Case Document Filed Page of Case Document Filed Page of Case Document Filed Page of AO Rev Subpoena to Testify al a Deposition in Civil Action UNITED STATES DISTRICT COURT for the Southern District of New York yirgi,:i1c Giuffrr Plain Civil Action No Ghislaine Maxwell Defendant SUBPOENA TO TESTIFY AT A Df POSJTiON fN A CIVIL ACTlON To JEFFRE:-Y EPSTEIN auk Tf J1 tfu fl Testimony YOU ARE COM:WANDED to appear at the time date and place set fcnih below to testify at a deposition to be taken in this civil action If you are an organization you musi 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 P1 tc Boi0s Schiller F!exner l.LP Lexinpton 260vonue NE:x1 York NY nu dl at a.m Productfon You or your representatives must also bring with you to the deposition the following documents electronicalJy stored information or objects and mu8l pcm1it inspection copying testing or sampling of the nwterial PLEASE SEE ATTACHED EXHIBIT A The Collowing provisions of Fed Civ are attached Rule relating to the place of compliance Rule relating to your protection as a person subject to a subpoena and Ruk and relating to your duty to respond to this subpoena and the potential consequences of not doing so Date CLERK OF COURT OR Signature ofC/e1 or Depriry Clerk The name address e--m-iil i,:l a and tdepbone r11m,bcr oC 1iic atlorn-"Y repn mting na11i 1lfmJ Y,i_ lif ia _Giuffre who ii,sn or requ sts this subpoena are Sigrid Mccawley BSF LLP Las Olas Blvd Ft Lauderdale FL mcc wley J-nl1k1.COlfl Notice to tile person who issues or rcquc,sts this subpoena If this subpoena commands the production of documents electronically stored infomrntion tangible things a notice and a copy of the suhpoena mmt be served on each pmty in this case before it is served on the person to whom it is directed Fed Civ a Case Document Filed Page of Case Document Filed Page of AO Rev Subpoena to TcRtify ata Deposition in Civil Action P,,ge Civil Action No PROOF OF SERVICE This seetion should 1wt he flied with the court unless required by Fed Civ I received this subpoena for name ofindilidual and title any on dMc I served the subpoena by delivering a copy to the named individual as follows on date I returned the subpoena unexecuted because or Unless the subpo ma wa8 issued on behalf of the Uriiled States or one of ifs 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 arc for travel and for services for a total ofS I declare under penalty ofpei ury that this information is trne Date Se1e1 signature Printed name and title Serve address Additional information regarding attempted service etc D?e e2 I ᇔ??G i a cpe Y??Ô A;?XWh ѽgz?E5?eN p?1P 䏾?D?K?Y ߢW?5Ue?t Z??Z a d)y?i Q?bM qJ rn?R Ќ?E?m W?hJl?D Ҏ47N eC?U b?6?yא 9a?ion Jm Z?_?"EO?tf i B??v p7?PE?o!u a?u!?!fj p?N?Ƃ x?a?3?UÂ 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s?T i տ??FO DQ5(ۑ p8h?C:?X?w PMqöv Jh??YfU E0 a?6K P?C 4Z c?g?hv f?T n?ZC i?ڢ J?RA?Z?0 B?ZPZ I??U ݰ?B o!O P!FN?9?m qX Lk?ߪ??m?Z?Q i??r??aW KwJ?Oj?Z r?jL??EV呧ڂ?g Sz?5G?Qi kϾ걢 8S dI葌 q?C ڷ?O ByfFˢ TR 6fj 9mg N;al pt?kTLv cI7ȃ W?n?K M?P?G 1d L??nL?n xu e_ k?"L mk 64FĒ?MN?Afiwo??(jM Js?Ĵ h?L wPS??x O?CY Case Document Filed Page of Case Document Filed Page of AO SSA Rev Subpoenn to Testify uta Deposition in uCivil Action Page Federal Rule of Civil Procedure and Effective PhH.r of Compliance For Trial Heari11g or Deposition A subpoena may command a pcrsm attend a lriHI hearing or deposition only as follows A within mil of whcrn the person resides is vmplovcd or regularly trnMacts 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 pijrtys officer or ii is conun nded lo attend a trial and would not incur substantial expense For Other Dlscovery A subpoena may command A production of documents electronically stored infom1atio11 or tangible things at a place within miles ofwl1erc the person resides is employed or regularly trnnsacts business in person und inspection of premises at the premises to be insl cle-d lrntccting a Person Subject to a Subpoena Enforcement I A oidi11g Ull Burdell or E.,pe11se Sa,ictiom A party llr ntlomey 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 sm1ction-which may include Jost earnings and reasonable allorn ys tees--on a party or attorney who fails to comply Command to Produce Materials or Permit fllspect/011 A Appearance Not Required A person commanded to produce documents electronically stored information or tangible things or to pem1il the inspection of premises need not appear in person al the place of production or inspection unless also comnrnnded appear for a deposition henring or trial Objections A perso11 commanded lo produce documents or tangible things or lo permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting copying testing or sHmpl i ng any or oJthe makria!s or to inspecting the premises-or to produ ing 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 suhpnena is served Jfan objection is made the following rules apply i At ony time on notice to the conunandcd person the erving party rnity move the court for rhc di.strict where complinnue is required for an order compelling production or inspection IIJ These acL may be reqtlircd only as directed in the order and the order must protect a person who is neither party nor a party officer from significant expense re ulling from ompliance Quaslting Mo//ifying tt S11bpoe11i1 A When Required timely motion the court for the district where compliance is required must quash or modif a subpoena that i foils to