EFTA00726285.pdf

NAQP (Rev rol Subverts ip Cam Southern Issued by the UNITED STATES DISTRICT COURT DISTRICT OF Florida Albert G. `ill V. Tom Hunt, et al. TO: Jeffrey Epstein 358 El Brillo Way Palm Beach, FL 33480-4730 SUBPOENA IN A CIVIL CASE Carr N umber:: 07-cv-02020-O YOU ARE COMMANDED to appear in the United States District court at the place, date, and time specified below to testify in the above case: PLACE OE TESTIMONY COURTROOM DATE MD TIME t YOU ARE COMMANDED to appear at the place, date, and time specified below to testify at the taking of a deposition in the above ease. PLACE OF DEPOSITION Regus - Phillips Point, 777 S. Fleger Drive, Suite 800 West Tower, Went Palm Beach. FL 33401 DATE AND TIME 1/26/2010 9:30 am YOU ARE COMMANDED to produce and permit inspection and copying of the following documents or objects at the place, date, and time specified below (list documents or objects): See attached Exhibit A PLACE DATE AND TIME YOU ARE COMMANDED to permit inspection of the following premises at the date and time specified below. PREMISES DATE AND TIME Any organization not a party to this suit that is subpoenaed for the taking of a deposition shall designate one or more officers, directors, or managing agents, or other persons who consent to testify on its behalf, and may set forth, for each person designated, the matters on which the person will testify. F,pderal Rules of Civil Procedure, 30(bX6). TF4 ETTORNEY IMIt Pli eNTIF I ti %Lq_ EF MANE) tfor 1-0A3 eb_r Pt ncta, 444 ISSUING OFFICER'S NAME, ADDRESS AND PHO 'E NUMBER Bruce Bowman, Jr., Godwin Ronquillo , 1201 Elm Street, Suite 1700, Dallas, TX 75270-2041 (214) 939-8679 ATTORNEY FOR DEFENDANT ALINDA WIKERT DATE 12128/09 (Sot Rule 45, Federal Rule of Civil Prot:eta Subdivilices (C. (ek on Page) ' If action pending in Mono other than astnct of imance. stoic chsinct under case flUnter. EFTA00726285 uagaas:61232faSuboacouloseiaCtic PROOF OF SERVICE DATE PLACE SERVED Na,ligNotx, . SERVED ON (PRINT NAME) MANNER OF SERVICE Sec •(tra-4t-- SERVED BY (PRINT NAME) TITLE OCy „ E'S CA44-a fia: Cgt SIINA-re DECLARATION OP SERVER I declare under penalty of perj ury under the laws of the United States ofAmerica that the foregoing information contained in the Proof of Service is true and correct. Executed on 1Z(2% (0 5 DATE SIG, RE OF SbItVE.R ADDRESS OF SERVER Rule 45. Fedtral Rules or Civil Procedure. Subdivisiorts (c), (d), and (c), as amended on December I, 2006: (c)Paoacrias or FlAY.N$ Suatcr m$uwowu. (I) A party at an &rem, responsible fa the issuance and service ore robpans shall Like ressonstdc stem to .mad nmicang undue burden of apace on a person **jut to Ili mboxnA. The corm ce hehdf of which the subporrin wet limed shall enforce this day and impose tgen the party or many in hatch fifths nay an Approptime &meta which nay mclude, bate nee limited to. lx earnings 3 renerolik money's (CO (2) (A) A penal ccemnandei to produce and Fetnit 'moaner.. copying. wring or smaplingordeegnaled electronically gored efornation. hooka. PoPmh. damsn's ce leigtble Wimp. ia Witco.= or Forms Iwo] nOr *per in person at Me Frac of production or otiptai011 non Olaltariel...11 b "MI me &posit:on baring or bad tanukalloPmagnch(d)(7)0(eni rule.* Main eseavanded PprOduceind palms inspecnon, copying testing, a wnpiinp nay. withn IF 4)3 spun kly ,3 of the 9.8porra cc Wan the tau mecifnil for COMIT‘ tir-C, .r etch hag it lot Than Ie dart afar Wnifa MAYC open the pony or seamy dessmined in the subpoena %TUX.] apicelipl ID prCauCing any or el oldie doesporedwacrialser innecrion °fibs minims — cc to producing electunically tweed info:mown si the fernier (uniformed Ifobjemoi is re& the piny ravine the subacto gal: AC4 be eluded inlayed. copy. ester >septette menials ceinnott Ile porno except pursuant man coda of the *oat by which die sapient was Tend I folnatiori hu teen nude, the party saving the subpoena may, upre atica to the man ceaunnided m pretax. more ay one IS in ads m weed he geo4nake. cavemen 0311515€ swing or Cancling, Seri it °ear .