Electronically Filed Pa8tljlofM A year after Rothstein many questions unanswered South Florida Business Journal From the South Florida Business Journal ln.html SUBSCRIBER CONTENT Oct EDT Page of A year after Rothstein many questions unanswered Paul Brinkmann Its been a year since South Florida learned that Scott Rothstein was a Ponzi schemer and not just an eccentric flashy attorney Rothsteins victims are just starting to recover Charities still have gaping holes in their budgets and law firms are still pecking over the carcass of his former law firm Rothstein Rosenfeldt Adler in bankruptcy court The Florida Bar found no cause to investigate former RRA attorneys and only three cases remain open Federal authorities moved relatively quickly to indict Rothstein on Dec after a period during which he helped them bring down reputed mafia members However federal prosecutors have only indicted two people related to the scheme Rothstein and his firms COO Debra Villegas Rude awakening Like a fairy tale gone bad Rothsteins rags-to-riches story proved to be an Illusion noteworthy even by South Florida standards For four years Rothstein grinned and glad-handed his way onto billboards and society pages He threw money around like candy at a parade He got a former judge an ex-mayor and a felonious former sheriff to work for him But quicker than his meteoric rise Rothstein was suddenly gone one day to Morocco The money was gone too in a billion Ponzi scheme That was Oct He returned to Florida on Nov For a month Rothstein was seen In various spots around town apparently oblivious promising to pay people back The story trickled out about how lurid Rothstein was including allegations of blackmailing n.html?s print A year after Rothstein many questions unanswered South Florida Business Journal Page of people to invest in his phony lawsuit settlements Finally on Dec Rothstein was handcuffed and charged At the time Daniel Auer IRS special agent in charge promised We will continue to move forward with this investigation wherever it leads and we will bring to justice those who defrauded the American public and members of our community out of their hard-eamed money A year later the government has taken its time In fulfilling that promise Rothstein told the South Florida Sun-Sentinel in November that Fort Lauderdale was a town full of thieves Federal investigation Rothstein was sentenced to years in prison on June Authorities charged Villegas on April she pleaded guilty and was sentenced Oct to years Their sentencing judges U.S District Judges James I Cohn and William Ziech noted that Rothstein and Villegas would have further sentencing reductions If they continue cooperating with authorities John Gillies FBI special agent in charge for Miami summed up Villegas crime with these words She chose greed over her integrity Cohn ruled Aug that about victims were entitled to million in restitution although only million to million is available A select list of non-investor clients was made completely whole At the end of October people close to the Rothstein investigations were predicting more arrests were imminent For the first year the government apparently wanted to move slowly said William Scherer an attorney representing investors in a million lawsuit It has seemed like five years worth of news in one year Bankruptcy case Rothsteins law partner Stuart Rosenfeldt tried to put the firm into a state court receivership the day after Halloween But several Rothstein victims soon petitioned for a bankruptcy court filing In bankruptcy court attorneys for trustee Herbert Stettin have sued dozens of people to recover money in civil claims 225edition/20 I 0/10/22/rothstein.html?s print A year after Rothstein many questions unanswered South Florida Business Journal Page of Rothsteins biggest feeder George Levin agreed to settle claims against him by turning In assets valued at up to million Auto dealership owner Ed Morse another Rothstein chum settled for million Stettin and attorneys in the RRA bankruptcy including Miami-based Berger Singerman often clashed with federal authorities over the firms assets Cohn has granted the bankruptcy estate custody of RRAs former bank accounts but federal authorities marshaled other assets including boats and houses Investor lawsuit The Rothstein investor lawsuit could be the largest such lawsuit in Broward County history at pages with more than two dozen plaintiffs and two dozen defendants The big targets are TD Bank and Gibraltar Private Bank Trust banks that handled Rothsteins money but have denied knowing it was dirty The investor lawsuit handled by Scherer is just starting to schedule depositions of key witnesses TD Banks attorneys have sought more time to depose witnesses and ask questions of the plaintiffs So far Judge Jeffrey Streitfeld has declined to put limits on depositions On Oct the federal Office of Thrift Supervision slapped Gibraltar with a cease and desist order for weak money laundering controls The bank has declined to comment on whether the order is related to the Rothstein scandal but is operating under restrictions on how it accepts deposits and compensates officers Florida Bar takes little action The Florida Bar has taken relatively little action in response to one of the biggest crises in its history Last November Rothstein agreed to disbarment on consent Bar President Jesse Diner issued a statement at the time saying the Rothstein scandal was a terribly unfortunate and tragic situation but it is also a rare circumstance In the legal profession At the time Diner said the Bar would continue to investigate any violations of Its rules by other attorneys who may have been involved In this case The Bar originally opened investigations into former RRA attorneys At the end of June it announced that of those cases were closed When asked by the Business Joumalfor an update on Oct the Bar said only three of those cases remain open Rosenfeldt Russell Adler and Steven Lippman Rosenfeldt is also fighting a million claim in the bankruptcy case Where is Rothstein in.html print A year after Rothstein many questions unanswered South Florida Business Journal Page4 of4 Few people know where Rothstein is except that he Is supposed to be In federal prison His name does not come up in a public website search for prisoners names because he is still cooperating with federal investigators Rothstein professed remorse in court but that had little effect on his sentence In a June letter to Cohn Rothstein wrote I do not really possess the words to adequately explain the magnitude of what I have done why I did It and the overwhelming remorse and self-loathing I feel about myself and the intense harm and pain I have inflicted upon Innocent people Whether