EFTA01140114.pdf

#291874/mep IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800)OOO(MBAG 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: DEF. 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 EFTA01140114 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 Jeffrey Epstein phone records II. Sarah Kellen's phone 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. EFTA01140115 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 3 of I I DEF. PLF. DATE MARK ADMIT NO. NO. OFFERED DESCRIPTION OF EXHIBITS TED List of corporations owned by Jeffrey Epstein 24 All documents evidencing relationship between Jeffrey Epstein 25 and Jean Luc Brunel All documents evidencing relationship between Jeffrey Epstein 26 and MC2 or any modeling agencies 27. Yearbooks of Jane Doe 2002 Royal Palm Beach High School Year Book 28. 2001 Royal Palm Beach High School Year Book 29 2003 Palm Beach Gardens High School Year Book 30. Affidavit and Application for Search Warrant on Jeffrey 31. Epstein's home Tape recording or transcript of recording of conversation 32 between Jeffrey Epstein and George Rush Notepads found in Jeffrey Epstein's home and/or during trash 33 pulls outside of his home during criminal investigation The Palm Beach State Attorney's Criminal file against Jeffrey 34. Epstein All documents related to Jeffrey Epstein's 6/30/08 conviction 35. Jeffrey Epstein's criminal plea colloquy 36. 37. Public records from the Department of Corrections related to Jeffrey Epstein Records from the Florida Department of Law Enforcement 38. related to Jeffrey Epstein All statements made by Jeffrey Epstein 39. List of properties and vehicles in Larry Visoski's name 40 All of Jeffrey Epstein's Responses to Requests for Production, 41. 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 EFTA01140116 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 4 of I I DEF. PLF. DATE MARK ADMIT NO. NO. OFFERED DESCRIPTION OF EXHIBITS TED All discovery related responses of Jeffrey Epstein in this matter 42. 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 Jeffrey Epstein's Answers and Affirmative Defenses in 43. all civil cases against him All Complaints in which Jeffrey Epstein was a plaintiff 44. or defendant Jeffrey Epstein's Deposition testimony and discovery responses 45. 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 Jeffrey Epstein's Deposition testimony and discovery responses 46 in State Court cases LM v. Jeffrey Epstein, Case No. 502008CA028051XXXXMB AB and E.W. v. Jeffrey Epstein, Case No. 502008CP003626XXXXMB Jeffrey Epstein Deposition Testimony and discovery responses 47 in State Court case Jeffrey Epstein v. Scott Rothstein, et al. Case No 502009C A040800XXXXMBAG Any and all newspaper articles, online articles or publications 48 related to Jeffrey Epstein Report and Analysis of Jeffrey Epstein's assets 49 Video footage (DVD) of walk through site inspection of Jeffrey 50. Epstein's home. Photos of all of Jeffrey Epstein's properties, cars, boats and planes 51 Prob Affidavits prepared against Jeffrey Epstein 52. and Audio tape of Haley Robson 53. Photographs, videos and books taken in the search warrant 54. of Jeffrey Epstein's home Documents related to or evidencing Jeffrey Epstein's donations 55. to law enforcement Victim Notification Letter from US Attorney's Office to 56. Victim EFTA01140117 Edwards adv. Epstein Case No.: 502009CAC140800XXXXMBAG 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. L. Dennison Reed's Report 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 mails involving communications of Jeffrey Epstein, 65. Jeff Fuller, Maritza Vasquez, Pappas Suat, Jean Luc Brunel and Amanda Grant 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 EFTA01140118 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 TED DESCRIPTION OF EXHIBITS 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 Vanessa Zalis 89 Ted's Sheds