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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. 3

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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