South Floridians have changed their reaction to Rothstein-type personalities in business remains to be seen I think people are being more careful with flamboyant personalities particularly charities and investors Scherer said We saw that Rothstein could buy political good will and stature But there have always been frauds and there will always be pbrlnkmann bizjournals.com I I 0/22/rothstein.html?s print Page of Home I News Broward Palm Beach I Sports Entertainment Trave Li1 Opinion I Video Home Collections Florida Bar Ads By Google Shocking Language Video If you dont know Spanish and you want to_ you should click here to see this short video_ Watch Video AdOIOiceaO FIND OUR BEST FA.RES NOW jetBtif:9 Florida Bar looking at forme from Rothsteins firm January I By Amy Shannan and Jay Weaver The Miami I The Florida Bar is investigating at least former senior firm headed by Scott Rothstein who was disbarred before using the firm to run a billion Investment racket The Bar confirmed to The Miami Herald on Wednesday th the former firm Rothstein Rosenfeldt Adler lied about and whether they stole any of it Ads By_ oogle Local Breast Cancer Walk Making Strides Breast Cancer Walk Help Sav MakingStridesWalk.org Related Articles State Bar Investigates From Rothstein Firm November Scott Rothstein scandal One year later November Judge Warns Of distressing News In Scott Rothstein Law November Were Rothsteins Associates Blinded By His Star Power November Find More Stories About Florida Bar Page of3 Rothstein Is scheduled to plead guilty Jan to federal charges stemming from his massive Ponzi scheme which funds Several of Rothsteins former partners have said they wer law firm to sell bogus legal settlements to wealthy lnvesto without mentioning names have said that some of the la culpability The Florida Bar board of govemors and its president Je Rothstein in early November when word of the scandal bri pursue the probe into the other lawyers The Bar takes this issue very seriously Diner a Fort La actively investigating and will pursue remedies against an investigation didnt stop with Scott Rothstein This is a terrible thing that has happened to the legal prol the profession and the public to fully investigate this thing Diner said that Bar investigators will first determine wheth made any false representations to the Bar when they certi annually certify such accounts which are used to hold clie memberships He also said Bar Investigators will detennlne whether any misappropriated money from client trust accounts as Re admitted doing when he agreed to be disbarred voluntaril Diner said the Bar which plays the role of a regulatory pre punishment ranging from a public reprimand to suspensio According to the federal criminal charges Rothstein ralde finn held at Toronto Dominion Bank In Broward County The Bar Initially disclosed in November that it was lnvesti fall name partners Stuart Rosenfeldt and Russell Adler a general counsel David Boden Ads By Google Anidjar Levine Law Firm So Florida Lawyers Specializing in Personal Injury Cas southfloridainjurylaw com/Lawyers Dell Latitude Laptop Dont Forget to Shop Scalable Dell Latitude Laptops w.dell.com/Latitude But additional attorneys have received letters from the Bai Investigation said Howard Greitzer a Fort Lauderdale att Meanwhile Rothstein appeared in federal court Wednesd who worked at his firm has no conflicts of Interest in repn his upcoming guilty plea cannot be appealed Index by Keyword Terms o1 Service Page of3 Prosecutors have said that Nurik Is not under criminal lnvE li fi Privacy Policy I Criminal Defense Lawyer Please note the en-lined lir IKI arlicle lt1XI has been applied commercially whhoui any rnvolvernent from our newsroom editors reporters or any other e!Jllorial slHII Aggressive Criminal Defense I Free Consultation w.palmbeachcountydefense.com Featured Articles must-see places to visit in Florida MORE i _f lRj ttii Use your own iPho1 Walmarts Straight unlimited plan Low white blood cell count not always a sign of LH medical problem mi Fort Lauderdale accepting Section applications Ts How to recognize and treat a spider bite Ar OE This Just In I Sun Sentinel Blogs I former Scott Rothstein attorneys cleared by The Flor Page I of SunSentinel.com ljJ Home Broward County Palm Beach County Weather Sports Business Entertainment Consumer Cla I Lifestyle I Food I Green Living I Home Garden I Fashion I Travel I Kim Rothstein wants some of her bling back I Main I Scott Rothstein partner Stuart Rosenfeldt testifies under oath former Scott Rothstein attorri,eys cleare by The Fle id Ba By Peter Franceschina Sun Sentinel Posted by Admin at PM The Florida Bar has cleared former attorneys who worked at the Rothstein Rosenfeldt Adler law firm of any wrongdoing during the time Ponzi schemer Scott Rothstein was running a massive billion fraud scheme The Bar recently sent out letters notifying the cleared attorneys that a grievance committee found no probable cause of any wrongdoing Fourteen other attorneys including name partners Stuart Rosenfeldt and Russell Adler remain under investigation according to Bar spokeswoman Karen Kirksey The cases involving those attorneys have not yet been heard by the grievance committee The Bar is investigating whether any of the firms top lawyers were involved In any trust account irregularities at the firm Rothstein ran his fraud scheme using the now-bankrupt firms trust accounts Bankruptcy records show hundreds of millions of dollars flowing in and out of those accounts According to the Bar the cleared lawyers are Steven Abrams Shawn Birken Harold Bofshever Robert Buschel Sara Coen-Giovanelli Mark Fistos Scott A Goldstein Julio Gonzalez Jr Frank Herrera Steven Jaffe Christina Kitterman Seth Michael Lehrman Arthur Neiwirth Steven Osber florida/blog/2010/07 _former_ scott rothstein atto This Just In I Sun Sentinel Biogs I former Scott Rothstein attorneys cJeared by The Flor Page of John Michael Ross Adam Steinberg Richard Storfer Osvaldo Torres Matthew Weissing Johnny Williams Jr Tami Wolfe Blandin Wright The attorneys who have not yet had their cases heard according to the Bar are Russell Adler William Berger David Boden Gary Farmer Jr Denis A Kleinfeld Carl Linder Steven Lippman Marc Nurik Michael A Pancier Carlos Reyes Stuart A Rosenfeldt Grant Smith Barry Stone Les Stracher The Sun Sentinel obtained a copy of a Bar letter sent last week to one of the cleared attorneys It is titled Notice of no probable cause and letter of advice to accused The letter says the attorney held himself out as a partner at Rosthstein Rosenfeldt Adler when only Rothstein and Rosenfeldt held equity in the firm they were percent partners but the Bar acknowledged that the practice is customary around the