EFTA00801460.pdf

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA00800XXXXMBA JEFFREY EPSTEIN. Plaintiff/Counter-Defendant. JUDGE: HAFELE vs. SCOTT ROTHSTEIN, individually. BRADLEY J. EDWARDS. individually. Defendants/Counter-Plaintiff. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO STRIKE PORTIONS OF DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S WITNESS LIST OR COMPEL PROPER RESPONSES IN ACCORDANCE WITH THIS COURT'S ORDER Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Paragraph IV of this Court's Order Setting Jury Trial and Directing Pretrial and Mediation Procedures and the Florida Rules of Civil Procedure, moves this Court to strike the portions of Defendant/Counter-Plaintiff Bradley Edwards ("Edwards") - witnesses- listed below and prevent use of any of the witnesses at trial for his failure to comply with this Court's Order. Alternatively. Epstein requests that this Court compel Edwards to comply with this Court's Order and modify all subsequent deadline dates so as to not prejudice Epstein in preparation for trial or seeking additional discovery. In support thereof, Epstein states: Tonja Haddad. P.A. • 315 SE 7th Street. Fort Lauderdale. FL 33301• EFTA00801460  INTRODUCTION Edwards noticed this matter for trial on December 3. 2015. On February 8, 2016, this Court entered an Order setting trial in this matter for the trial period of August 29. 2016 through November 4. 2016. After receiving same. Epstein moved to stay this matter or alternatively continue the trial date until such time as the Florida Supreme Court ruled on the Litigation Privilege issue. This Court denied Epstein's first Motion, without prejudice. As the trial date approached, Epstein filed a renewed Motion to stay or continue the trial date, and after hearing on Epstein's Motion, this Court entered an Order resetting this case for the October 24, 2016 trial period, and further ordered that the initial trial order dates be adjusted in accordance therewith. A true and correct copy of the initial Court Order Setting Jury Trial and Directing Pretrial and Mediation Procedures (hereinafter "Order"), and the Order resetting the trial period. are attached hereto as composite "Exhibit Pursuant In the Order's amended dates, the parties were to "exchange lists of all trial exhibits. names and addresses of all trial witnesses, and names and addresses of all expert witnesses." See Exhibit A. I II.A (emphasis added). While Epstein provided a proper witness list, containing the names and addresses of all witnesses. Edwards provided a list that failed to provide a proper name or address for several witnesses, including any expert witness, which is delineated in detail below. This is the third time that Edwards has filed this witness list with the same deficiencies, and the third time that Epstein has sought intervention from the Court. Edwards consistently espouses readiness for trial. notwithstanding his repeated and blatant failure to comply with the Order. As demonstrated more fully herein. Edwards's actions prejudice the administration of justice, Tonja Haddad. P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301• EFTA00801461  thwart Epstein's ability to timely receive discovery and adequately prepare for trial, and blatantly violate the Court's Order. ITEMS TO BE STRICKEN OR AMENDED TO INCLUDE PROPER RESPONSES Edwards's witness list contains twenty-eight (28) numbered paragraphs. A true and correct copy of same is attached hereto as "Exhibit B." Paragraphs one (1) through seven (7) contain proper names and addresses. Conversely, paragraphs eight (8) through seventeen (17) and paragraphs nineteen (19) and twenty (20) contain proper names only and no addresses, and the remaining paragraphs with which Epstein takes issue provide merely the following: 18. Any and all FBI agents who assisted in the investigation of Jeffrey Epstein. 21. All victims identified in the local, state and federal investigations. 22. All attorneys who have prosecuted claims against Jeffrey Epstein on behalf of other victims. 23. All other named victims. 24. All persons referenced in Edwards' Motion for Summary Judgment. 