001-03.pdf
3.97 MB
Extraction Summary
10
People
6
Organizations
5
Locations
3
Events
4
Relationships
4
Quotes
Document Information
Type:
Subpoena (civil action)
File Size:
3.97 MB
Summary
This document is a subpoena issued by the US District Court (SDNY) on behalf of Defendant Ghislaine Maxwell to attorney Bradley J. Edwards in May 2016. It demands the production of various documents, including those related to previous litigation involving Jeffrey Epstein and Alan Dershowitz, communications with journalist Sharon Churcher, and records regarding the organization 'Victims Refuse Silence, Inc.' A check for $45.00 payable to Edwards is included, likely as a witness fee.
People (10)
| Name | Role | Context |
|---|---|---|
| Virginia Giuffre | Plaintiff |
Plaintiff in the civil action; formerly known as Virginia Roberts.
|
| Ghislaine Maxwell | Defendant |
Defendant in the civil action.
|
| Bradley J. Edwards | Recipient/Attorney |
Recipient of the subpoena; attorney representing Giuffre in other matters.
|
| Laura Menninger | Attorney |
Attorney for Ghislaine Maxwell; issuing the subpoena.
|
| Jeffrey S. Pagliuca | Attorney |
Signatory on the subpoena for the Defendant.
|
| Thomas Loffredo | Attorney |
Contact at Gray Robinson law firm for document production.
|
| Jeffrey Epstein | Subject |
Mentioned in document requests regarding past cases and communications.
|
| Sharon Churcher | Journalist |
Specifically named in request #15 regarding communications.
|
| Alan Dershowitz | Litigant |
Mentioned in case name 'Edwards and Cassell v. Dershowitz'.
|
| Paul Cassell | Litigant |
Mentioned in case name 'Edwards and Cassell v. Dershowitz'.
|
Organizations (6)
| Name | Type | Context |
|---|---|---|
| United States District Court Southern District of New York |
Court where the civil action is filed.
|
|
| Haddon, Morgan & Foreman, PC |
Law firm representing Ghislaine Maxwell.
|
|
| Gray Robinson |
Law firm providing the location for document production in Florida.
|
|
| Professional Process Servers & Investigators, Inc. |
Company that issued the check for witness fees.
|
|
| JPMorgan Chase Bank, N.A. |
Bank on the check.
|
|
| Victims Refuse Silence, Inc. |
Organization mentioned in document requests (Items 10, 11, 16, 17).
|
Timeline (3 events)
2016-06-06
Locations (5)
| Location | Context |
|---|---|
|
Original printed address for Bradley J. Edwards (struck through).
|
|
|
Handwritten corrected address for service.
|
|
|
Address for document production (Gray Robinson).
|
|
|
Address of Haddon, Morgan & Foreman PC.
|
|
|
Address of Professional Process Servers & Investigators, Inc.
|
Relationships (4)
Subpoena requests engagement letters between You [Edwards] and Virginia Giuffre (Item 7).
Menninger is listed as the attorney representing Ghislaine Maxwell.
Subpoena requests documents relating to Edwards' formation of or work on behalf of the organization.
Subpoena specifically requests communications between Edwards/Giuffre and journalist Sharon Churcher.
Key Quotes (4)
"YOU ARE COMMANDED to produce at the time, date, and place set forth below the following documents"Source
001-03.pdf
Quote #1
"All Documents or communications that You have had with any journalist, reporter, producer, author, director... including without limitation Sharon Churcher"Source
001-03.pdf
Quote #2
"All Documents relating to Your formation of, association with, or work on behalf of Victims Refuse Silence, Inc."Source
001-03.pdf
Quote #3
"All Documents relating to Epstein v. Edwards et. al... referencing Virginia Giuffre, whether by name or as 'Jane Doe 3'"Source
001-03.pdf
Quote #4
Full Extracted Text
Complete text extracted from the document (8,322 characters)
Case 1:17-mc-00025-RWS Document 1-3 Filed 06/13/16 Page 1 of 9
Individual Service ONLY
AO 88B (Rev. 12/13) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action
AO 88B (Rev. 12/13) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action
PRIORITY
OBTAIN DESCRIPTION
UNITED STATES DISTRICT COURT
for the
Southern District of New York
OBTAIN DESCRIPTION
UNITED STATES DISTRICT COURT
for the
Southern District of New York
Virginia Guiffre
Plaintiff
v.
Ghislaine Maxwell
Defendant
Plaintiff
v.