country The Bar apparently heard the cases first involving attorneys who were considered partners and those who have not had their cases heard yet were considered shareholders It appears the Bar 1s also looking at whether some of the RRA attorneys were involved in campaign finance violations Federal prosecutos alleged in their criminal charges against Rothstein that employees of the firm violated state and federal election law by being reimbursed for political contributions The Bar also became aware of allegations that lawyers at RRA may have engaged in actions that constituted violations of campaign finance law the letter says It was alleged that lawyers at RRA were instructed to make political campaign contributions that were then reimbursed to the lawyer from funds at RRA The lawyer who received the clearance letter denied having knowledge of any trust account Irregularities before the news accounts of Mr Rothstein fleeing the United States and thereafter being prosecuted criminally You denied that you were ever reimbursed for making campaign contributions or that you were ever asked to do so according to the letter The letter goes on to caution the attorney about proper trust account procedures and to observe standards of professional conduct POSTED IN Scott Rothstein Discuss this entry P8ffllallnk I Share II florida/blog/2010/07 fonner scott_rothstein _atto This Just In I Sun Sentinel Biogs former Scott Rothstein attorneys cleared by The Flor Page of I COMMENTS Aw come on isnt looking the other way a crime Posted by im no lawyer I July PM Is anyone but me tired and disgusted at haveing to look at this crooks smiling face every time the Sun entinel runs a story on him Posted by Robert July PM Free Russel Posted by docdecay I July PM What about the suspicious employess that worked there I heard that Andrew Barnett was involved in this fiasco along with others Posted by Steven I July PM What about the suspicious employess that worked there I heard that Andrew Barnett was involved in this fiasco along with others Posted by Slaven I July PM Some damn fine lawyers and former judges are still in the soup it looks like My guess The ones that didnt just hold themselves out as partners but were actually partners are still being investigated for Trust accounting violations Too bad But they were supposed to keep track of the accounts Non-delegable duty Im afraid It anint fair given the custom of letting the major sharholders do all the accounting Practice will change as a result Posted by Wait-A-Minute I July PM And how many of these newly FL Bar cleansed attorneys laundered RRA money for political contributions to Charlie Crist John McCain et al Need a pie Doesnt he have a mug-shot you could use I think the smug Im a Rock Star before shot is best Posted by And What About I July PM Posted by Cheese I July PM What a joke the Bar is you saps Its a country club for lawyers Do you really think theyre going to revoke somebodys membership in the club for committing a crime Theyre slapping each other on the back laughing at the farce they just pulled off Posted by endrew learmonth I July PM Not sure what all the fuss is about per cent of the firm had no clue about any wrongdoing and there was no reason to believe so Posted by ron huckster I July AM florida/blog/20 _former_ scott _rothstein atto This Just In I Sun Sentinel Biogs I former Scott Rothstein attorneys cleared by The Flor Page of Shawn Birken Judge Birkens son That clears up the mystery why an incompetent like Judge Birkens wife Barbara McCarthy was appointed to the benh by Charlie Posted by Stan I July AM What about Pedro Dijols Posted by Greg I July AM The bar giving press releases involving attorneys under investigation is their attempt to look like the knight riding in on his big horse to save the poor public from thse cretins leave it to a group headed by Jesse Diner to be full of itself Posted by klato I July AM lsnt not getting back to clients about their case make clients wonder If the attorney they believe in are really innocent or guilty Posted by Lill I July PM The Florida Bar is a criminal enterprise And no one can reign them in so the best thing to do is ignore them until they go away Posted by Dumbfounded I July AM Nice So I wonder how much the Fla Bar was paid to clear these names You cant tell me that they knew NOTHING about a major scheme that was happening in their very office Unbelieveable I POST A COMMENT Name Email Address CJ Remember personal info mment y_ou H!ML ag sty_le keep spam off our site please enter the letter In the field below Posted by Not surprised I July AM _former_ scott _rothstein _atto i This Justin I Sun Sentinel Biogs former Scott Rothstein_attomeys cleared:bithe Page of I ott_rothstein.:_atto PAX lfl Al Rothstein Rcsenfekft Adler Attorney at Law July Via Fa lle ROTHSlBlN ROSBNFELT ADLE Adam Horowitz Esquire Stuart Mermelstein Esquire Isidro Manuel Garcia Esq 1effiey Marc Herman Esquire Katherine Bartbt.n Ezell Esquire Robert Josefsberg Bsquire Jack Hill Esquire Dear Conmcl lif Bradley f:dwards Direct Dial dwardst mt-law.com We have recently received Notiae for Depositions from Adam Horowitz for several witnesses and the lever from Jack Hill inditating an intent to take others We latend to Ctoss-NotiGD oaoh deposition AdditiODally we intend to set the following other individuals for video deposition I I I Donald Trump West Palm Beach Olen Dubin West Palm Beach GJtlslainMaxwell NcwYork Sara Uer New Yorlc Leslie Wexner Ohio Bill Clinton D.C Paula,,Heil New York Jean Luc Bruhel New York 1l EXHJBIT Deporian rodAtJ Date Rptr.fU:_ Reply To La9 Olia Oil Cantte Ent Lm Olaa BaullWaRI Sulfa Port Lautl tdale Aotlda Telepllane Fax SOCA RATON FORT LAUDERDAt.E 1WAM1 MlW YORK CITY TAUAHASSEI WASHINGlON D.C WEST PALM BEACH EXHIBITM July Page 2of ROTHSTEIN ROSBNFBLT ADLB We will choose dates 1hat have not already been ocx:upied by other depositions ahcady set in this case If you would lib to be included in the soheduling of these depositions please proVide me with your scheduling secretaries names and 225mall addrcsse If any of you do Jl2t need to be consulted regmdiog the schedtlling of these depositio please advise me of that as wells Very traly yours ROTHSTBIN ROSENFELDT ADLER Bmdlcy Edwards Esquire Partner Fort tho Firm BJBhng1 i __ JANE DOE vs PlainUff UNITED STATl;S DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CIV ARRA/JOHNSON JEFFREY EPSTEfN Defendant NOTICE OF-TAKING VIDEO DEPOSITION PLEASE TAKE NOTICE that the Plaintiff JANE DOE will take the deposition of Leslie Wexler on Friday August at a.m at McGinnis Associates North High Street Suite Worthington OH The deposition shall be conducted pursuant to the Florida Rules of CiviLProcedure and shan 267continuedayto 