EFTA00018214.pdf

AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case
UNITED STATES DISTRICT COURT
for the
Southern District of New York
United States of America
v.
Ghislaine Maxwell
Defendant
Case No. 20CR330 (AJN)
SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR
OBJECTS IN A CRIMINAL CASE
To: Jordana Feldman
(Name of person to whom this subpoena is directed)
YOU ARE COMMANDED to produce at the time, date, and place set forth below the following books, papers,
documents, data, or other objects:
See Attachment A
Place: United States District Court
Southern District of New York, Courtroom 318
40 Foley Square, New York, NY 10007
Date and Time: 11/29/2021 8:30 am
Certain provisions of Fed. R. Crim. P. 17 are attached, including Rule 17(c)(2), relating to your ability to file a
motion to quash or modify the subpoena; Rule 17(d) and (e), which govern service of subpoenas; and Rule 17(g),
relating to your duty to respond to this subpoena and the potential consequences of not doing so.
(SEAL)
Date:
CLERK OF COURT
Signature of Clerk or Deputy Clerk
The name, address, e-mail, and telephone number of the attorney representing (name of party) Ghislaine Maxwell
, who requests this subpoena, are:
Jeffrey S. Pagliuca, Haddon, Morgan & Foreman P.C., 150 East 10th Ave., Denver, Colorado 80203, [REDACTED]
Notice to those who use this form to request a subpoena
Before requesting and serving a subpoena pursuant to Fed. R. Crim. P. 17(c), the party seeking the subpoena is advised to
consult the rules of practice of the court in which the criminal proceeding is pending to determine whether any local rules
or orders establish requirements in connection with the issuance of such a subpoena. If no local rules or orders govern
practice under Rule 17(c), counsel should ask the assigned judge whether the court regulates practice under Rule 17(c) to
1) require prior judicial approval for the issuance of the subpoena, either on notice or ex parte; 2) specify where the
documents must be returned (e.g., to the court clerk, the chambers of the assigned judge, or counsel’s office); and 3)
require that counsel who receives produced documents provide them to opposing counsel absent a disclosure obligation
under Fed. R. Crim. P. 16.
Please note that Rule 17(c) (attached) provides that a subpoena for the production of certain information about a victim
may not be issued unless first approved by separate court order.
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AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case (Page 2)
Case No. 20CR330 (AJN)
PROOF OF SERVICE
This subpoena for (name of individual and title, if any)
was received by me on (date)
I served the subpoena by delivering a copy to the named person as follows:
on (date) ; or
I returned the subpoena unexecuted because:
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 $ for travel and $ for services, for a total of $ 0.00
I declare under penalty of perjury that this information is true.
Date:
Server’s signature
Printed name and title
Server’s address
Additional information regarding attempted service, etc.:
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AO 89B (07/16) Subpoena to Produce Documents, Information, or Objects in a Criminal Case (Page 3)
Federal Rule of Criminal Procedure 17 (c), (d), (e), and (g) (Effective 12/1/08)
(c) Producing Documents and Objects.
(1) In General. A subpoena may order the witness to produce any books, papers, documents, data, or other objects the subpoena
designates. The court may direct the witness to produce the designated items in court before trial or before they are to be offered in
evidence. When the items arrive, the court may permit the parties and their attorneys to inspect all or part of them.
(2) Quashing or Modifying the Subpoena. On motion made promptly, the court may quash or modify the subpoena if compliance
would be unreasonable or oppressive.
(3) Subpoena for Personal or Confidential Information About a Victim. After a complaint, indictment, or information is filed, a
subpoena requiring the production of personal or confidential information about a victim may be served on a third party only by court
order. Before entering the order and unless there are exceptional circumstances, the court must require giving notice to the victim so that
the victim can move to quash or modify the subpoena or otherwise object.
(d) Service. A marshal, a deputy marshal, or any nonparty who is at least 18 years old may serve a subpoena. The server must deliver a copy
of the subpoena to the witness and must tender to the witness one day’s witness-attendance fee and the legal mileage allowance. The server
need not tender the attendance fee or mileage allowance when the United States, a federal officer, or a federal agency has requested the
subpoena.
(e) Place of Service.
(1) In the United States. A subpoena requiring a witness to attend a hearing or trial may be served at any place within the United
States.
(2) In a Foreign Country. If the witness is in a foreign country, 28 U.S.C. § 1783 governs the subpoena’s service.
(g) Contempt. The court (other than a magistrate judge) may hold in contempt a witness who, without adequate excuse, disobeys a subpoena
issued by a federal court in that district. A magistrate judge may hold in contempt a witness who, without adequate excuse, disobeys a
subpoena issued by that magistrate judge as provided in 28 U.S.C. § 636(e).
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ATTACHMENT A
DEFINITIONS
1. “You” or “Your” means any owner, shareholder, partner or employee of the Epstein Victim's
Compensation Program ("EVCP"), and any former owner, shareholder, partner or employee
of the EVCP.
2. “Accusers” or “Accuser” means [REDACTED], [REDACTED], [REDACTED], and [REDACTED].
3. Attorneys means legal counsel for any Accuser or the EVCP.
4. “Communication” means all forms of correspondence, including regular mail, email, text
message, memorandum, or other written communication of information of any kind.
5. “EVCP Material” refers to any submission to the Epstein Victim’s Compensation Program
made by an Accuser, including any claims on behalf of persons who have accused Jeffrey
Epstein or Ghislaine Maxwell of any misconduct, any releases signed by an Accuser or their
Attorneys, and any compensation received by an Accuser.
INSTRUCTIONS
1. Production of documents and items requested herein shall be made in person to United States
District Court, Southern District of New York, 40 Foley Square, New York, NY 10007,
Courtroom 318.
2. This Request calls for the production of all responsive Documents in Your possession,
custody or control without regard to the physical location of such documents.
3. If any Document was in your possession or control, but is no longer, state what disposition
was made of said Document, the reason for the disposition, and the date of such disposition.
4. In producing Documents, if the original of any Document cannot be located, a copy shall be
produced in lieu thereof, and shall be legible and bound or stapled in the same manner as the
original.
5. Any copy of a Document that is not identical shall be considered a separate document.
6. All Documents shall be produced in the same order as they are kept or maintained by You in
the ordinary course of business.
7. Responsive electronically stored information (ESI) shall be produced in its native form; that
is, in the form in which the information was customarily created, used and stored by the
native application employed by the producing party in the ordinary course of business.
8. Defendant does not seek and does not require the production of multiple copies of identical
Documents.
9. This Request is deemed to be continuing. If, after producing these Documents, you obtain or
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become aware of any further information, Documents, things, or information responsive to
this Request, you are required to so state by supplementing your responses and producing
such additional Documents to Defendant.
DOCUMENTS OR THINGS TO BE PRODUCED
1. Any and all EVCP Material submitted by each Accuser, not limited to Claim Forms and
supporting submissions made by each Accuser;
2. Communications between the EVCP to each of the Accusers and/ or their Attorneys;
3. Copies of any payments to the Accusers and their Attorneys;
4. Any and All Releases executed by the Accusers.
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