# UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK



Plaintiff,

CASE NO: 19-cv-10475-LGS-DCF

V.

DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN and GHISLAINE MAXWELL,

Defendants.

# PLAINTIFF NOTICE OF DEPOSITION
OF DEFENDANT GHISLAINE MAXWELL

PLEASE TAKE NOTICE that, pursuant to Federal Rule of Civil Procedure 30, Plaintiff by and through her attorneys, will take the oral deposition of Defendant Ghislaine Maxwell on April 29, 2020, beginning at 10:00 a.m. Eastern Standard Time at the offices of Boies Schiller Flexner LLP, unless the parties mutually agree to hold the deposition on a different date or time and/or at a different location.

The deposition will be taken before a duly qualified notary public or other officer authorized by law to administer oaths and record testimony pursuant to Federal Rule of Civil Procedure 28. The deposition will be recorded by video, audio, and stenographic means. The deposition may be used to preserve testimony for trial, to obtain discovery, and for any other purpose authorized by the Federal Rules of Civil Procedure.

EFTA00031388

Dated: March 24, 2020

By: /s/ Sigrid McCawley
Sigrid McCawley (Pro Hac Vice)
Boies Schiller Flexner LLP

David Boies
Boies Schiller Flexner LLP

Joshua I. Schiller
Andrew Villacastin
Sabina Mariella
Boies Schiller Flexner LLP

Counsel for

2

EFTA00031389

# CERTIFICATE OF SERVICE

WE HEREBY CERTIFY that a true and correct copy of the above and foregoing Notice of Deposition has been provided by electronic mail to all counsel of record identified below, on this 24th day of March, 2020.

Laura Menninger, Esq.
HADDON MORGAN FOREMAN P.C.

Tel:
Fax:
Email:

Counsel for Defendant Ghislaine Maxwell

Bennet J. Moskowitz, Esq.
Molly S. DiRago, Esq.
TROUTMAN SANDERS LLP

Tel:
Fax:
Email:

Counsel for Defendants Darren K. Indyke and Richard D. Kahn

By: /s/ Sigrid McCawley
Sigrid McCawley

3

EFTA00031390