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 e.f day of July to all those on the attached Service List EXHIBITN I cc US Legal Support Court Reporters ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff East Las Olas Blvd Suite Fort Lauderdale Florida Tel Fax Email bedwards rra-Jaw.com By BRAD EDWARDS ESQ Florida Bar No WE HEREBY CERTIFY that a copy of the foregoing was mailed trusath day of July to Via regular mail and fax to Robert Critton Jr Esquire Flagler Drive Suite West Palm Beach Florida fax rcrit bclclaw.com Via emai to Jack Patrick Hill jph searcylaw.com Isidro Manuel Garcia isidrogarcia bellsouth.net Katherine Warthen Ezell Kezell podhurst.com Michael James Pike Mpilce bclclaw.com Paul Cassell cassellp law.utah.edu Richard Horace Willits lawyerwillits aol.com Robert Josefsberg rjosefsbert podhurst.com Stuart Mermelstein ssm sexabuseattorney.com Adam Horowitz ahorowitz sexabuseattomey.com ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff East Las Olas Blvd Suite Fort Lauderdale Florida Telephone Telecopier By Bradley Edwards Florida Bar No bedwards n:a-law.com William Berger Florida Bar No wberger rra Iaw.com AO Rev 0IAJ9 Subpoena to Tesrify at a Deposition or Produce Documenl in a Civil Aelion UNITED STATES DISTRICT COURT JANE DOE PlainJljf JEFFREY EPSTEIN Defendant for the Southern District of FJorida Civil Action No 08-80893CIV-MARRA/JOHNSO If the action is pending in another district state where SUBPOENA TO TESTIFY AT A DEPOSmON OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION To Leslie Wexler One Whitebam Road New Albany Ohio ti Testimony YOU ARE COMMANDED to appear at the time date and place set forth below to testify at a deposition to be taken 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 McGinnis Assqclates Date and Time North High Street Suite A.UlAs am The deposition will be recorded by this method CJ 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 Fed Civ 4S 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 O_F_C_O_U._R_T OR a Signature of 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 Attorneys for Plaintiff East Las Olas Blvd Suite Fort Lauderdale Florida bedwards rra-law.com Sf I AO A hv Subpoella to Testify llt a Deposition or to Produce Doc:umtnts in a Civtl Aetion Page Civil Action No 08-80883CIV-MARRA/JOHNSO PROOF OF SERVICE This sectiqn sho11ld not be flied wllh the court unless required by Fed Clv 4S This subpoena for name of individual rmd tide if GIi was received by me on date IJ I personally served the subpoena on the individual at place on date or CJ I left the subpoena at the individuals residence or usual place of abode with name a person of suitable age and discretion who resides there on dole and mailed a copy to the individuals last known address or I served the on nameofind wauaV who is designated by law to accept service of process on behalf of name of organization on dale or I returned the subpoena unexecuted because Other 8JJt!d/y 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 Server 225311lgnawre Printed name trt1d ti1le Server address Additional information regarding attempted service etc or UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CIV MARRA/JOHNSON JANE DOE Plaintiff vs JEFFREY EPSTEIN Defendant I NOTICE OF TAKING VIDEOTAPED DEPOSITION PLEASE TAKE NOTICE that the Plaintiff JANE DOE will take the deposition of Ghlslane Noelle Maxwell on Monday August 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 g_ day of July to all those on the attached Service List I cc US Legal Support Court Reporters ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff East Las Olas Blvd Suite Fort Lauderdale Florida Tel Fax Email bedwards rra-law.com By ttRADe Florida Bar No AO Rev Subpoena to Testify at a position or to Produce Docwnent9 in a Civil Action UNITED STATES DISTRICT COURT for the Southern District of Florida JANEOOE Plainli.ff JEFFREY EPSTEIN Defendant Civil Action No 08-80893CIV-MARRA/JOHNSO If the action is pmiding in mu ther district state wbin SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCE DOCUMENTS IN A CML ACTION To GHISLANE NOELLE MAXWELL LLC NEW YORK Testimony YOU ARE COMMANDED to appear at the time date and place set forth below to testify at a deposition to be taken in this civil action lfyou are au orgaoiz.ation 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 Date and Time One Pem Plaza Suite York NY am The deposition will be recorded by this method Production You or your representatives must also bring with you to the deposition the following documents electronically stored infonnation or objects and pennit their inspection copying testing or sampling of the material The provisions of Fed 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 A cLERK oF coUIIT OR cffe SI gn aJWY ufCJerkor Deputy Clerk Attorneyuignaturc The name address e-mail and telephone number of the attorney representing name of party who issues or requests this subpoena are rad Edwards Esq ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff East Las Olas Blvd Suite Fort Lauderdale Florida bedwards rra-law.com AO Re_v Subpoc,na to TC3tily Ill itlon or Produce DDcwncnta in a Civil Acclon Paga Civil Action No 08-80893CIV-MARRA/JOHNSO PROOF OF SERVICE This section should not be.filed with tl,e court unless requlredby Fed Chi This subpoena for name of individual and tiJJe if tJJtY was received by me on dale I personally served the subpoena on the individual at place on date or I left the subpoena at the individuals residence or usual place of abode with name a person of suitable age and discretion who resides there on daie and mailed a copy to the individuals last known address or I served the subpoena on name of tndividUIZIJ who is designated by law to accept service of process on behalf of name of orgt;rnizatron on daJB or I returned the subpoena unexecuted because Other pectjy 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 infonnation is true Date Servers signature Primed name and tille Servers address Additional information regarding attempted service etc or UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CIV MARRNJOHNSON JANE DOE Plaintiff vs JEFFREY EPSTEIN Defendant NOTiCE OF 267TAKING VIDEOTAPED DEPOSITION PLEASE TAKE NOTICE that the Plaintiff JANE DOE will take the deposition of Glenn Russell Dul ln on esday August at a.m at Eqt.1ir,e _qourt Reporters on Perin 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 untii completed i HEREBY CERTIFY that a true and correct copy of the foregoing has been served by U.S Mail and email transrnission this day of July to all those-of the attached Service List cc US Legal Support Court Reporters ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff East las Olas