Documents 90. Documents related to property searches of Jeffrey Epstein's 91 properties Arrest Warrant of Sarah Kellen 92 Police report regarding Alexandra Hall picking up money 93. dated 11-28-04 EFTA01140119 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 Dana Burns 103. Passenger List Palm Beach flights 2005 104. Jeffrey Epstein notepad notes 105. Pleadings of lane Doe 1 and 2 v. US case 106. Jeffrey Epstein 5h Amendment Speech 107. Reiter letter to Krisher dated 5-1-06 108. Jail receipts of Jeffrey Epstein 109. Alexandra Hall 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. EFTA01140120 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 8 of 11 DEF. PLF. DATE MARK ADMIT NO. NO. OFFERED DESCRIPTION OF EXHIBITS TED Victim's employment records from MOP 114 Police report of Juan Alessi theft at Jeffrey Epstein's home 115. Victim's Medical Records from Milton Girls Juvenile Facility 116 Victim's Medical Records from Dr. Randee Speciale 117 Victim's Medical Records from Wellington Regional Hospital 118 Victim's Medical Records from St. Mary's Medical Center 119 Victim's Medical Records from United Health 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. EFTA01140121 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 9 of I I DEF. PLF. DATE MARK ADMIT NO. NO. OFFERED DESCRIPTION OF EXHIBITS TED Any articles or publications of Dr. Ryan Hall 133. Any articles or publications of Dr. Richard Hall 134. Any articles or publications of Dr. L. Dennison Reed 135. All items and documentation review by Dr. L. Dennison Reed 136. Transcript and video (DVD) of IME of Victims 137 All exhibits to Dr. L. Dennison Reed's Deposition 138 All exhibits to Dr. Richard Hall's Deposition 139. All items and documents reviewed by Dr. Richard Hall 140. All items and documents reviewed by Dr. Ryan Hall 141 All exhibits listed on the Epstein's Exhibit List 142 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. mo rtality-tables Edwards' reserves all objections to Epstein's Exhibits 145 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 All pleadings and attachments in the action under the Crime 149. 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. EFTA01140122 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page I 0 of I I DEF. PLF. DATE MARK ADMIT NO. NO. OFFERED TED DESCRIPTION OF EXHIBITS 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 molestation. 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, i 2014. Jack S ola/ law.com; mep@searcylaw.com Fl rid tar No.: 169440 ear• Denney Scarola Barnhart & Shipley, P.A. 9 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9451 Attorneys for Bradley J. Edwards EFTA01140123 Edwards adv. Epstein Case No.: 502009CA040800)ODOCIVIBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 11 of I I COUNSEL LIST Jack A. Goldberger, Esquire jgoldberger®agwpa.com; smahoney®agwpa.com Phone: (954)-467-6767 Atterbury, Goldberger & Weiss, P.A. Fax: (954)-467-3599 250 Australian Avenue South, Suite 1400 Attorneys for Jeffrey Epstein West Palm Beach, FL 33401 Phone: (561)-659-8300 Marc S. Nurik, Esquire Fax: (561)-835-8691 marc@nuriklaw.com Attorneys for Jeffrey Epstein Law Offices of Marc S. Nurik One E Broward Blvd., Suite 700 Bradley J. Edwards, Esquire Fort Lauderdale, FL. 33301 staff.efile®pathtojustice.com Phone: (954)-745-5849 Farmer, Jaffe, Weissing, Edwards, Fistos & Fax: (954)-745-3556 Lehrman, FL Attorneys for Scott Rothstein 425 North Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Tonja Haddad Coleman, Esquire Phone: (954) 524-2820 tonja®tonjahaddad.com; Fax: (954) 524-2822 Debbie®Tonjahaddad.com Tonja Haddad, P.A. Fred Haddad, Esquire 315 SE 7th Street, Suite 301 Dee@FredHaddadLaw.com; Fort Lauderdale, FL 33301 haddadfm®aol.com Phone: (954)467-1223 Fred Haddad, P.A. Fax: (954)-337-3716 One Financial Plaza, Suite 2612 Attorneys for Jeffrey Epstein Fort Lauderdale, FL 33394 EFTA01140124