one time in existence but are no longer in existence then so state specifying for each Document a the type of document the types of information contained thereon the date upon which it ceased to exist the circumstances under which it ceased to exist the identity of all person having knowledge of the circumstances under which it ceased to exist and the identity of all persons having knowledge or who had knowledge of the contents thereof and each individuals address All Documents shall be produced in the same order as they are kept or maintained by You in the ordinary course of business You are requested to produce all drafts and notes whether typed handwritten or otherwise made or prepared in connection with the requested Documents whether or not used Case Document Filed Page of To Rinaldo Rizzo Documents attached to each other shall not be separated Documents shall be produced in such fashion as to identify the department branch or office in whose possession they were located and where applicable the natural person in whose possession they were found and business address of each Documents custodian If any Document responsive to the request is withheld in all or part based upon any claim of privilege or protection whether based on statute or otherwise state separately for each Document in addition to any other information requested a the specific request which calls for the production the nature of the privilege claimed its date the name and address of each author the name and address of each of the addresses and/or individual to whom the Document was distributed if any the title or position of its author type of tangible object e.g letter memorandum telegram chart report recording disk etc its title and subject matter without revealing the information as to which the privilege is claimed i with sufficient specificity to permit the Court to make full determination as to whether the claim of privilege is valid each and every fact or basis on which You claim such privilege and whether the document contained an attachment and to the extent You are claiming a privilege as to the attachment a separate log entry addressing that privilege claim If any Document requested herein is withheld in all or part based on a claim that such Document constitutes attorney work product provide all of the information described in Instruction No and also identify the litigation in connection with which the Document and the information it contains was obtained and/or prepared Plaintiff does not seek and does not require the production of multiple copies of identical Documents Case Document Filed Page of To Rinaldo Rizzo This Request is deemed to be continuing If after producing these Documents You obtain or become aware of any further information Documents things or infonnation responsive to this Request You are required to so state by supplementing Your responses and producing such additional Documents to Plaintiff Case Document Filed Page of To Rinaldo Rizzo DOCUMENTS TO BE PRODUCED PURSUANT TO TIDS SUBPOENA All documents concerning Jeffrey Epstein from present All documents concerning Ghislaine Maxwell from present All documents concerning or describing any work you performed with Jeffrey Epstein Ghislaine Maxwell or any affiliated entity from present All video tapes audio tapes photographs or any other print or electronic media concerning Jeffrey Epstein or Ghislaine Maxwell All documents concerning calendars schedules or appointments for you from present that relate to visits with or communications with either Jeffrey Epstein or Ghislaine Maxwell All documents concerning any females that you know who provided massages or interacted with Jeffrey Epstein All documents concerning any females that you know who provided massages or interacted with Ghislaine Maxwell All documents concerning Jeffrey Epstein or Ghislaine Maxwells interactions with females
