EFTA01116995.pdf

#291874/mep IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, / REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS COMES NOW the Counterplaintiff, BRADLEY J. EDWARDS, by and through his undersigned attorneys and hereby lists his exhibits for trial as follows: DER PLF. DATE MARK ADMIT NO. NO. OFFERED TED DESCRIPTION OF EXHIBITS EXHIBITS EXPECTED TO BE USED I. All applicable criminal statutes 2. All applicable Florida Statutes 3. All applicable Rules of Evidence 4. Video of Jeffrey Epstein's home and route from victim to Epstein's home 5. Order confirmation from Amazon.com for purchase of books "SM 101: A Realistic Introduction," "Slave Craft: Roadmap for Erotic Servitude-Principles, Skills and Tools" and "Training Miss EFTA01116995 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 2 of I I DEF. PLF. DATE MARK ADMIT NO. NO. OFFERED DESCRIPTION OF EXHIBITS TED Abernathy: A Workbook for Erotic Slaves and Their Owners" 6. Non-Prosecution Agreement 7. Jane Doe 102 Complaint Messages taken from message pads found at Epstein's home 8 Documents related to Jeffrey Epstein produced by Alfredo 9. Rodriguez Jeffrey Epstein flight logs 10. I I. Jeffrey Epstein phone records I•hone records 12. Jail Visitation Logs 13. Jeffrey Epstein's probation file 14. All probable cause affidavits related to criminal investigation 15. of Jeffrey Epstein All evidence, information and documents taken or possessed 16. by FBI related to criminal investigation of Jeffrey Epstein Victims' statements to the FBI related to criminal investigation 17 of Jeffrey Epstein Video of Search Warrant of Jeffrey Epstein's home being 18 executed Application for Search Warrant of Jeffrey Epstein's home 19. Complaint Jane Doe v. Epstein and all subsequent Amended 20. Complaints All records of homes, properties, bank accounts and any and 21 all records related to Jeffrey Epstein's assets Jeffrey Epstein's passport (or copy) 22. Jeffrey Epstein's driver's license (or copy) 23. EFTA01116996 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 3 of I I DEF. PLF. DATE NO. NO. OFFERED MARK ADMIT TED DESCRIPTION OF EXHIBITS 24 List of corporations owned by Jeffrey Epstein All documents evidencing relationship between Jeffrey Epstein 25. and Jean Luc Brunel 26. All documents evidencing relationship between Jeffrey Epstein and MC2 or any modeling agencies 27 Yearbooks of Jane Doe 28 200 igh School Year Book 29 2001 I igh School Year Book 2003 ugh School Year Book 30 Affidavit and Application for Search Warrant on Jeffrey 31. Epstein's home 32. Tape recording or transcript of recording of conversation between Jeffrey Epstein and George Rush 33. Notepads found in Jeffrey Epstein's home and/or during trash pulls outside of his home during criminal investigation 34 The Palm Beach State Attorney's Criminal file against Jeffrey Epstein All documents related to Jeffrey Epstein's 6/30/08 conviction 35. 36. Jeffrey Epstein's criminal plea colloquy Public records from the Department of Corrections related 37. to Jeffrey Epstein Records from the Florida Department of Law Enforcement 38. related to Jeffrey Epstein 39 All statements made by Jeffrey Epstein 40 List of properties and vehicles in Larry Visoski's name 41. All of Jeffrey Epstein's Responses to Requests for Production, Requests for Admission, Answers to Interrogatories in this matter, and cases 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 EFTA01116997 Edwards adv. Epstein Case No.: 502009CA040800XX.XXMBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 4 of I DEF. PLF. DATE NO. NO. OFFERED MARK ADMIT TED DESCRIPTION OF EXHIBITS 42. All discovery related responses of Jeffrey Epstein in this matter and cases 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802 09-81092 43. Jeffrey Epstein's Answers and Affirmative Defenses in all civil cases against him 44. All Complaints in which Jeffrey Epstein was a plaintiff or defendant 45. Jeffrey Epstein's Deposition testimony and discovery responses in this case and cases 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 46. Jeffrey Epstein's Deposition testimony and discovery responses in State Court cases LM v. Jeffrey Epstein, Case No. 502008CA02805OOOOCMB AB and E.W. v. Jeffrey Epstein, Case No. 502008CP003620000(MB 47. Jeffrey