Ghislaine Maxwell
Defendant
Civil Action No. 15-cv-07433-RWS
SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS
OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION
OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION
To: Bradley J. Edwards, 425 N. Andrews Ave Ste. 2 Ft. Lauderdale, Florida 33301
[Handwritten strikethrough and annotation]: 10141 40th Street, Davie, FL 33328
(Name of person to whom this subpoena is directed)
[Handwritten strikethrough and annotation]: 10141 40th Street, Davie, FL 33328
(Name of person to whom this subpoena is directed)
Production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following documents, electronically stored information, or objects, and to permit inspection, copying, testing, or sampling of the material:
See Attachment A
See Attachment A
Place: Laura Menninger, Haddon, Morgan & Forman, PC
C/O Thomas Loffredo, Gray Robinson, 401 E. Las Olas Blvd., Suite 1000, Ft. Lauderdale FL 33301
C/O Thomas Loffredo, Gray Robinson, 401 E. Las Olas Blvd., Suite 1000, Ft. Lauderdale FL 33301
Date and Time: 06/06/2016 5:00 am
[Handwritten notes in margin]: 5/28 7:58 pm
6/01 9:05 AM
K1920
6/01 9:05 AM
K1920
[Check Image]
31834
PROFESSIONAL PROCESS SERVERS & INVESTIGATORS, INC.
PH. 954-566-2523
1749 NE 26TH STREET STE A
WILTON MANORS, FL 33305
31834
PROFESSIONAL PROCESS SERVERS & INVESTIGATORS, INC.
PH. 954-566-2523
1749 NE 26TH STREET STE A
WILTON MANORS, FL 33305
JPMORGAN CHASE BANK, N.A.
WWW.CHASE.COM
63-8413/2670
5/27/2016
WWW.CHASE.COM
63-8413/2670
5/27/2016
PAY TO THE ORDER OF Bradley J. Edwards
$**45.00
Forty-Five Only****** DOLLARS
$**45.00
Forty-Five Only****** DOLLARS
MEMO Menninger
[Signature]
[Signature]
Case 1:17-mc-00025-RWS Document 1-3 Filed 06/13/16 Page 2 of 9
[Duplicate of Page 1 with Signature]
Date: 05/23/2016
CLERK OF COURT
Signature of Clerk or Deputy Clerk
OR
Attorney's signature: /s/ Jeffrey S. Pagliuca
[Duplicate of Page 1 with Signature]
Date: 05/23/2016
CLERK OF COURT
Signature of Clerk or Deputy Clerk
OR
Attorney's signature: /s/ Jeffrey S. Pagliuca
The name, address, e-mail address, and telephone number of the attorney representing (name of party) Ghislaine Maxwell, who issues or requests this subpoena, are:
Laura Menninger, Haddon, Morgan & Foreman PC, 150 East 10th Ave., Denver, Colorado 80203, 303.831.7364, lmenninger@hmflaw.com
Laura Menninger, Haddon, Morgan & Foreman PC, 150 East 10th Ave., Denver, Colorado 80203, 303.831.7364, lmenninger@hmflaw.com
Case 1:17-mc-00025-RWS Document 1-3 Filed 06/13/16 Page 3 of 9
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)
[Form is blank/unfilled]
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)
[Form is blank/unfilled]
Case 1:17-mc-00025-RWS Document 1-3 Filed 06/13/16 Page 4 of 9
Federal Rule of Civil Procedure 45 (c), (d), (e), and (g) (Effective 12/1/13)
[Standard legal text of Rule 45 regarding Place of Compliance, Protecting a Person Subject to a Subpoena, Duties in Responding to a Subpoena, and Contempt]
Federal Rule of Civil Procedure 45 (c), (d), (e), and (g) (Effective 12/1/13)
[Standard legal text of Rule 45 regarding Place of Compliance, Protecting a Person Subject to a Subpoena, Duties in Responding to a Subpoena, and Contempt]
Case 1:17-mc-00025-RWS Document 1-3 Filed 06/13/16 Page 5 of 9
ATTACHMENT A
DEFINITIONS
1. "Any" means any and all.
2. "You" or "Your" means Bradley Edwards, any firm with whom You have been affiliated in the relevant time period, and anyone acting on Your behalf, and any employee, agent, attorney, consultant, assignee, related entities or other representative of You.
3. "Agent" shall mean any agent, employee, officer, director, attorney, independent contractor or any other person acting, or purporting to act, at the discretion of or on behalf of another.
4. "Document" is intended to be defined as broadly as permitted by Rule 34...
5. "Communication" means any transmission or exchange of information...
6. "Virginia Roberts Giuffre" means Virginia Giuffre, formerly known as Virginia Roberts, date of birth August 9, 1983, the Plaintiff in the above captioned matter.
7. "Identify" means to specify as to a "Person," the name, address, telephone number and any other identifying information possessed by You.
8. "Person" means any natural person...
9. Regardless of the tense employed, all verbs should be read as applying to the past, present and future...
ATTACHMENT A
DEFINITIONS
1. "Any" means any and all.