Blvd Suite Fort Lauderdale Florida Tel Fax Email bedwards rra-law.com By BRAD EDWARDS ESQ Florida Bar No AO Rev Subpoena to Test.icy at a Depo.,ition or to Produce Document in a Civil Action UNITED STATES DISTRICT COURT JANE DOE Plainliff for the Southern District of Florida Civil Action No 08-80893CIV-MARRA/JOHNSO JEFFREY EPSTEIN If the action is pending in another district state where Defendant SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCE DOCUMENTS IN A CIVIl ACTION To Glenn Russell Dubin 5th Avenue Unit New York NY Testimony YOU ARE COMMANDED to appear at the time date and place set forth below to testify at a deposition to be taken 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 RE!porters Date and Time One Penn Plaza Suite York NY am The deposition will be recorded by this method CJ Production You or your representatives must also bring with you to the deposition the following documents electronically stored information or objects and permit their inspection copying testing or sampling of the material The provisions of Fed 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 cff CLERK OF COURT Sig,,ahue of Clerlc or Deputy aerie Attorneys signature The name address e-mail and telephone number of the attorney representing of party who issues or requests this subpoena are Br ad Edwards Esq ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff East Las Olas Blvd Suite Fort Lauderdale Florida bedwsrds rra-law.com S2 I l..O BM Rev Subpoena to lel fy Bl Deplmklcm Ill hi llvdu Doi.umiml:I in a Civil Autism Pap Civil Action No 08-80893CIV-MARRNJOHNSO PROOF OF SERVICE This secJion should not bejlled with tJ,e court unless required by Fed Clv 4S This subpoena for name of individual mid tide If any was received by me on fdJe I personally served the subpoena on the individual at place on dau or I left the subpoena at the individuals residence or usual place of abode with name a person of suitable age and discretion who resides there on dale and mailed a copy to the individuals last known address or I served the oe name of tndi who is designated by law to accept service of process on behalf of name of orga,,iz11i on date or I returned the subpoena unexecuted because CJ Other 1pecity 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 or I declare under penalty of perjury that this information is true Date Servers sig1ilure Printed name and tille Server addren Additional information regarding attempted service etc UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLOR!DA CASE NO MARRA/JOHNSON JANE DOE Plaintiff vs JEFFREY.EPSTEIN Defendant __ Re--NOTICE OF TAKING VIDEOTAPED DEPOSmoN PLEASE TAKE NOTICE that the Plaintiff JANE DOE will take the deposition of Donald Trump on gust at a.m at Esquire Court Reporters One Penn Plaza Suite New York NY The deposition shall be conducted pursuant to the Flotida Rules of CMI 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 Mall and email transmission this LL.ataY of August to all those on the attached Service List I cc Esquire Court Reports ROTHSTEIN ROSENFELDT ADLER Attorneys for Plalntiff East Las Otas Blvd Suite Fort Lauderdale Florida Tel Fax Email bedwards rra-law.com Robert Critton Jr Esq BURMAN CRITTON BT AL North Flagler Drive Suite West Palm Beach FL Jay Howell Assoc Cesery Boulevard Suite Jacksonville FL Jack Alan Goldberger Esq Atterbury Goldberger et al Australian Ave South Suite West Palm aeach FL Paul Cassell Esq South Room Salt Lake Cirty UT Service List Jack Alan Goldberger Esq Atterbury Goldberger Weiss PA Australan Avenue South Suite West Palm Beach I Lt I i I UNITED STATES DISTRlCT COURT 267SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CIV MARRA/JOHNSON JANE DOE Plaintiff vs JEFFREY EPSTEIN Defendant NOTICE OF TAKING VIDEOTAPED DEPOSmON PLEASE TAKE NOTICE that the Plaintiff JANE DOE will take the dapositlor:t of Nadia Marclnkova on Thursday 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 CMI Procedure and shall oontinue 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 Mall and email transmission this IL day of August to all those on the attached Service List cc Esquire Court Reporters ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff East Las Clas Blvd Suite Fort Lauderdale Florida Tel Fax Email bedwards rra 225law.com By _q;z BRAD EDWARDS ESQ Florida Bar No AO SSA Rev Subprena to Testify Ill a lkposition or to Produce Documents in a Civil Aciion 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 DEPOSlTION OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION To Nadla Marclnkova Street New York NY Testimony YOU ARE COMMANDED to appear at the time date and place set forth below to testify at a deposition to be taken in this civil action lfyou are an organii:ation that is not a party in this case you must designate one or more officers directors or managing agents or design.ate 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 Date and Time am The deposition will be recorded by this method CJ Production You or your representatives must also bring with you to the deposition the following documents electronically stored information or objects and permit their inspection copying testing or sampling of the material The provisions of Fed 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 Signalre of Clerk or Deputy Clerk Attorneys sigr,atlln 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 AO SBA Rn Subpoena to TCSllfy et a Deposition or tO Produce Doeumcnl3 in a Civil Action Pag112 Civil Action No 08-90893CIV-MARRA/JOHNSO PROOF OF SERVICE This section should not be flied with the court unless required by Fed Clv 4S This subpoena for name of indildua and if a,ry was received by me on date CJ I personally served the subpoena on the individual at place on date or CJ I left the subpoena at the individuals residence or usual place of abode with name a person of suitable age and discretion who resides there date and mailed a copy to the individuals last known address or I served the subpoena on name of i,idividual who is designated by law to accept service of process on behalf of name of organization on date or CJ returned the subpoena unexecuted because CJ Other cffy Unless the subpoena was issued on behalf of the United States or one of its officers or agents 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 infonnation is true Date Serwr signalre Printed name and title Server address Additional infonnation regarding attempted service etc or AO BIA Rev Subpoena lo Testify at a Dcposilion to Prod Documents in a Civi1 Action Pago Federal Rule of Civil Procedure dh and Effective Protedlng a Person Subject to a Subpoena AlOldlng UlUhle Burden or Expense;.Sanction A party or auomey responsible for issuing end serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpOCDa 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 ProdRce Malerla/s or Pennit lnspedlon A Appearance Not Required A person commanded to produce documems electronically stored information or tangible things or to permit the inspeclion 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 comlTUldcd lo produce documents or tllngib things or to pennit inspection may serve on the party or attomey designated In the subpoena a written objection to inspecting copying testing or sampling or all of the materials or to inspecting the premises or to producing electronically stored information in the fonn 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 At any time on notice to the commanded person the serving party may move the issuing court 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 QlShllfl or Modifying a Sllbpoaia A When 243q11ired On timely molion the issuing court must quash or modify a subpoena that I fails to aUow a reasonable time to oomply ii requires a person who is neither a party nor a partys officer to travel more than miles from where that person resides is employed or regularly transacts business In person except that subject to Rule 4S cX3 0Xlil the person may be commanded to attend a trial by traveling from any such place within the state where the trial is held ill requires disclosure of privileged or other protccied matter if no exception or waiver applies or iv subjects a person to undue burden When Permilled 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 information ii disclosing an unretained experts opinion or infonnation that does not describe spcoific occurrences In dispute and results from the experts study lhat was not requesred 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 Specw,l11g Conditions as an Alternative In the circumstances described in Rule 4S 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 olhCIWisc met without undue hardship and ii ensures that the subpoenaed person will reasonably c:ompemated Dutlea In Responding to a Subpoena Producing DOCllments or EleCllOnklzy S,Or,d lnfomuttloJL These procedures apply to producing documents or elearonically stored Information A Documen1s A person responding to a subpoena to produce documents mim 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 Prodllctn.g Electrorrically Stored J,iformatio,i Not Specified If a subpoena does not specify a form for producing el ronically stored infolIJltion the person responding must produce it in a form or fonns in which it is ordinarily maintained or in a reasonably usable form or fonns Electronically Stored Information Produced in Only One Form The person responding need not produce the same electronically stored information in mare than one fonn lnacceuible Electronically Slored nf Olmalion The person nding need not provide discovery of electronically stored information from soun:es that the person identifies as not reasonably accessible because of undue burden or cost On motion to COOtpel discovety or for a protective order the person responding must show that the informatioo is not reasonably accessible because of undue burden or cost If that showing is made the court may nonethel order discovery from such sources If the requesting party shows good cause consldering lhe limitations of Rule The court may specify conditions for the discoveiy Qalmlng PrMlege or Prolec/1011 A l,iformalion Withheld A person withholding subpoenaed information Wider a claim that ii is privileged or subject to protection as trial-preparation material must expressly make the claim and IJ describe the natun of the withheld documents communications or tangible things In a maMer thll1 without revealing information itseJfprivilcgcd or protected will enable tile parties to assess the claim Information Produced If infonnation produced ic response to a subpoeoa is subject to a claim of privilege or of protection as trlal prqJaration materio.l the person mak.lng the claim may notify any party that fCived the infurmation 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 infonnation until the claim is resolved must take reasonable steps to retrieve the information if the pB.rty disclosed it before being notified and may promptly present the infonnation to the court under seal for a determination of the claim The person who produced the infonnation must pn:serve the information until the claim is resolved ContempL The i.sm,ing court may hold In contempt a person who having been served falls without adequate exCllse 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 piece ouiside the limits of Rule A ii UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CIV MARRNJOHNSON 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 Mark Epstein on Monday 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 untll completed I HEREBY CERTIFY that a true and correct copy of the foregoing has been served by U.S Mall and email transmission this L/Aday of August to all those on the attached Service List 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 By BRAD EDWARDS ESQ Florida Bar No AO Subpoena ID Testify at Dcpvaitiou or ll Produa Documents in a Civil Action UNITED STATES DISTRICT COURT JANE DOE P/o/11Jljf JEFFREY EPSTEIN Defendant for the Southern District of Florida Civil Action No 08-90893CIV-MARRA/JOHNSO lfthc adion is pending in another district sIBte where SUBPOENA TO TESTIFY AT A DEPOSfflON OR TO PRODUCE DOCUMENTS IN A CML ACTION To Mark Epstein 66th Street New York NY Testimony YOU ARE COMMANDED to appear at the time date and place set forth below to testify at a deposition to be taken 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 CJ 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 Fed 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 Signaturt of Clerk or Def1ty Clerk Anomeys 1/gnat11NI The name address e-mail and telephone number of the attorney representing name qf party who Issues or requests this subpoena are Br ad EdWards Esq Rothstein Rosenfeldt Adler Las Olas Blvd Suite Fort Lauderda Florida 8edwards rra-laW.com AO llcv Subpoena to Te,tify at a Deposition or to Produce Documenis in a Civil Action Page Civil Action No 90893CIV-MARRA/JOHNSO PROOF OF SERVICE This section _should_not bejlled with the court unless required by Fed Clv This subpoena for name of indiv/drlQ and title If mry was received by me on date CJ I personally served the subpoena on the individual at place on date or I left the subpoena at the individuals residence or usual place of abode with name a person of suitable age and discretion who resides there on dew and mailed a copy to the individuals last known address or I served the subpoena on na1e o/individuai who is designated by law to