allow a reasonable time to comply ii requires a person to comply beyond the geogrnphical limits specified in Rule i requires disclosure of privileged or other protected matter if no exception or waiver applies or i sul iects a person to undtw burden When Permitled To protect a person subject to or affected by mbpoena the court for the district wlrnre compliance is re4uirc may on motion quash or modify the subpoena ifit juir i disclosing a trade secret or other confidential research development or commercial information nr ii disclosing an unretained expens opinion or information that does not describe specific occurrences in dispute and results trom the expet1s study that wos nol requested by a party Specifying Conditions as cm Altemat/ve In the circumstances described in Rt1le the court may instead of quashing or modifying a subpoena order appearance or production under specified conditions if the serving party i shows a snhstantial need for the testimony or material that cannot be otherwise met without undue hardship und ii ensures rhatthc subpoenaed person will be reasonably compensated Duties in Responding to Subpoena Ptod11ci11g Documents or Electro11ic11lly Stored J11Jormatlo11 These procedures apply to producing documents or electronically stored infnrmalion A Doc1e1s A person responding to a subpoena produce documents must produce them as 1l1cy are kept in the ordinary course of business or 1st organize and label them to correspond to the categories in the demand Form for Producing El ronit;a//yS1ored informal/on Not Specfjie,;I If a subpoena does not specify a fom1 for producing electronically stored informnlion the person responding must produce it in a form or forms in which it is ordinarily maintained or in reasonably usable form or forms E/ectronicolly Stored i1ifom1otio11 Produced in Only One Form The pernDn responding need not produce the same eleclnmically stored information in more than one form Inaccessible Electronica Stored I11Jormatic1 The person responding need not provide discovery of electmnical!y stored information from sources that the person identifies as not reasonably ccessiblc because of undue burden or cost On motion lo compel discovery or for a protective order the person responding must show that the information is not reasonably cssiblc because of undue hurdeu or cost lfthat 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 PrMfege or Jrotect/011 A lnformation Hilhheld A person withholding subpoenaed informu!ion under ii claim that it is privileged or subject to protection as triul-pieparation material muse expressly mak the claim and il describe the mnurc of the withheld documents communications or tangible l11ings in a munner that without revealing information itself privileged or protected will enable the parties to assess U1e claim Information Produced If information produced in response to a subpoena is subject to a claim of privilege or of protection iis trial-preparation nrnterial the person making the claim may notify any party that received the infonnation of the claim and the basis for it After being notified a party must promptly return queswr or destroy the specified infoJmation und any cnpfr il ltus must not use or disclose the infonnation until the claim is re.solved must take reasonable steps to retrieve the infonualion if the pa1ty disclosed ii before being notified and may promptly present the information under se11I lo the court for the district where compliance is required for a determination ofthc claim The person who produced the infonnalion mt1st preserve the information unlil the claim is resolved Co11tem1lt The court for the district wl1ere e11mpliance is required-and also after motion is transferred the issuing court-may hold in contempt person who having been served foils without udequ11te excuse lo obey lltc subpoena or 1m order rcluted to ii For ac,,css to subpoena materials ice Fed Civ a Committee Note Case Document Filed Page of Case Document Filed Page of Jeffrey Epstein EXUHHT A l-t!JTIO NS Wherever they hereafter appear the following words and phrases have the following meanings Agent shall mean any agent employee officer dilector attomey independent contractor or any other petson acting or purporting to act at the discretion of or on behalf of another Correspondence or communlcation 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 ston;:d 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 othenvise face-to-face by telephone Lelecopies e-mail text modem transmission computer generated message mail personal delivery or otherwise Plaintiff in the above captioned action shall mean the plaintiff Virginia Giuffre formerly known as Virginia Roberts Defendant in the above captioned action shall mean the defendant Ghislaine Maxwell and her employees representatives or agents Document shall mean all written and graphic matter however produced or reproduced and each and every thing from which information can be processed transcribed transmitted restored recorded or memorialized in any vay by any means regardle-ss of technology or form It inc.ludes without limitation correspondence memoranda notes notations diaries papers books accounts newspaper and magazine articles advertisements photographs videos notebooks ledgers letters_ telegrams cables telex messages facsimiles Case Document Filed Page of Case Document Filed Page of Jeffrey Epstein EXTUHlLl contracts offers agreements reports objects tangible things