The motion opens with a formal introduction and the request for alternative means of serving the subpoenas (pages 1-2). Virginia Giuffre's allegations center around being sexually abused by Jeffrey Epstein and Ghislaine Maxwell, with assistance from others such as Sarah Kellen and Nadia Marcinkova. The motion details the importance of deposing Epstein, who directed Maxwell to recruit Giuffre for sexual abuse. Despite Maxwell's suggestion to Giuffre to question Epstein directly, Epstein has avoided answering these queries under oath and has not authorized his lawyer to accept service of the subpoena (pages 2-3).

Efforts to serve Epstein with a deposition subpoena are documented, including multiple attempts by an investigative company and communications with Epstein's counsel. Similar evasion tactics are described for Kellen and Marcinkova, both identified as potential co-conspirators in Epstein’s sex trafficking organization. The motion provides evidence of their involvement, including flight logs and previous invocations of the 5th Amendment in related litigation (pages 3-6).

The argument section justifies the request for alternative service, citing Rule 45(b)(1) of the Federal Rules of Civil Procedure and various legal precedents that support alternative service methods when personal service is evasive. It details the diligent efforts made to serve the subpoenas personally, including attempts at different locations and through legal representatives. The motion proposes specific alternative service methods that have been employed, such as posting subpoenas at known locations, mailing them, and providing copies via email to known counsel (pages 7-9).

The conclusion reiterates the request for permission to serve deposition subpoenas alternatively due to the multiple failed attempts at personal service. The motion is respectfully submitted by Giuffre's legal team, with a list of her attorneys and their contact information (pages 9-11). A certificate of service confirms the electronic filing of the document and lists additional legal representatives involved (page 12).