accept service of process on behalf of name of orgonlztllian 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 are for travel and for services for a total of I declare under penalty of perjury that this infonnation is true Date Servers signature Printed rrame and lille Server a addreaa Additional infonnation regarding attempted service etc or AO Rev Subpoena to Talify at a Dcpt,silion or It Pn duce umenb in II Chiil A tioo Page Federal Rule of Civil Procedure 4S and Effective Proteding II Person Subject to a Subpoena Avoldtng l/ndue Barden or E,q,a,se;SanctJon A party or attorney responsible for issuing serving a subpoena must take reasonable steps to avoid imposing undue bw-dtm or expense on a porson subject to lhe 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 Con,mm,d to Prodllce Mlerl418 or Permit lnq,ectlon A Appearance Not Required A person commanded to produce documents electronically stored infonnation 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 nearing or trial ObjecJioN1 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 infom1Stion in U!e fonn or fonns requested The objection must be served before lhe 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 court for an order wmpclng production or Inspection Ii These acts may be required only as directed in the order and the order must protect a person who is ncitha a party nor a partys officer from significant expense resulting from compliance Quw,u,g or Modlhing a Subpoena A Wlum Required On timely motion the issuing court must quash or modify a subpOfna that i fails to allow a reasonable lime to comply II requires a person who Is neither a party nor a partys officer to travel more than I miles from where that person resides is employed or regularly tnmsact:3 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 ill requires disclosure of privileged or other procec:ted matter if no exception or waiver applies or Iv subjects a person to undue burden Whe,a Permitted To proicct a person subject to or affected by a subpoena the issuing court may on motion quash Of modify the subpoena if it requires i disclosing a trade secret or other confidential research development or conunercial infonnation ii disclosing unn:tained 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 substanlial expense to travel more th1 miles to attend trial Specifying Conditions as an Alternative 1n the circumstances described in Rule lbe coon may instead of quashing or modifying a subpoena order appearance or production under specified conditions if the sciving 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 Produdng Docutno1ts or ElecJronlcally Stond lnfonnallon These proced apply to producing documents or electronically gtored information A Documents A person responding to a subpoena to produce documents must produce them as they are kept in tho ordinary course of business or must organize and label them to correspond to the categories in the demand Form for Producing Electronically Stored l,iformaJion 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 fonns in which it is ordinarily maintained or in a reasonably usable form or fonns E/u;tromcally Stored Infor"1lltion Prodw:ed in Only One Form The person responding need not produce the same electronically stored information in more than one form lnacces1ible Elec1ronically Stored lnf ormation 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 disoovery or for a protective order the person responding must show that the information is not reasonably accessible because of undue burden or cost Jflhat showing is made the court may nonetheless order disoovery from such sources if the requesting party shows good cause considering the limitations of Rule The court may specify conditions for the discovery Qaimlng Privilege r,r Protecllon 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 infonnation itself privileged or protecled will enable the parties to the claim Information Produced lf information produced in se 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 infonnation of the claim and the basis for iL 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 tmtil the claim is resolved must take reasonable steps to retrieve the infonnation if the party disclosed it before being notified and may promptly present the information to the court under seal for a detennination of the claim The persori 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 lletVed fails without adequate excuse to obey the subpoena A nonpartys failure to obey must be excused if the subpoena purports to require the nooparty to llttelld or produce at a place outside the limits of Rule A ii UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO MARRA/JOHNSON JANE DOE Plaintiff vs JEFFREY EPSTEIN Defendant NOTICE OF TAKING VIDEOTAPED DEPOSITION PLEASE TAKE NOTICE that the Plaintiff JANE DOE wRI take the deposition of Jean Luc Bruhel on Tuesday September at a.m at Esquire Court Reporters One Penn Plaza Suite4715 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 Mall and email transmission this ay of August to all those on the attached Service List I I ill I cc Esquire Court Reporters ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff East Las Oles Blvd Suite Fort Lauderdale Florida Tel Fax Email bedwards rra--law.com By BRAD EDWARDS esb Florida Bar No AO Rev Subpoena lD Testify a Dq,o.,ltion or to Produce Documtll181 a Civil Action UNITED STATES DISTRICT COURT JANE DOE Plainlijf JEFFREY EPSTEIN Defendant for the Southern District of Florida Civil Action No 0B-90893CIV-MARRA/JOHNSO If the action is pending in another district stare where SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCE DOCUMENTS IN A CIVIL AcnON 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 taken in this civil action If you are an organiz.ation that is not a party in this case you must designate one or more officers mrectors 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 R,porters One Penn Plaza Suite New York NY Date and Time am The deposition will be recorded by this method 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 Fed 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 Sig,w.hae of Clerk or Deputy Cleric Attomey rlgnature The name address e-mail and telephone number of the attorney representing name o/ptUty who issues or requests this subpoena are Brad Edwards Esq Rothstein Rosenfeldt Adler Las Olas Blvd Suite Fort Lauderdale Florida Bedwards rra-law.cQm AO Rev Subpoena to Testify at a Dq,osition or Produce DoGumcall in a Civil Action Page Civil Action No 08-90893CIV-MARRA/JOHNSO PROOF OF SERVICE This section should not be filed with du court unless required by Fed Civ This subpoena for name of lndividwl and if any was received by me on dale