Epstein Secrets

18205 Biscayne Bolevard Suite 2218 Miami, FL 33160 Received by MIMAI-DADE PROCESS, INC. on the 24th day of July, 2009 at 4:00 pm to be served on ALFREDO RODRIGUEZ, 11349 SW 86 LANE, MIAMI, FL. I, RAFAEL (BUDA) GONZALEZ. do hereby affirm that on the 25th day of July, 2009 at 5:24 pm, I: Individually Served the

09, Alfredo Rodriguez, a nonparty, was personally served a subpoena duces tecum to appear for deposition on July 29, 2009 ("the subpoena'). I The I Rodriguez was originally scheduled to appear for deposition on July 23, 2009, but failed to appear, claiming that he had "car troubles." Plaintiffs' counsel a

Road 13 Suite 228 North Miami, Eland,' 14 August 7, 2009 1:15 p.m. to 5:30 p.m. 15 16 CONTINUED 17 VIDEOTAPED 18 DEPOSITION 19 CC 20 ALFREDO RODRIGUEZ 21 22 taken on behalf of the Plaintiffs pursuant 23 to a Re-Notice of Taking Continued Videotaped 24 Deposition (Duces Team) 25 Page 272 Page 271 1

rules includes not only documents in the nonparty's possession, but also "the legal right to obtain the documents requested on demand." Searock v. Stripling, 736 F.2d 650 (11th Cir. 1984). Rodriguez has this right to obtain the subpoenaed documents under Battlev or in the normal course of discovery in hi

____________________________________/ PLAINTIFF JANE DOE NO. 2’s MOTION TO COMPEL COMPLIANCE WITH SUBPOENA AND FOR ORDER OF CONTEMPT AGAINST ALFREDO RODRIGUEZ, 1. On July 25, 2009, Alfredo Rodriguez, a nonparty, was personally served a subpoena duces tecum to appear for deposition on July 29, 2009 (“the

z, and Incorporated Memorandum of Law, pursuant to Fed.R.Civ.P. 45(e), and state as follows: 1 1 Rodriguez was originally scheduled to appear for deposition on July 23, 2009, but failed to appear, claiming that he had “car troubles.” Plaintiffs’ counsel

lfredo Rodriguez has, at the very least, a right to possession of the documents that are the subject of the Plaintiff’s subpoena. Searock v. Stripling, 736 F.2d 650 (11th Cir. 1984). Rodriguez has this right to obtain the subpoenaed documents under Bagley or in the normal course of discovery in hi

____/ ORDER THIS CAUSE is before the Court on Plaintiff Jane Doe No.2's Motion to Compel Compliance with Subpoena and for Order of Contempt Against Alfredo Rodriguez (D.E. #469). The time period for filing a response in opposition to the subject Motion has passed and Mr. Rodriguez has elected to not file a respons

Order of Contempt Against Alfredo Rodriguez (D.E. #469). The time period for filing a response in opposition to the subject Motion has passed and Mr. Rodriguez has elected to not file a response to the Motion. Noting Mr. Rodriguez’ failure to file a response to the Motion, it is hereby ORDERED AND ADJUDGED

y rules includes not only documents in the non-party’s possession, but also “the legal right to obtain the documents requested on demand.” Searock v. Stripling, 736 F.2d 650 (11 Cir. th 1984). Inasmuch as Rodriguez has the right to obtain the subpoenaed documents under Bagley or in the normal course of dis

e with Subpoena and for Order of Contempt Against Alfredo Rodriguez (D.E. #469). The time period for filing a respon

der of Contempt Against Alfredo Rodriguez (D.E. #469). The time period for filing a response in opposition to the subject Motion has passed and Mr. Rodriguez has elected to not file a response to the Motion. Noting Mr. Rodriguez' failure to file a response to the Motion, it is hereby ORDERED AND ADJUDGED

rules includes not only documents in the non-party's possession, but also "the legal right to obtain the documents requested on demand." Searock v. Stripling, 736 F.2d 650 (111" Cir. 1984). Inasmuch as Rodriguez has the right to obtain the subpoenaed documents under Bagley or in the normal course of disc