work papers transcripts minutes reports and recordings of telephone or other conversations or communic.ations or of interviews or conferences or of other meetings_ occurrences or transactions affidavits statements summaries opinions tests experiments analysis evaluations journals balance sheets income statements statistical records desk calendars appointment books lists tabulations sound recordings data processing input or output microfilms checks statements receipts summaries computer printouts computer programs text messages e-mails information kept in computer hard drives other computer drives of any kind computer tape back-up CD-ROM other computer disks of any kind teletypes telecopics invoices worksheets printed matter of every kind and dcsniption grnphic and oral records and representations of any kind and electronic writings and recordings as set fcHth in the Federal Rules of Evidence including but not limited to originals or copies where originals are not avriilable Any Document with any marks such as initials comments or notations of any kind of not deemed to be identical with one without such marks and is produced as a separate Document Where there is any question about whether a tangible item otherwise described in these requests falls within the definition of Document such tangible item shall be produced Employee includes a past or present officer_ director agent or servant including any attorney associate or pa1incr or paralegal Including means including without limitation Jeffrey Epstein includes Jeffrey Epstein and any entities owned or contnilled by Jeffrey Epstein any employee agent attorney consultant or representative of Jeffrey Epstein Case Document Filed Page of Case Document Filed Page of Jeffrey Epstein EXHrnITA 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 pmtncrships trusts joint ventures groups associations organizations or any other legal or business entity You or Your hereinafter means Jeffrey Epstein and any employee agent attorney consultant related entities or other representative ofJeffrey Epstein DSTRUCT1ONS Production of Documents and items requested herein shall be made at the offices of Boies Schiller Flexner LLP East Las Olas Boulevard Suite Fort Lauderdale Florida no later than five clnys before the date noticed for Your deposition or if an alternate date is agreed upon no later than five days before the agreed-upon date Unless indicated otherwise the Relevant Period for this Request is from lo the present A Document should be considered to be within the relevant time frame ifit refers or relates Lo communications meetings or other events or Documents that occurred or were created Vi thin 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 Ir any Document requested was in Your possession or control but is no longer in its possession or control state whnt disposition was made of said Document the reason for such disposition and the date of such disposition Case Document Filed Page of Case Document Filed Page of Jeffrey Epstein 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 tbe following a Wherever appropriate herein the singular form of a word shall be interpreted as plural and vice versa And as well as or slwll be construed either disjunctively or cmtjunc.tively 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 lfthc recipient has no Documents responsive to a pa1iicular Request the recipient shall so state Unless instructed otherwise each Request shall be construed independen1ly and not by reference to any other Request for the purpose of limitation The vords relate relating relates or any other derivative thereot as used herein includes concerning referring to responding to relating to pertaining to connected with comprising memorializing evidencing commenting on regarding discussing showing describing reflecting analyzing constituting Identify means with respectto any person or any reference to the identity of any 267person to provide the name home address telephone number business name business Case Document Filed Page of Case Document Filed Page of Jeffrey Epstein EXHrnlT address business telephone number e-mail address and a description of each such persons c.onnection vith the events in question 267Identify means with lespect to any Document or any reference to stating the identification of any Doc.ument provide 1he title and date of each such Document the name and address of the parly or parties responsible for the preparation of each such Document the name and address of the party who requested or required the preparation and on whose behalf it was prepared the name and address of the recipient or recipients to each such Document and the present location of any and al I copies of each such Document a11d lhc names and addresses of all persons who have custody or control of each such Doeument or copies thereof In producing Documents if the original of any Document cannot be located a copy shall be produced in lieu thercot and shall be legihle 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 Documenl lfany requested Document cannot be produced in full produce the Document to the extent possible spccifYing e.ach 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 ff any Document requested was at any one time in existence but are no longer in existence then so state specifying for each Document a tbe type of Document the types of information contained thereon the dale upon which it ceased to exist the