EFTA01113966.pdf

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, INAND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408003OOOCMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, JUDGE: DAVID CROW VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff, EPSTEIN'S OBJECTIONS TO EDWARDS'S REVISED EXHIBIT LIST Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Paragraph D4 of this Court's Order Setting Jury Trial and Directing Pretrial and Mediation Procedures, hereby objects to the following of Defendant/Counter-Plaintiff Bradley Edwards's trial exhibits (numbered in order as they appeared in Edwards's Revised Exhibit List): I. All applicable criminal statutes 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 Abernathy: A Workbook for Erotic Slaves and Their Owners" 6. Non-Prosecution Agreement 7. Jane Doe 102 Complaint EFTA01113966 8. Messages taken from message pads found at Epstein's home 9. Documents related to Jeffrey Epstein produced by Alfredo Rodriguez 10. Jeffrey Epstein flight logs I I. Jeffrey Epstein phone records 12. phone records 13. Jail Visitation Logs 14. Jeffrey Epstein's probation file 15. All probable cause affidavits related to criminal investigation of Jeffrey Epstein 16. All evidence, information and documents taken or possessed by FBI related to criminal investigation of Jeffrey Epstein 17. Victims' statements to the FBI related to criminal investigation of Jeffrey Epstein 18. Video of Search Warrant of Jeffrey Epstein's home being executed 19. Application for Search Warrant of Jeffrey Epstein's home 20. Complain v. Epstein and all subsequent Amended Complaints 21. All records of homes, properties, bank accounts and any and all records related to Jeffrey Epstein's assets 24. List of corporations owned by Jeffrey Epstein 25. All documents evidencing relationship between Jeffrey Epstein and Jean Luc Brunel 26. All documents evidencing relationship between Jeffrey Epstein and MC2 or any modeling agencies 27. Yearbooks of Jane Doe 28. 2002 Royal Palm Beach High School Year Book 29. 2001 Royal Palm Beach High School Year Book 30. 2003 Palm Beach Gardens High School Year Book EFTA01113967 31. Affidavit and Application for Search Warrant on Jeffrey 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 35. All documents related to Jeffrey Epstein's 6/30/08 conviction 36. Jeffrey Epstein's criminal plea colloquy 37. Public records from the Department of Corrections related to Jeffrey Epstein 38. Records from the Florida Department of Law Enforcement 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 Intelmgatories in 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 42. All discovery related responses of Jeffrey Epstein in 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 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. 502008CA028051XXXXMB AB and E.W. v. Jeffrey Epstein, Case No. 502008CP003626XXXXMB EFTA01113968 48. Any and all newspaper articles, online articles or publications related to Jeffrey Epstein 49. Report and Analysis of Jeffrey Epstein's assets 50. Video footage (DVD) of walk through site inspection of Jeffrey Epstein's home. 51. Photos of all of Jeffrey Epstein's properties, cars, boats and planes 52. Probable Cause Affidavits prepared against Jeffrey Epstein anc 53. Audio tape of 54. Photographs, videos and books taken in the search warrant of Jeffrey 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 57. Expert Dr. L. Dennison Reed's Report of Victim 58. Palm Beach Police Department Incident Report dated 4/20/06 59. All reports and documentation generated by Palm Beach Police Department related to Jeffrey Epstein 60. All Witness Statements generated by Palm Beach Police Department relating to Jeffrey Epstein 61. Passenger Manifests of Jeffrey Epstein's aircraft and private plane flight logs 62. Passenger lists for flights taken by Jeffrey Epstein 63. Letter from Jeffrey Epstein to Alberto Pinto regarding house island project 64. Jeffrey Epstein's bank statements Jeffrey Epstein's tax returns (this item not numbered on Edwards's Trial Exhibit Listt) ' • ' • ein, Jeff Puller EFTA01113969 66. DVD of plea and colloquy taken on 6-30-08 67. Transcript of plea and colloquy taken on 6-30-08 68. Massage Table 69. Lotions taken from Jeffrey Epstein's home during search warrant 70. Computers taken from Jeffrey Epstein's home during search 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 73. Criminal Score Sheet regarding Jeffrey Epstein 74. Documents evidencing Jeffrey Epstein's Community Control and Probation 75. Jeffrey Epstein's Sex Offender Registration 76. Jeffrey Epstein's Booking photograph 77. CAD calls to 358 El Brillo Way, Palm Beach FL 33480 78. List of Jeffrey Epstein's House contacts 79. Documents related to Jeffrey Epstein's investments 80. Letter from Chief Michael Reiter to Barry Krischler 81. List of planes owned by Jeffrey Epstein 82. Letter from Guy Fronstin to Assistant State Attorney dated 1-11-06 83. Letter from Guy Fronstin to Assistant State Attorney dated 1-13-06 84. Letter from Guy Fronstin to Assistant State Attorney dated 2-17-06 85. Letter from Guy Fronstin to Assistant State Attorney dated 4-6-06 86. Letter from Guy Fronstin to Assistant State Attorney dated 4-10-06 87. Letter from Goldberger dated 6-22-06 EFTA01113970 88. All subpoenas issued to State Grand Jury 89. Documents