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efta-efta00728295DOJ Data Set 9Other

UNITED STATES DISTRICT COURT

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DOJ Data Set 9
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efta-efta00728295
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EFTA Disclosure
Text extracted via OCR from the original document. May contain errors from the scanning process.
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, Plaintiff, Vs. JEFFREY EPSTEIN, et al. Defendant. CASE NO. 08-CV-80893-CIV-MARRA/JOHNSON Related Cases: 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 NOTICE OF TAKING DEPOSITION VIDEO DEPOSITION PLEASE TAKE NOTICE that plaintiff, Jane Doe, will take the video deposition of: NAME DATE AND TIME PLACE OF TAKING DEPOSITON Story Cowles South Olive Avenue #201S West Palm Beach, FL May 12, 2010 @ 10:00 AM US Legal Support 444 West Railroad Avenue Suite 300 West Palm Beach, FL 33401 upon oral examination before US Legal Support, Notary Public, or any other notary public or officer authorized by law to take depositions in the State of Florida. The oral examination will continue from day to day until completed. The depositions are being taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted under the Rules of Court. EFTA00728295 CASE NO: 08-CV-80119-MARRAIJOHNSON CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing was served by e-mail on April 15, 2010 to: See attached service list. Bradley J. Edwards Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Ave.. Suite 2 F L d rdale, FL 33301 ax By: BRADLEY.. EDWARDS Florida Bar No.: 542075 2 EFTA00728296 CASE NO: 08-CV-80119-MARRALIOHNSON SERVICE LIST Jane Doe v. Jeffrey Epstein United States District Court - Southern District of Florida Jack Alan Goldber er, Esq. Robert D. Critton, Esq. Isidro Manual Garcia Jack Patrick Hill Katherine Warthen Ezell Michael James Pike Paul G. Cassell Richard Horace Willits Robert C. Josefsber Adam D. Horowitz Stuart S. Mermelstein 3 EFTA00728297 AO SYli I Rry ;ram IANtice INK-tertni‘, It format ton or Objects or to IMInspodionot Penises in a ovii .kct,nn UNITED STATES DISTRICT COURT for the Southern District of Florida JANE DOE miming Civil Action No. 08-80893CIV-MARRAJJOHNSO JEFFREY EPSTEIN Defendant (lithe adios Is pcntling in another district, stoic here: ) SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION 'ro: Story Cowles, 801 South Okve Avenue, #201S. West Palm Beach, FL 33401 O Production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following documents, electronically stored information, or objects, and permit their inspection, copying, testing, or sampling of the material: Place: US Legal Support 444 West Railroad Avenue, Suite 300 West Palm Beach, FL 33401 Date and Time: 05/12/201010:00 am O Inspection of Premises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or other property possessed or controlled by you at the time, date, and location set forth below, so that the requesting party may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it. Place: Date and Time: The provisions of Fed. R. Civ. P. 45(c), relating to your protection as a person subject to a subpoena, and Rule 45 (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, arc attached. Date: 04/15/2010 CLERK OF COURT Signature of Clerk or Deputy Ckrk OR Attorney's signature The name, address, e-mail, and telephone number of the attorney representing (name of party) JANE DOE , who issues or requests this subpoena, are: INN elssing, et al., 425 North Andrews Avenue, Suite 2. Ft. Lauderdale, FL 33301 EFTA00728298 AO RIM (Rev. 04•'09) Subpoena to Prork.me Documents. Inforrnalton. or Objects or to Permit illArlt1107 of Prer11{r ,n a civil Actir rage ') as Ci' it Action No. 08-80893CIV-MARRNJ0HNS0 PROOF OF SERVICE (This section should not bellied wish the court unless required by Fed. R. ay. P. 41) This subpoena for (name of individual and title. if any) was received by me on (dare) O I served the subpoena by delivering a copy to the named person as follows: El I returned the subpoena unexecuted because: on (date) ; or 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 day's attendance, and the mileage allowed by law, in the amount of My fees are S Date: for travel and S for services, for a total of S 0.00 I declare under penalty of perjury that this information is true. Server's signature Printed name and title Server's address Additional information regarding attempted service, etc: EFTA00728299 AO !Olt] n(d04: Sub; a to Producc Docurotntr. Informatior. nr Olajeor or 10 Perot, Ifinatlion of Premises in a ('.ail won:Pair 1, Federal Rule of Civil Procedure 45 (c), (d), and (e) (Effective 12/1/07) (c) Protecting a Person Subject to a Subpoena. (1) Avoiding Undue Burden or Expense; Sanctions A party or attorney responsible for issuing and saving a subpoena must lake reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena- The issuing court must enforce this duty and impose an appropriate sanction — which may include lost earnings and reasonable attorney's fees — on a party or attorney who fails to comply. (2) Command to Produce Materials or Permit Inspection. (A) Appearance Not Required. A person commanded to produce documents, electronically stored information, or tangible things, or to = 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. (B) Objections. A n commanded to produce documents or tangible things or to = inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 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 compelling production or inspection. (11) 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 party's officer from significant expense resulting from compliance. (3) Quashing or Modifying a Subpoena. (A) When Required. On timely motion, the issuing court must quash or modify a subpoena that: (i) fails to allow a reasonable time to comply; (II) requires a person who is neither a party nor a party's officer to n travel more than 100 miles from where thate n resides, is employed, or regularly transacts business in — except that, subject to Rule 45(cX3)(BXiii), the person ommanded to attend a trial by traveling front any such place within the state where the trial is held; (iii) requires disclosure of privileged or other protected matter, if no exception or waiver plies; or (iv) subjects a to undue burden. (B) When Permit . 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 expert's opinion or information that does not describe specific occurrences in dispute and results from m. y the expert's stud that was not requested by a party; or (III) a who is neither a party nor a party's officer to incur substant. expense to travel more than 100 miles to attend trial. (C) Specifying Conditions as an Alternative. In the circumstances described in Rule 45(eX3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party: (I) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and (ii) ensures that the subpoenaed person will be reasonably compensated. (d) Dales In Responding to a Subpoena. (1) Fraiche: Documents or Electronically Stored Information. These procedures apply to producing documents or electronically stored information: (A) Documents. A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label than to correspond to the categories in the demand. (B) Form for Producing Electronically Stored Information Not Specillat If a subpoena does not specify a Conn for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms. IectroII Electronically Stored Information Produced in Only One The person responding need not produce the same e nically stored information in more than one form. (D) Inaccessible Electronically Stored Information. The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(bX2XC). The court may specify conditions for the discovery. (2) Claiming Privilege or Protection. (A) Information Withheld A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must: (I) expressly make the claim; and (II) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim. (B) Information Produced, If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial- preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must promptly return, sequester, or destroy the specified 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 information to the court under seal for a determination of' the claim. The person who produced the information must preserve the information until the claim is resolved. (e) Contempt. The issuing court may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena. A nonparty's 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 45(c)(3XAXii). EFTA00728300

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