Epstein Secrets

Civil Action No. 15-cv-07433-RWS SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION To: David N. Rodgers, do Bruce Reinhart, McDonald Hopkins LLC, (Name of person to whom this subpoena is directed) ye Production: YOU ARE COMMANDED to produce at the ti

ICE OF RULE 45 SUBPOENA FOR DOCUMENTS UPON DAVID RODGERS (A/K/A DAVE RODGERS) PLEASE TAKE NOTICE THAT, pu

NTIFF'S NOTICE OF SERVICE OF RULE 45 SUBPOENA FOR DOCUMENTS UPON DAVID RODGERS (A/K/A DAVE RODGERS) PLEASE TAKE NOTICE THAT, pursuant to Rule 45 of the Federal Rules of Civil Procedure, Plaintiff, hereby provides Notice of Service of Subpoena upon David Rodgers (a/k/a Dave Rodgers). A copy of the Subpoena is attached to

esented (Epstein's number one co-conspirator who was actually named as such in the NPA), his housekeeper his pilots Larry Morrison, Larry Visoski, David Rogers, William Hammond and Robert Roxburgh. (Hammond and Roxburgh were not deposed, but the others were.) See depositions of these individuals in various

we are also writing to ask for your non-opposition to Jane Doe No. 3 and Jane Doe No. 4's motion to intervene in the case. As you know, Rule 24 of the Federal Rules of Civil Procedure allows intervention on two grounds: Mandatory intervention is allowed where a putative intervenor "claims an inter relating to the . . .

aid for legal representation for (Epstein's executive assistant and procurer of girls for him to abuse), Larry Visoski (Epstein's personal pilot), Dave Rogers (Epstein's personal pilot), Larry Harrison (Epstein's personal pilot), Ghislaine Maxwell (manager of Epstein's affairs and businesses) , Mark Epst

al place of abode with Mark, a person of suitable age and discretion who resides there . . . ." 8. The foregoing service constituted proper service the Federal Rules of Civil Procedure. See Fed. R. Civ. P. 4(e)(2)(B). Under the Federal Rules of Civil Procedure, an answer to a properly served complaint must be filed withi

interest in any witness, subject, or t et of the E stein invests ation includin Ghislaine Maxwell, , Louella Ruboyo, Larry Morrison, Larry Visold, David Rogers, William Hammond, and Robert Roxburgh; c) All documents, correspondence, and other information reflecting telephone calls (includin telephone logs

e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic

lvement in and/or awareness of the Government's n witness, subject, or tar et of the Epstein i including )111%1;6 Maxwell, Larry Morrison, iso , David Rogers, William Hammond, and Robert Roxburgh; c) All documents, correspondence, and other information reflecting telephone calls (includin telephone logs

e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic

Household Age 51 Median Income: $111,607 Median Home Value: $475,000 Median Education: 14 years Household Members None Listed Other Associates RODGERS, DAVID N 6:49 ZORRO RANCH RD BH STANLEY, NM 87056-9743 Address Dates Phone 49 ZORRO RANCH RD BH 7/2015 -112015 STANLEY, NM 87056-9743 SANTA F

76 2015 U.S. Dist. LEXIS 87203, * already served their Rule 26(a)(1) disclosures (DE 266 at 13), and although this Court has repeatedly held that the Federal Rules of Civil Procedure "govern the general course of this proceeding," the Government maintains that the rule governing initial disclosures in civil litigation

areness of the Government's • • witness, subject, or t ' investigation, includin Ghislaine Maxwell, Lesley Groff, Larry Morrison, Larry Visoki, David Rogers, William Hammond, and Robert Roxburgh; c) All documents, correspondence, and other information reflecting telephone calls (including telephone log

e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic