DOJ-OGR-00030426.jpg
637 KB
Extraction Summary
5
People
1
Organizations
1
Locations
4
Events
3
Relationships
0
Quotes
Document Information
Type:
Legal document
File Size:
637 KB
Summary
This legal document, page 2 of a filing, details a dispute between opposing counsel regarding the deposition of "Jane Doe." The author, Jane Doe's attorney, alleges that Epstein's attorney, Jack Goldberger, ignored an agreement to find a mutually convenient date and improperly served subpoenas on both Jane Doe and her out-of-state mother for a date he knew Jane Doe's counsel was unavailable. The filing argues that the service on the mother was legally defective.
People (5)
| Name | Role | Context |
|---|---|---|
| Epstein |
Party in a civil lawsuit and criminal matter whose attorney is seeking a deposition.
|
|
| Jack Goldberger, Esq. | Epstein's criminal attorney |
Contacted the undersigned to schedule a deposition for Jane Doe, and is alleged to have improperly served subpoenas d...
|
| Jane Doe | Deponent |
The individual whose deposition is sought by Epstein's attorney in a criminal matter.
|
| The undersigned | Counsel for Jane Doe |
The author of the document, representing Jane Doe, who is recounting the events surrounding the scheduling of a depos...
|
| Jane Doe's mother |
Was served with a subpoena in Waleska, Georgia, in what is described as a defective service of process.
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| Ricci Leopold PA | Law firm |
Appears in the fax header of the document.
|
Timeline (4 events)
2008-02-04
Mr. Goldberger had a process server serve Jane Doe's mother with a subpoena.
Waleska, Georgia
Process server
Jane Doe's mother
2008-02-06
The date for which Jane Doe's deposition was unilaterally scheduled by Mr. Goldberger.
Week of 2008-01-25
Epstein's attorney, Jack Goldberger, contacted Jane Doe's attorney (the undersigned) to schedule a deposition.
Jack Goldberger
The undersigned
Locations (1)
| Location | Context |
|---|---|
|
The out-of-state residence of Jane Doe's mother.
|
Relationships (3)
The document states Goldberger is "Epstein's criminal attorney".
The undersigned states they would "accept service on behalf of Jane Doe," indicating a lawyer-client relationship.
They are opposing counsel in a legal matter, communicating about scheduling depositions and disagreeing on the process.
Full Extracted Text
Complete text extracted from the document (2,268 characters)
02/05/2008 TUE 12:38 FAX Ricci Leopold PA 002/006
3. After the filing of the civil lawsuit and during the week of January 25, 2008, Epstein's criminal attorney, Jack Goldberger, Esq., contacted the undersigned to advise that he wished to take the deposition, in the criminal matter, of Jane Doe on February 6, 2008. The undersigned informed Mr. Goldberger that he would accept service on behalf of Jane Doe, but was not available on February 6, 2008. Counsel agreed to use best efforts to schedule the deposition at a mutually convenient date and time.
4. Despite these assurances and understanding, on Friday evening, February 1, 2008, Epstein's process server served Jane Doe at her place of work for a deposition scheduled to take place on February 6, 2008. ¹ See Subpoena attached as Exhibit “A” (Jane Doe's real name has been redacted from the exhibit).
5. The undersigned was forced to call Mr. Goldberger on Friday evening and remind him of our earlier conversation and agreement and to insist that the deposition be re-noticed.²
6. After the conversation of Friday evening and with the expressed assurances that the undersigned would accept service for Jane Doe, two days later on Monday morning February 4, 2008, Mr. Goldberger had a process server serve Jane Doe's mother who resides out of state in Waleska, Georgia. See Subpoena attached as Exhibit “B” (Jane Doe's mother's name has been redacted from the exhibit).
7. The service of process on Jane Doe's mother was defective as an Out of State Commissioner was never appointed and no order was issued by this court authorizing such service. Additionally, Mr. Goldberger had been told not once, but twice that the undersign would accept service on behalf of Jane Doe, yet despite this Epstein and/or his attorney has insisted on
¹ Mr. Goldberger unilaterally set Jane Doe's deposition for February 6, 2008 despite knowing that the undersigned was not available on that date.
² Mr. Goldberger has now agreed to postpone the deposition.
² Mr. Goldberger has now agreed to postpone the deposition.
Page 2 of 3
07/26/17 Page 73 of 114 Public Records Request No.: 17-295
DOJ-OGR-00030426
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