2. "You" or "Your" means Bradley Edwards, any firm with whom You have been affiliated in the relevant time period, and anyone acting on Your behalf, and any employee, agent, attorney, consultant, assignee, related entities or other representative of You.
3. "Agent" shall mean any agent, employee, officer, director, attorney, independent contractor or any other person acting, or purporting to act, at the discretion of or on behalf of another.
4. "Document" is intended to be defined as broadly as permitted by Rule 34...
5. "Communication" means any transmission or exchange of information...
6. "Virginia Roberts Giuffre" means Virginia Giuffre, formerly known as Virginia Roberts, date of birth August 9, 1983, the Plaintiff in the above captioned matter.
7. "Identify" means to specify as to a "Person," the name, address, telephone number and any other identifying information possessed by You.
8. "Person" means any natural person...
9. Regardless of the tense employed, all verbs should be read as applying to the past, present and future...
Case 1:17-mc-00025-RWS Document 1-3 Filed 06/13/16 Page 6 of 9
10. With respect to any Documents withheld on the basis of a privilege, provide a log consistent with Local Rule 26.2...
INSTRUCTIONS
1. Production of documents and items requested herein shall be made Laura Menninger, Haddon, Morgan & Forman, PC... no later than June 6, 2016, at 5:00 p.m.
[Instructions 2-10 detailing production format, ESI, continuing obligation, etc.]
10. With respect to any Documents withheld on the basis of a privilege, provide a log consistent with Local Rule 26.2...
INSTRUCTIONS
1. Production of documents and items requested herein shall be made Laura Menninger, Haddon, Morgan & Forman, PC... no later than June 6, 2016, at 5:00 p.m.
[Instructions 2-10 detailing production format, ESI, continuing obligation, etc.]
Case 1:17-mc-00025-RWS Document 1-3 Filed 06/13/16 Page 7 of 9
DOCUMENTS TO BE PRODUCED
1. All Documents produced to You by the opposing party or pursuant to F.R.Civ.P. 45 in Edwards and Cassell v. Dershowitz, 15-000072, (17th Judicial District, Broward County, Florida).
2. All Documents produced by You to the opposing party in Edwards and Cassell v. Dershowitz, 15-000072...
3. All Documents produced by You to the opposing party or obtained by subpoena in Epstein v. Edwards et. al., Case No 50-2009 CA 04080OXXXXMBAG (15th Judicial Circuit, West Palm Beach, Florida).
4. All Documents produced to You by the opposing party in Epstein v. Edwards et. al...
5. All Documents relating to Epstein v. Edwards et. al... referring to or referencing Virginia Giuffre, whether by name or as "Jane Doe 3," including notes, records, memorandum, emails, or other documentation.
6. All Documents or discovery responses produced to You in Jane Doe #1 et al. v. United States, 08-cv-80736-KAM (U.S. District Court, Southern District of Florida).
7. All engagement letters by or between You and Virginia Giuffre.
8. All joint defense agreements or common interest agreements to which You are a party that relate in any manner to any case, claim, cause of action, investigation, or other proceeding in which Virginia Roberts Giuffre is involved in any manner, as a party, potential witness, or otherwise.
9. All joint defense agreements or common interest agreement to which Virginia Roberts Giuffre is a party.
10. All Documents relating to Your formation of, association with, or work on behalf of Victims Refuse Silence, Inc.
11. All Documents relating to any disclosures made by You to Victims Refuse Silence, Inc., or any person associated with Victims Refuse Silence, Inc., including disclosures pursuant to any of the Florida Rules of Professional Conduct, including Rule 4-1.8.
12. All Documents relating to any disclosures made by You by Virginia Roberts Giuffre, or consents provided to You by Virginia Roberts Giuffre, pursuant to any of the Florida Rules of Professional Conduct.
DOCUMENTS TO BE PRODUCED
1. All Documents produced to You by the opposing party or pursuant to F.R.Civ.P. 45 in Edwards and Cassell v. Dershowitz, 15-000072, (17th Judicial District, Broward County, Florida).
2. All Documents produced by You to the opposing party in Edwards and Cassell v. Dershowitz, 15-000072...
3. All Documents produced by You to the opposing party or obtained by subpoena in Epstein v. Edwards et. al., Case No 50-2009 CA 04080OXXXXMBAG (15th Judicial Circuit, West Palm Beach, Florida).
4. All Documents produced to You by the opposing party in Epstein v. Edwards et. al...
5. All Documents relating to Epstein v. Edwards et. al... referring to or referencing Virginia Giuffre, whether by name or as "Jane Doe 3," including notes, records, memorandum, emails, or other documentation.
