EFTA00806754.pdf

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Plaintiff, v. No. 17 Civ. 00616 (JGK) JEFFREY EPSTEIN, GHISLAINE MAXWELL, LESLEY GROFF and Defendants. PLAINTIFF'S NOTICE OF SERVICE OF RULE 45 SUBPOENA AND NOTICE OF TAKING VIDEOTAPED DEPOSITION OF DAVID RODGERS a/k/a DAVE RODGERS PLEASE TAKE NOTICE THAT, pursuant to Rules 30 and 45 of the Federal Rules of Civil Procedure, counsel for Plaintiff, will take a videotaped deposition as set forth below: NAME: David Rodgers a/k/a Dave Rodgers DATE AND TIME: November 19, 2018 at 9:00 a.m. LOCATION: Boies Schiller Flexner, LLP 401 E. Las Olas Boulevard, Ste. 1200 Fort Lauderdale, FL 33301 The videotaped deposition will be taken upon oral examination before Magna Legal Services, or any other notary public authorized by law to take depositions. The oral examination will continue from day to day until completed. The video operator shall be provided by Magna Legal Services. This deposition is being taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted under the rules of this Court. I EFTA00806754  Plaintiff, also hereby provides Notice of Service of Subpoena upon David Rodgers a/k/a Dave Rodgers. A copy of the Subpoena is attached to this Notice. Dated: October 25, 2018. BOIES SCHILLER FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Meredith Schultz (Pro Hac Vice) Boies Schiller Flexner LLP Bradley J. Edwards, Esq. (Pro Hac Vice) Stanley Pottinger, Esq. EDWARDS POTTINGER LLC Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah This daytime business address is provided for identification and correspondence purposes only and is not intended to imply institutional endorsement by the University of Utah for this private representation. 2 EFTA00806755  CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 25th day of October, 2018, I served the attached PLAINTIFF'S NOTICE OF SERVICE OF RULE 45 SUBPOENA AND NOTICE OF TAKING VIDEOTAPED DEPOSITION OF DAVID RODGERS a/k/a DAVE RODGERS via Email to the following counsel of record. Michael Miller Justin Y.K Chu Michael A. Keough Scott J. Link LINK & ROCKENBA H PA Counselfor Jeffrey Epstein, and Lesley Groff Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. Counselfor Ghislaine Maxwell By: /s/ Sigrid McCawlev Sigrid McCawley 3 EFTA00806756