° MAP*/ than paces WY casco whois so • party or an otrKu of sooty from signi6aust expense tootling from the Spectre, copying terms& a tanstiag commanded (3) (A) eh Ontlymence. Pre mein by whole witoteaa was .anal shalt nasal ornehty the subpxno Wk (a) faits mallow rasonable time for complonec (a) rerun a perm who it nonparty o: as, officer of a patty m trawl to • place =fete I00 ranee fian the plait what that penal rest. newton:dor regularty pantos Meseta in person. ccoptantasibjen lothcomisicatofebrese(c)(110:04)ofthisritle.sech a pinta may M oda to amend mat to consnanded to travel horn any sub plan within the pore in which etc nal is held, (m)omens &drat of Privileged a other prattled inter end no cacao, or new aPPIte4 or (iv) mitteco o paten to undue burden (B) If umbra= niquito disclosure of a codeine-re or OthrfOnraclaitial inkra.flaveloproall a oarsman, Warne/re. or (ii) renultes disctosure of an uregamed mixt' prom or gramma, not donating specific events ce occormlices in dispose rod foulest from the expert's duty node nods; mina awry piety, or (ti) tepees a pawns alto as nor a pony or an &erneof. pony paces substantial engem: la bawl =RC than I CO mitt so and etial, the court meg to Facet • pence labial ma offened by the ',bean& spans a muMfY to mahlassehah if the MIT m whose behalf the subpoena is earned a.. O a sub:uncial need for the testisenr, or notate that canoe be otherwise mg 'Aleut endue hardship and ammo that en pan to wham the sabpxna es rekkessed sea be sammontly compawased.the nun may order ppalacea seuctioion only axe specified ceednions. (d) DUTIES ORESPOPOING TOSUProara. (I) (A) A penes stipOnding to a subpoena to peace documents shad prorates than as Sty Are kept n dnusal cameo( Waken Or Shell Minim are Libel Mon to correspond with the categories is S dent (B)Ifa soteccenclocs not sooty the former fauns forprodocingelectronicily stored infamy:on. a paste rowed% mambo:au smut produce the mfermatax inform or Semifluid& the person catihnily IMISItilitet n a inform cs MI101 that am rommalohy usable (C)A persostoptedmg tea subpoena pool as ;codex the same docuonialy awed infanta°. in mesa than ate form. (0) A penal Ottp0C4fog loosebox= peed pot Fordo discos), of elonaroicalh mind informetire Son armors Am depown 'Omaha a not moveably accessable because of undie burden cc can. On =non toxin* discover/ or to mask the pence flan wban duo:way nom& must show to the albrmence murk In rat twaubly axe:aide boos °fondue boa= a cost treat skowint is made. Me cant num nossearient order discovery saeltscuroes noncoms party show:. Wand mine ccesidenagthe lamination of Rule ibIli/(2XCI The CAW day spo.-4 ,:ench:,ons eta the slucovery. (2)(A) When laminae labial te or abyvena n withhddat edam thal ka privileged a subject to praecox is trial.prepar soon ntreratis, et Lom shah be made alas* and shall be riposted by a description of tee solute &the dower" eatorarnicatiorn, away moduced Mat is Wrenn: to Gable its,: &trending party to contest Mechem. MI Winton...don is prottuoid m r open% ton subpoena that Is Subject Ai a claim of ;talky a *topple:6m at trial-trepan:go meenal,de person making the clam may nay any patty lad MOWS the Sam sten of to cam and the bens lbe it. Ago teed wand a pany man meetly ream% scqutAla, n iittrvy ese specified information and any copier it Ins aid may net a at diAdalt ofooneima and the ChM ri MICAH: A receiving pay may pranpdy present the ingninfire m rho court ran seal fag darrrninbon of theelan If the rectivkig petty disclosed the is Monne before being notified, is mutt take tearonable stops as reteme it Ile pence who Featured the information nag simian the information acid AOCIlial is tescived. (elCowtsaarl. I:MN/co/nay past without aiecaue co:ute mWeyer subpoena served oPre that person nay be deemed a contenpt of Die court from *huh the subpoena timed. AA adequate case for linen to obey mina what a sublimes perpms to mount a nonparty to attend ce potter tinplate noe winos the limits punted by clause (incest:pangs* (c)(3)(A) EFTA00726286 EXHIBIT A Instructions: (a) "Jeffrey Epstein" shall refer to Jeffrey Epstein, as well as his employees (current and former), portfolio managers, analysts, agents, associates, partners, trustees, limited partners, companies related by common ownership or agreement, affiliated organizations, subsidiaries, consultants, accountants, advisors, directors, officers, predernsors or successors in interest, attorneys, and all other authorized representatives acting on its behalf or otherwise subject to his control. (b) The term "document" or "documents" shall broadly mean and include all originals or, if not available, all copies of originals, and all non-identical copies of all written, typed, recorded or graphic matter, as well as all attachments, agenda, and appendices thereto, of any nature or description whatsoever, wherever located, and in whatever form or condition, including but not limited to all letters, correspondence, telegrams, faxes, e-mails, electronic communications, cd- roms, hard drives, memoranda, notes, fee statements, records of legal services rendered, summaries, diaries, diary entries, calendars, appointment books, time records, visitor records, work records, telephone bills and records, expense records, travel and entertainment records, inspections, estimates, reports, journals, journal entries, ledgers, ledger entries, worksheets, work papers, accounting records, bank records, bank statements, cancelled checks, check stubs, check books, deposit receipts, employee records, payroll records, drafts, invoices, fee statements, books, articles, magazines, circulars, trade letters, press clippings, surveys, statistical data, graphs, maps, charts, transcripts, microfilm, microfiche, voice recordings, video recordings, tape or disc recordings, film, photographs, punch cards, programs, electronic recordings, any other data compilations for which information can be obtained or translated, and any summaries or drafts of the foregoing. (c) "Communications" includes, without limitation, every manner or means of statement, utterance, notation, disclaimer, transfer, or exchange of information of any nature whatsoever, by or to whomever, whether oral or written or whether face to face, by telephone, mail, personal delivery or otherwise, including but not limited to, letters, correspondence, conversations, memoranda, dialogue, discussions, meetings, interviews, consultations, agreements and other understandings. (d) The time period for these Requests for Production is January 1, 2000 to the present, unless otherwise stated. Document Requests: 1. Any all documents evidencing or relating to communications by and between Jeffrey Epstein and or Albert G. III, as well as their empire. current and former), attorneys, including any lawyer from the law firm of Bickel & entities or companies related by common ownership or agreement, including but not limited to Al-ITrey Investments, affiliated organizations, and all other authorized representatives acting on their behalf or otherwise subject to their control. D 1528188 v1-23444/0004 PLEADINGS EFTA00726287 2. Any and all documents provided to Jeffrey Epstein by ■ or Albert G. IN, HI, as well as theirfinkees (current and former), attorneys, including any lawyer from the law firm of Bickel & entities or companies related by common ownership or agreement, affiliated organizations, including but not limited to AHTrey Investments, and all other authorized representatives acting on their behalf or otherwise subject to their control. 3. Any and all documents provided to or Albert G.., III, as well as their S ees (current and former), attorneys, including any lawyer from the law firm of Bickel & entities or companies related by common ownership or agreement, affiliated organizations, including but not limited to AHTrey Investments, and all other authorized representatives acting on their behalf or otherwise subject to their control, by Jeffrey Epstein. D 1528188 v1-23444/0004 PLEADINGS EFTA00726288