Epstein Deposition Testimony and discovery responses in State Court case Jeffrey Epstein v. Scott Rothstein, et al. Case No. 502009CA0408007OOOCMBAG 48. Any and all newspaper articles, online articles or publications related to Jeffrey Epstein 49. Report and Analysis of Jeffrey Epstein's assets -o Video footage (DVD) of walk through site inspection of Jeffrey Epstein's home. 5 I. Photos of all of Jeffrey Epstein's properties, cars, boats and planes 52 Probable Cause Affidavits prepared against Jeffrey Epstein and 53. Audio tape of 54. Photographs, videos and books taken in the search warrant ofJeffrey Epstein's home 55. Documents related to or evidencing Jeffrey Epstein's donations to law enforcement 56. Victim Notification Letter from US Attorney's Office to Victim EFTA01116998 Edwards adv. Epstein Case No.: 502009CA040800)OCXXMBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 5 of I I DEF. PLF. DATE MARK ADMIT NO. NO. OFFERED DESCRIPTION OF EXHIBITS TED Expert Dr port of Victim 57 Palm Beach Police Department Incident Report dated 4/20/06 58. All reports and documentation generated by Palm Beach Police 59. Department related to Jeffrey Epstein All Witness Statements generated by Palm Beach Police 60. Department relating to Jeffrey Epstein Passenger Manifests of Jeffrey Epstein's aircraft and private 61. plane flight logs Passenger lists for flights taken by Jeffrey Epstein 62 Letter from Jeffrey Epstein to Alberto Pinto regarding house 63. island project Jeffrey Epstein's bank statements 64. Jeffrey Epstein's tax returns MC2 emails involvin communications of Jeffrey Epstein, 65. Jeff Fuller appas Suat, Jean Luc Brunel and Aman a rant DVD of plea and colloquy taken on 6-30-08 66. Transcript of plea and colloquy taken on 6-30-08 67. Massage Table 68. Lotions taken from Jeffrey Epstein's home during search 69 warrant Computers taken from Jeffrey Epstein's home during search 70. warrant 71. Vibrators, dildos and other sex toys taken from Jeffrey Epstein's home during search warrant 72. No Contact Orders entered against Jeffrey Epstein Criminal Score Sheet regarding Jeffrey Epstein 73 74. Documents evidencing Jeffrey Epstein's Community EFTA01116999 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 6 of II DEF. PLF, DATE MARK ADMIT NO. NO. OFFERED DESCRIPTION OF EXHIBITS TED Control and Probation 75. Jeffrey Epstein's Sex Offender Registration Jeffrey Epstein's Booking photograph 76. CAD calls to 358 EL BRILLO WAY, PALM BEACH 77. FL 33480 List of Jeffrey Epstein's House contacts 78 Documents related to Jeffrey Epstein's investments 79. Letter from Chief Michael Reiter to Barry Krischler 80 List of planes owned by Jeffrey Epstein 81. Letter from Guy Fronstin to Assistant State 82 Attorney dated 1-11-06 Letter from Guy Fronstin to Assistant State 83 Attorney dated 1-13-06 Letter from Guy Fronstin to Assistant State 84 Attorney dated 2-17-06 Letter from Guy Fronstin to Assistant State 85 Attorney dated 4-6-06 Letter from Guy Fronstin to Assistant State 86 Attorney dated 4-10-06 Letter from Goldberger dated 6-22-06 87 All subpoenas issued to State Grand Jury 88. Documents related to the rental of a vehicle for 89. Ted's Sheds Documents 90. Documents related to property searches of Jeffrey Epstein's 91 properties Arrest Warrant o 92. Police report regarding picking up money 93 dated 11-28-04 EFTA01117000 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 7 of I I DEF. PLF. DATE MARK ADMIT NO. NO. OFFERED DESCRIPTION OF EXHIBITS TED List of Trilateral Commission Members of 2003 94. Alan Dershowitz Letter dated 4-19-06 and Statute 90.410 95. Guy Fronstin letter dated 4-17-06 96. Jeffrey Epstein Account Information 97. Jeffrey Epstein Criminal Closeout Sheet 98. Jeffrey Epstein Polygraph Test and Results 99. Victim's GED testing information and results 100. JEGE, Inc. Passenger Manifest 101. Hyperion Air Passenger Manifest 102. Flight information for 103. Passenger List Palm Beach flights 2005 104. Jeffrey Epstein notepad notes 105. Pleadings of Jane Doe I and 2 v. US case 106. Jeffrey Epstein 51h Amendment Speech 107. Reiter letter to Krisher dated 5-1-06 108. Jail receipts of Jeffrey Epstein 109. Police Report dated 11-28-04 110. Compulsory Medial Examination of victim, CMA III . Victim's school records and transcripts 112. Victim Notification letter dated 7-9-08 113. EFTA01117001 Edwards adv. Epstein Case No.: 502009CA040800XXMMBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 8 of II DEF. PLF. DATE MARK ADMIT NO. NO. OFFERED TED DESCRIPTION OF EXHIBITS Victim's employment records from 114 Police report of Juan Alessi theft at Jeffrey Epstein's home 115. 