circumstances under which it ceased to exist the identity of all person having knowledge of the Case Document Filed Page of Case Document Filed Page of Jeffrey Epstdn circumstances under which it ceased to exist and the identity of all persons having know ledge or who had knmv ledge 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 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 wen found and business address of each Documents custodian If any Documcnl 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 vvas distributed if any tbc title or position of its author type of tangible object e.g Jetter 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 foll 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 Case Document Filed Page of Case Document Filed Page of Jeffrey Epstein lfany Document requested herein is withheld in all or part based on a claim that such Document constitutes attorney work product provide alJ of the information described in Instrnction No and also identity the litigation in connection with vhich 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 This Request is deemed to be continuing If after producing these Documen1s You obtain or become aware ot any further infonnation Documents things or information responsive to this Request You arc required to so stale by suppleimmling Your responses and producing such additional Documents ro Plaintiff Case Document Filed Page of Case Document Filed Page of Jeffrey Epstein FX.ilH!T DOCUMENTS TO B.E PIH Jl!;CED Pl Sl.JANT TO HS SUBPOENA All video tapes audio tapes photographs including film negatives or film slides CDs or any other print or electronic media depicting You in the presence of Virginia Roberts a/k/a Virginia Giuffre or Ghislaine 267Maxwell All video tapes audio tapes photographs including film negatives or film slides CDs or any other print or electronic media depicting Virginia Roberts All video tapes audio tapes photographs including film negatives or film slides CDs or any other print or electronic media depicting Ghislaine Maxwell All video tapes audio tapes phoJ-01:,,-raphs including film negatives or film slides CDs or any other print or electronic media depicting females under the age of or purporting to be under the age of including pornographic media whether commercial or amatem All Documents or other media includng photographs describing or depicting nude or paitially nude females in Your possession including but not limited to all Documents or other media describing or depicting how such photographs were displayed in Your various residences All Documents relating to Virginia Roberts All Documents relating to jhislaine Maxwell including all Documents related to communications with Ghisluine Iaxwel from present All Documents relating to any members of Ghislaine Max,vell.s family including all Documents related to communications vith any members of Ghislaine Maxwells family from present All Doc;uments related to communications with Alan Dcrshowitz from present Case Document Filed Page of Case Document Filed Page of Jeffrey Epstein t;xmmTA All Documents relating to and all media depicting any of the following individuals from present Emmy Taylor Eva Dubin Glen Dubin Alan Dershowitz Jean Luc Brunel Sarah Kellen a/k/a Sara Kensington and Sarah Vickers Nadia Marcinkova a/k/a Nadia Marcinko Nadia Bjorlin or any females under the age of All Documents relating to any agreements including by not limited to confidentiality agreements imlemni1kation agreements employment agreements or agreements to pay legal foes between You Ghislaine Maxwell whether such agreements arc written verbal or merely understood among the parties and not otherwise expressed whether or not such agreements wefe ever executed or carried out Documents relating to any credit cards paid for by You that were used by Ghislaine Maxwell or any related entity or Virginia Giuffre from present All telephone records associated with You including cell phone records from present that show any communications with Ghislaine Maxwell All Documents relating to calendars schedules or appointments for You from present that relate to visits with or communications with Ghislaine Maxwell and females under the age of All Documents identifying any individuals who provided You a massage All Documents identitying any individuals who You paid for sexual acts either with You or with other individuals All Documents identifying any females recru.ited by Ghislaine Maxwel1 for either work sexual acts or companionship for You All Documents relating to any females Ghislaine Maxwell introduced to You A Documents relating 1o any females You paid to perform any kind of service Case Document Filed Page of case Document Filed Page of Jeffrey Epstein EXHrnrr A including but not limited to work as an assistant a massage therapist sex worker or companion All Documents relating to Your travel from the period of present when that travel was either with Ghislaine Maxwell or another female or to med Ghislaine Maxwell or other females including but not limited to commercial flights helicopters passport records records indicating passengers traveling with You hotel records and credit card receipts I All Documents relating lo payments You made whether as cash stock real estate or in-kind to Ghislaine Max vell or any related entity to Ghislaine Maxwell including the TerraMar Project All Documents identifying any individuals to whom Virginia Roberts provided a nmssage
