Case 1:15-cv-07433-LAP Document 252 Filed 06/24/16 Page 1 of 3 Case 1:15-cv-07433-RWS Document 221 Filed 06/16/16 Page 1 of 3 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK Plaintiff, v. No. 15-cv-07433-RWS GHISLAINE MAXWELL, ECF CASE ORAL ARGUMENT REQUESTED Defendant. NOTICE OF MOTION TO QUASH (OR IN THE ALTERNATIVE MODIFY) SUBPOENA AND FOR A PROTECTIVE ORDER PLEASE TAKE NOTICE that upon the accompanying declaration of Gregory L. Poe dated June 16, 2016, the exhibits attached to the declaration, the accompanying memorandum of law, and all pleadings and proceedings herein, the undersigned will move this Court, before the Honorable Robert W. Sweet, United States District Judge for the Southern District of New York, for an order pursuant to Fed. R. Civ. P. 26 and Fed. R. Civ. P. Rule 45(d)(3) to quash (or in the alternative modify) a subpoena served by plaintiff on non-party Jeffrey Epstein, and for a protective order and such other and further relief as the Court may deem just and proper. PLEASE TAKE FURTHER NOTICE that, pursuant to S.D.N.Y. Local Civil Rule 6.1 and Rule 6(d) of the Federal Rules of Civil Procedure, opposing papers, if any, and reply papers, if any, must be served in accordance with the rules, with argument to be heard on July 7, 2016 (the first Thursday following the completion of briefing) or on a later date convenient for the Court. 711e 7yn e Dated: June 16. 2016 e ey 01-6-/ 6e-e-ne; cla 50 U sar g,z3. EFTA02799086