116. 117. 118. 119. 120. All surveillance conducted by law enforcement on Jeffrey 121 Epstein's home Emails received from Palm Beach Records related to Jeffrey 122 Epstein All items listed on the Palm Beach Police Property Report Lists 123 All items taken in the execution of the search warrant of 124 Jeffrey Epstein's home: 358 EL BRILLO WAY, PALM BEACH FL 33480 All copies of convictions related to Jeffrey Epstein 125 Jeffrey Epstein criminal records 126 All documents produced by Palm Beach Police Department 127 prior to the deposition of Detective Recarey Photographs of all persons listed on Victims' Witness Lists 128 Statements, deposition transcripts, videotaped depositions 129 and transcripts taken in connection with this and all related cases and exhibits thereto Any and all expert witness reports and/or records generated 130. in preparation for this litigation by any party to this cause Curriculum vitaes of any and all listed experts 131. Curriculum vitae of Dr. Ryan Hall 132. EFTA01117002 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 9 of I I DEF. PLF. DATE NO. NO. OFFERED MARK ADMIT TED DESCRIPTION OF EXHIBITS Any articles or publications of Dr. Ryan Hall 133. 134. Any articles or publications of Dr. Richard Hall Any articles or publications of Dr. L. Dennison Reed 135. 136. All items and documentation review by Dr. L. Dennison Reed Transcript and video (DVD) of IME of Victims 137 138 All exhibits to Dr. L. Dennison Reed's Deposition All exhibits to Dr. Richard Hall's Deposition 139 140. All items and documents reviewed by Dr. Richard Hall All items and documents reviewed by Dr. Ryan Hall 141. 142 All exhibits listed on the Epstein's Exhibit List Demonstrative aids and exhibits including, but not limited to, 143. anatomical charts, diagrams and models, surveys, photographs and similar material including blow-ups of the aforesaid items. 144. Any-and-all-mortality-tables 145. Edwards' reserves all objections to Epstein's Exhibits Edwards reserves the right to supplement and/or amend his 146. Exhibit List By listing an Exhibit, Edwards is not waiving his right to 147. object to same at trial and does not waive their right to amend same. All exhibits listed by Epstein subject to Edwards' objections. 148 149. All pleadings and attachments in the action under the Crime Victims Rights Act prosecuted by Bradley Edwards on behalf of victims of Epstein's criminal molestations. All attachments to Edwards' Motion for Summary Judgment. 150. EFTA01117003 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 10 of 11 DEF. PLF. DATE MARK ADMIT NO. NO. OFFERED DESCRIPTION OF EXHIBITS TED All time records and hourly billing documentation produced 151. in discovery. All deposition testimony and discovery responses by Epstein 152. submitted in this action. All pleadings filed by Epstein in the Rothstein 153. bankruptcy proceeding. All submissions by Epstein in connection with the Rothstein 154. deposition. All Settlement Agreements between Epstein and victims 155. of his sexual molestations. Plaintiff reserves the right to amend this list. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by E- Service to all counsel on the attached list, th Septembe , 2013. w com; mep@searcylaw.com Flor No.: 169440 Se •enney Scarola Barnhart & Shipley, P.A. 21: 'alm Beach Lakes Boulevard st Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9451 Attorneys for Bradley J. Edwards EFTA01117004 Edwards adv. Epstein Case No.: 502009CA04080WOOOMBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page II of II COUNSEL LIST Atter Goldber er & Weiss P A. Attorneys for Jeffrey Epstein ~fre Marc Nurik ttomeys or e ey pstein Law Offices of Marc S. Nurik Bradley J. Edwards, Esquire Fort Lauderdale, FL 33301 anner, e, etssorg, wards, Fistos & Attorneys for Scott Rothstein re ona - ai.a. e. . Fred Haddad, Es uire ort auderdale FL 33301 re a . . Attorneys for Jeffrey Epstein o au er e, EFTA01117005