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Case 1:15-cv-07433-LAP Document 1320-8 Filed 01/03/24 Page 3 of 12
Giuffre’s counsel contacted counsel for Epstein to seek agreement that he would accept service
of the subpoena in this matter. See McCawley Decl. at Composite Exhibit 3, Electronic
Correspondence to Attorney Marty Weinberg. Ms. Giuffre was unable to obtain that agreement
so she retained an investigative company to attempt to locate Epstein for purposes of personal
service’. As explained in the attached affidavit, the Alpha Group Investigators commenced
efforts to personally serve Epstein on April 26, 2016. See McCawley Decl. at Exhibit 4
Affidavit of Douglas G. Mercer, Chief Investigator Alpha Group. Those efforts have continued
for weeks, and included over sixteen (16) attempts to personally serve Epstein, including as
recently as May 18, 2016, at which time the investigator affixed the subpoena to the front door of
Epstein’s residence and mailed copies of the subpoena to both of his New York addresses along
with a witness check. Counsel for Ms. Giuffre also provided a copy of the subpoena to Marty
Weinberg, Epstein’s attorney.
Jeffrey Epstein is not the only key witness who has been evading Ms. Giuffre’s efforts to
depose them. The next echelon in the sex trafficking organization below Epstein and the
Defendant includes Sarah Kellen and Nadia Marcinkova. Ms. Giuffre alleges that they were
heavily involved in the sex trafficking. Both Kellen and Marcinkova appear repeatedly on the
flight logs of Jeffrey Epstein’s aircraft. The U.S. Attorney’s Office for the Southern District of
Florida specifically identified both Kellen and Marcinkova as among four named “potential co-
conspirators of Epstein” in the non-prosecution agreement it executed with Epstein as part of his
guilty plea to Florida state sex offense charges. See Non-Prosecution Agreement, Jn re:
Investigation of Jeffrey Epstein at 7. Additionally, both Kellen and Marcinkova previously
' As recently as today, Ms. Giuffre’s counsel continues to attempt to negotiate acceptance of service of
the subpoena for Mr. Epstein, which now includes a request that his deposition take place in the U.S.
Virgin Islands but has still not received an agreement to accept service. See McCawley Decl. at
Composite Exhibit 3, Correspondence with Marty Weinberg, counsel for Jeffrey Epstein.
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Document Details
| Filename | Giuffre_Maxwell_Batch1_p00114.png |
| File Size | 331.8 KB |
| OCR Confidence | 95.3% |
| Has Readable Text | Yes |
| Text Length | 2,337 characters |
| Indexed | 2026-02-04 12:32:19.083879 |