I personally served the subpoena on the individual at place OD dale or I left the subpoena at the individuals residence or usual place of abode with 11ame a person of suitable age and discretion who resides there on dau 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 na,ne of organiJalio11 on dale or I returned the subpoena unexecuted because a 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 bue Date Server 1lgnllhlre Prlnled 11ame and title Servers address Additional information regarding attempted service etc or AO Rev Subpoena to Testify at a lkposition or to ProduQe Documan1s in a Civil Ac:tion Page Federal Rule of Civil Procedure and Effective tectfng a Person Subject to a Subpoena Avoiding Undl Burdm or Expoau Sanction A party or auomey responsible for issuing and serving a subpoena must take re11SOnable atcpa to avoid imp0 ing undue burden or expense on a person subject to the subpoena The issuing court must enfon:e this duty and impose an appropriate sanction which may include lost eami.nga and reasonable attorneys fees on a party or attorney who fails to oomply Comnu,nd to Produce MlltuWs or Permit J,upealon A Appearance Not Re.quired 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 Objeclio,u A peraon commanded to produce documents or tangible thiDgs 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 infonnation in the fonn or forms requested The objection must be served before lhe 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 Cl urt for an order compelling production or inspection II These acts may be required only as directed in fhe order and th order must protect a person who is neither a party nor a partys officer from significant eiq,ensc resuhmg from compliance Quashing or tllfying II Subpoena A When Required On timely motion the issuing court must quiu;h or modify a subpoena that fails to allow a reasonable time to comply Ii requires a person who ia neither a party nor a partys officer to iravc:1 more than JOO miles fiom where mat person resides Is employed or regularly transacts business in person except that subject to Ruic BXiil the person may be commanded to attend a trial by traveling from any such place within the state where the trial is held lU n::quircs di elosure of privileged or other protected matter if no exception or waiver applies or Iv 8Ubjects a pcrson to undue burden When Permilled To protect a person subject to or affected by a subpoena the issuing court may on motion quash or modify the subpoena ifit requires I disclosing a trade secret or other confidential research development or commercial information II disclosing an unretained experts opinion or information that does not desc:nbe specific occurrences in dispute and results from the study that was not requested by a party or a person who is neither a party nor a partys officer to incm substantial eitpcnse to travel more than miles to attend trial Specifyu,g Conditioll.f as an Allernative In the circumstances described in Rule 4S the court may instead of quashing or modifying a subpoena onler eppeanmce or production under specified condition if the serving party I show a substantial need for the lc5timony or material that cannot be otherwise met without undue hardship and enswes that the subpoenaed person will be reasonably compensated Danes fn RespondJng to a Subpoena I Prodadng DOC11ments or Elearo11lcally Stored InfonlUdlon These procedures apply to producing documents or elec:tnmically stored infonnation A DoCJJments A person responding to a subpoena to produce documents must produce them as they are lcept 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 Iflormation Not Specifled If a subpoena does not specify a fonn for producing electronically BtOred 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 fonns Electrontcally Stored Ifl orntlion Produced Only One Form The person responding need not produce the 1amc electronically stored infonnation in more than one form Inaccessible Electronically Stored l,rforma1ion The person responding need not provide discovery of electronically stored infonnation from sources that the person identifies as not reiu;onab acuible because of undue burden or cost On motion to compel discovery or for a pro tee ti ve 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 nonethele3s order discoveiy from such sources if the requesting party shows good causo c:onsidering the limitations of Rule bX2 The COUJ1 may specify conditiona for the discovery Claiming Privilege Prutedion A Information Wltliheld A person withholding sobpoenaed information under a claim that it Is privileged or subject to protection as trial-preparation material must I expressly make the claim and il deacnbc the nature of the withheld documenbi communications or tangil,le things in a manner that without revealing informatlon itself privileged or protected will enable the parties to assess the claim Information Produced If infonuatioo produced in response to a Ubpoeoa i 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 relUm sequester or destroy the specified infonnation and any copies it has must not use or disclose the Information until the claim is resolved mll8t take reasonable steps to retrieve the information iftbe party disclosed it before being notified and may prompdy present the information to the court under seal for a determination of the claim The person who produced the infonnation must preserve the information until the claim is resolved Contempt The issuing court may hold in oontempt 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 of Rule X3 XAXii UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CIV MARRNJOHNSON JANE DOE Plaintiff vs JEFFREY EPSTEIN Defendant I Re NOTICE OF TAKING VIDEOTAPED DEPOSITION PLEASE TAKE NOTICE that the Plaintiff JANE DOE will take the deposition of Ghislane Noelle Maxwell on Wednesday 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 CMI Procedure and shall continue day to day weekends and holidays excepted until completed I HEREBY CE_RTIFY that a true and correct copy of the foregoing has been served by U.S Mall and email transmission this of August to all those on the attached Service List cc Esquire court Reporters ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff East Las Olas Blvd Sulta.1650 Fort Lauderdale Florida Tel Fax Email bedwards rra-law.com Robert Critton Jr Esq BURMAN CRIITON BT AL North Flagler Drive Suite West Palm Beach FL Jay Howell Assoc Cesery Boulevaro Suite Jacksonville FL Jack Alan Goldberger Esq Atterbury Goldberger et al Australian Ave South Suite West Palm each Fl Paul CasseB Esq South Room Salt Lake Girty UT Service List Jack Alan Goldberger Esq Atterbury Goldberger Weiss PA Austraman Avenue South Suite West Palm Beach I