6. All Documents or discovery responses produced to You in Jane Doe #1 et al. v. United States, 08-cv-80736-KAM (U.S. District Court, Southern District of Florida).
7. All engagement letters by or between You and Virginia Giuffre.
8. All joint defense agreements or common interest agreements to which You are a party that relate in any manner to any case, claim, cause of action, investigation, or other proceeding in which Virginia Roberts Giuffre is involved in any manner, as a party, potential witness, or otherwise.
9. All joint defense agreements or common interest agreement to which Virginia Roberts Giuffre is a party.
10. All Documents relating to Your formation of, association with, or work on behalf of Victims Refuse Silence, Inc.
11. All Documents relating to any disclosures made by You to Victims Refuse Silence, Inc., or any person associated with Victims Refuse Silence, Inc., including disclosures pursuant to any of the Florida Rules of Professional Conduct, including Rule 4-1.8.
12. All Documents relating to any disclosures made by You by Virginia Roberts Giuffre, or consents provided to You by Virginia Roberts Giuffre, pursuant to any of the Florida Rules of Professional Conduct.
Case 1:17-mc-00025-RWS Document 1-3 Filed 06/13/16 Page 8 of 9
13. All Documents concerning any investigation by any law enforcement agency that refer to Ghislaine Maxwell.
14. All Documents concerning any contracts or agreements between you and any other individual or entity that concern the publication of information related to any claim by Virginia Giuffre, fka Virginia Roberts that she was a victim of sexual abuse.
15. All Documents or communications that You have had with any journalist, reporter, producer, author, director, or any employee or agent of the same, including without limitation Sharon Churcher, which relate or refer to Virginia Giuffre, Ghislaine Maxwell or Jeffrey Epstein.
16. All documents or communications concerning any payments made to you or your law firm arising out of your representation of Virginia Roberts Giuffre or Victims Refuse Silence.
17. All documents or communications concerning any payments to you, your law firm, Virginia Roberts Giuffre, or Victims Refuse Silence from or on behalf of any media organization. The term "media organization" means "a person or entity engaged in disseminating information to the general public through a newspaper, magazine, other publication, radio, television, cable television, or other medium of mass communication." 2 USCS § 1602.
18. Please make available for inspection and copying the original of all photographs in your possession of Virginia Roberts Giuffre, including, but not limited to, all photographs appearing in any court papers, printed in any media publication or provided to any media organization.
19. Any letter or communication from you to any witness or prospective witness in Giuffre v. Maxwell, 15-cv-07433-RWS.
20. Any letter or communication to you from any witness or prospective witness in Giuffre v. Maxwell, 15-cv-07433-RWS.
13. All Documents concerning any investigation by any law enforcement agency that refer to Ghislaine Maxwell.
14. All Documents concerning any contracts or agreements between you and any other individual or entity that concern the publication of information related to any claim by Virginia Giuffre, fka Virginia Roberts that she was a victim of sexual abuse.
15. All Documents or communications that You have had with any journalist, reporter, producer, author, director, or any employee or agent of the same, including without limitation Sharon Churcher, which relate or refer to Virginia Giuffre, Ghislaine Maxwell or Jeffrey Epstein.
16. All documents or communications concerning any payments made to you or your law firm arising out of your representation of Virginia Roberts Giuffre or Victims Refuse Silence.
17. All documents or communications concerning any payments to you, your law firm, Virginia Roberts Giuffre, or Victims Refuse Silence from or on behalf of any media organization. The term "media organization" means "a person or entity engaged in disseminating information to the general public through a newspaper, magazine, other publication, radio, television, cable television, or other medium of mass communication." 2 USCS § 1602.
18. Please make available for inspection and copying the original of all photographs in your possession of Virginia Roberts Giuffre, including, but not limited to, all photographs appearing in any court papers, printed in any media publication or provided to any media organization.
19. Any letter or communication from you to any witness or prospective witness in Giuffre v. Maxwell, 15-cv-07433-RWS.
20. Any letter or communication to you from any witness or prospective witness in Giuffre v. Maxwell, 15-cv-07433-RWS.
Case 1:17-mc-00025-RWS Document 1-3 Filed 06/13/16 Page 9 of 9
[High resolution copy of check]
PROFESSIONAL PROCESS SERVERS & INVESTIGATORS, INC.
31834
JPMORGAN CHASE BANK, N.A.
5/27/2016
PAY TO THE ORDER OF Bradley J. Edwards
$45.00
Forty-Five Only
MEMO Menninger
[High resolution copy of check]
PROFESSIONAL PROCESS SERVERS & INVESTIGATORS, INC.
31834
JPMORGAN CHASE BANK, N.A.
5/27/2016
PAY TO THE ORDER OF Bradley J. Edwards
$45.00
Forty-Five Only
MEMO Menninger
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