Text extracted via OCR from the original document. May contain errors from the scanning process.
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
PLEASE TAKE NOTICE that plaintiff, Jane Doe, will take the video deposition of:
NAME
DATE AND
TIME
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
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:
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
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:
)
'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
(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