related to the rental of a vehicle fa 90. Ted's Sheds Documents 91. Documents related to property searches of Jeffrey Epstein's properties 92. Arrest Warrant 93. Police report regardin picking up money dated 11-28-04 94. List of Trilateral Commission Members of 2003 95. Alan Dershowitz Letter dated 4-19-06 and Statute 90.410 96. Guy Fronstin letter dated 4-17-06 97. Jeffrey Epstein Account Information 98. Jeffrey Epstein Criminal Closeout Sheet- 99. Jeffrey Epstein Polygraph Test and Results 100. Victim% GED testing information and results 101. JEGE, Inc. Passenger Manifest 102. Hyperion Air Passenger Manifest 103. Flight information fa 104. Passenger List Palm Beach flights 2005 105. Jeffrey Epstein notepad notes 106. Pleadings of _1 and 2 v. US case 107. Jeffrey Epstein 5th Amendment Speech 108. Reiter letter to Krisher dated 5-1-06 109. Jail receipts of Jeffrey Epstein 110. 'olice Report dated 11-28-04 EFTA01113971  11. Compulsory Medial Examination of victim, CMA 112. Victim's school records and transcripts 113. Victim Notification letter dated 7-9-08 114. Victim's employment records from IHOP 115. Police report of Juan Alessi theft at Jeffrey Epstein's home 116. Victim's Medical Records from Milton Girls Juvenile Facility 117. Victim's Medical Records from Dr. Randee Speciale 118. Victim's Medical Records from Wellington Regional Hospital 119. Victim's Medical Records from St. Mary's Medical Center 120. Victim's Medical Records from United Health 121. All surveillance conducted by law enforcement on Jeffrey Epstein's home 122. Emails received from Palm Beach Records related to Jeffrey Epstein 123. All items listed on the Palm Beach Police Property Report Lists 124. All items taken in the execution of the search warrant of Jeffrey Epstein's home: 358 El Brillo Way, Palm Beach FL 33480 125. All copies of convictions related to Jeffrey Epstein 126. Jeffrey Epstein criminal records 127. All documents produced by Palm Beach Police Department prior to the deposition of Detective Recarey 128. Photographs of all persons listed on Victims' Witness Lists 129. Statements, deposition transcripts, videotaped depositions and transcripts taken in connection with this and all related cases and exhibits thereto 130. Any and all expert witness reports and/or records generated in preparation for this litigation by any party to this cause 132. Curriculum vitae of Dr. Ryan Hall EFTA01113972 133. Any articles or publications of Dr. Ryan Hall 134. Any articles or publications of Dr. Richard Hall 135. Any articles or publications of Dr. L. Dennison Reed 136. All items and documentation review by Dr. L. Dennison Reed 137. Transcript and video (DVD) of IME of Victims 138. All exhibits to Dr. L. Demlison Reed's Deposition 139. All exhibits to Dr. Richard Hall's Deposition 140. All items and documents reviewed by Dr. Richard Hall 141. All items and documents reviewed by Dr. Ryan Hall 142. Demonstrative aids and exhibits including, but not limited to, anatomical charts, diagrams and models, surveys, photographs and similar material including blow-ups of the foresaid items.- need to see before we agree 143. Any and all mortality tables 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. 150. All attachments to Edwards's Motion for Summary Judgment. 151. All time records and hourly billing documentation produced in discovery. 152. All pleadings filed by Epstein in the Rothstein bankruptcy proceeding. 153. All Settlement Agreements between Epstein and victims of his sexual molestations. Epstein objects to all of the afore-referenced Exhibits on several grounds, including, but not limited to: Relevance; Prejudice; Confusion; Misleading; Hearsay; Impermissible/Inadmissible Character Evidence; Impermissible/Inadmissible Evidence of other Crimes, Wrongs, or Acts; and the fact that most of the items on this list were not EFTA01113973 provided to Epstein through discovery or otherwise in this case, in direct violation of this Court's Order Setting Jury Trial and Directing Pretrial and Mediation Procedures, and Epstein's "Exhibit A" to Bradley J. Edwards's Deposition Duces Tecum. By listing these grounds for objection to the afore-listed Exhibits, Epstein is not waiving his right to assert additional objections, or objections to any non-listed Exhibits at trial. WE HEREBY CERTIFY that a true and correct copy of the foregoing was served, via electronic service, to all parties on the attached service list, this September 19, 2013. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 954.337.3716 (facsimile) Attorneys for Epstein EFTA01113974  SERVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Scarola, Esq. jsx@searcylaw.com; mep@searcylaw.com Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldberger, Esq. jgoldberger@agwpa.com; smahoney@agwpa.com Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esq. I East Broward Blvd. Suite 700 Fort Lauderdale, FL 33301 Bradley J. Edwards, Esq. brad@pathtojustice.com Fanner Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Avenue Suite 2 Fort Lauderdale, Florida 33301 Fred Haddad, Esq. Dee@FredHaddadLaw.com 1 Financial Plaza Suite 2612 Fort Lauderdale, FL 33301 Tonja Haddad Coleman, Esquire Tonja@tonjahaddad.com; efiling@tonjahaddad.com Law Offices of Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Attorneys for Jeffrey Epstein EFTA01113975