Giuffre_Maxwell_Batch1_p00120.png
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Case 1:15-cv-07433-LAP Document 1320-8 Filed 01/03/24 Page 9 of 12
brought by one of Jeffrey Epstein’s sexual assault victims. See Decl. of Sigrid McCawley at
Composite Exhibit 9, Maxwell Deposition Notice; Subpoena and Cancellation Payment Notice,
and January 13, 2015 Daily Mail Article.
Ms. Giuffre proposes that she be permitted to serve her deposition notices by means other
than personal service. Ms. Giuffre asks this Court to rule that she be permitted to serve each of
the three individuals in ways that are reasonably calculated to give them actual notice. The
specific means that Ms. Giuffre proposes are the means that her investigators took on May 18"
of posting the subpoenas to the addresses associated with each of the witnesses and mailing the
subpoenas to those addresses with the witness fee check and providing copies of the subpoenas
via e-mail to the witnesses known counsel. See McCawley Decl. at Exhibit 4, Affidavit of
Douglas G. Mercer, Chief Investigator Alpha Group.
Means such as those described above have been approved by this Court in other cases.
For example, in Medical Diagnostic Imaging, PLLC v. Carecore National, LLC, 2008 WL
3833238 (S.D.N.Y. 2008) (Katz, J.), this Court allowed service of a deposition subpoena to be
made through mailing a copy of the subpoena to the witness’ place of employment along with a
copy of the Court’s order directing the witness to comply with the subpoena or face sanctions.
Id. at *3. Similarly, in JPMorgan Chase Bank, N.A. v. IDW Grp., LLC, No. 08 CIV. 9116(PGG),
2009 WL 1313259, at *3 (S.D.N.Y. May 11, 2009), this Court allowed service of a deposition
subpoena to be made by sending a copy of the deposition subpoena to the witness’ place of
business and residence by certified mail; leaving a copy of the deposition subpoena at the
witness’ residence and place of business with a person of suitable age and discretion; and
remitting a copy of the deposition subpoena by electronic mail and certified mail to counsel for a
related corporation. And, in at least two cases, this Court has found that certified mailing of a
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Document Details
| Filename | Giuffre_Maxwell_Batch1_p00120.png |
| File Size | 311.2 KB |
| OCR Confidence | 95.4% |
| Has Readable Text | Yes |
| Text Length | 2,101 characters |
| Indexed | 2026-02-04 12:32:21.347428 |