27. Any and all witnesses whose names appear in depositions. interrogatories. or requests for production provided by Bradley J. Edwards. See Exhibit B. Likewise, Edwards Expert Witness list provides as follows: "Experts include all listed attorneys involved in the prosecution of civil claims against Jeffrey Epstein arising out of Epstein's serial abuse of minor females." There are no attorneys listed. A true and correct copy of Edwards' Amended Expert Witness List is attached hereto as "Exhibit C." While it is likely that these witnesses, based upon the "description" given of them, have no relevant or admissible information to provide regarding the elements that Edwards 3 Ttmja Haddad. P.A. • 315 SE 7th Street. Fort Lauderdale. FL 33301• EFTA00801462 must prove in his claim for Malicious Prosecution against Epstein, Epstein cannot properly determine or evaluate that issue without knowing, at least, the purported witnesses names and. if warranted, engaging in discovery regarding each person thereafter. MEMORANDUM OF LAW This Court's Order clearly and unequivocally delineates the Pretrial rules with which the parties must comply and the required parameters for such compliance. See Exhibit A. Paragraph IV governs Noncompliance, and provides: "NONCOMPLIANCE WITH ANY PORTION OF THIS ORDER MAY RESULT IN THE STRIKING OF THE CASE, WITNESSES, OR EXHIBTS, OR IOMPOSITION OF SUCH OTHER SANCTIONS AS ARE JUST." (Emphasis in original). See Exhibit A. In the case at hand. Edwards's witness list clearly violates this Court's Order, just as it did the last two (2) times he filed it. This Court's Order requires that Edwards provide "names and addresses of all trial witnesses." See Exhibit A. Edwards's serial disregard of this Order by failing to provide proper names and addresses in each of three witness lists he filed in this matter, despite repeated requests by Epstein to correct that failure, mandate the implementation of the remedies set forth in Paragraph IV of the Order and the Florida Rules of Civil Procedure governing discovery violations. The law is clear that "leixcept in cases of a clear abuse of discretion prejudicial to the affected party, trial courts must be allowed to enforce pretrial orders to achieve the orderly and efficient administration of justice, fair to all parties." Fla. Marine Enterprises v. Bailey, 632 So. 2d 649, 651-52 (Fla. 4th DCA 1994). Courts have held that "decisions regarding the testimony of improperly disclosed witnesses" are squarely "within the broad discretion of the trial judge. who is vested with the interpretation and enforcement of any 4 Tonja Haddad. P.A. • 315 SE 7th Street. Fon Lauderdale, FL 33301• EFTA00801463 pretrial order mandating witness disclosure." Id. at 651. "Florida courts have explained that the rules of discovery are intended to avoid surprise and trial by ambush." Agrofollajes. S.A. v. E.I. Du Pont De Nemours & Co., Inc.. Nos. 3D07-2322, 3D07-2318, 3D07-1036, 2009 WL 4828975. at (Fla. 3d DCA Dec. 16, 2009); Escudo v. Greenleaf Products, Inc., 886 So. 2d 1059. 1062 (Fla. 1st DCA 2004). Here, it is undeniable that Edwards's failure to provide proper names of individual witness for the last four (4) years prejudices Epstein, and thwarts the efficiency of the judicial process. 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 June 28, 2017. /s/ Tonia Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad. PA 315 SE 7th Street Suite 301 le. Florida 33301 Attorneys for Epstein 5 Tutu., Haddad. P.A. • 315 SE 7th Street. Fort Lauderdale, FL 33301• EFTA00801464  SERVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Scarola, Esq. Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 ack Goldberger, Esq. l Atterbury. Goldberger. & Weiss. PA 250 Australian Ave. South Suite 1400 West Palm Beach. FL 33401 Marc Nurik, Esq. 1 East Broward Blvd. Suite 700 Fort Lauderdale, FL 33301 Bradley J. Edwards. Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Avenue Suite 2 Fort Lauderdale. Florida 33301 Fred Haddad. Esq. 315 SE 7th Street. Suite 301 Fort Lauderdale, FL 33301 Tonja Haddad Coleman, Esquire Law Offices of Tonja Haddad. P.A. 315 SE 7th Street. Suite 301 Fort Lauderdale, FL 33301 W. Chester Brewer, Jr. One Clearlake Center Suite 1400 250 Australian Avenue South West Palm Beach. Florida 33401 6 Tonja Haddad. P.A. • 315 SE 7th Street. Fort Lauderdale. FL 33301• EFTA00801465  IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLO RIDA CIRCUIT CIVIL DIVISION AG CASE NO. 50-2009-CA-040800-XXXX-MB JEFFREY EPSTEIN, Plaintiff(s) V. SCOTT ROTIISTEIN. individually, BRADLEY J. EDWARDS, individually, and L M, individually, Defendant(s). ORDER SETTING JURY TRIAL DIRECTING PRETRIAL AND MEDIATIO AND N PROCEDURES I. SCHEDULING This action is set for jury trial for the trial period of AUGUST 29, 201 NOVEMBER 4, 2016. YOU MUST 6 through APPEAR ON AUGUST 19, 2016 AT 9:00 COURTROOM 9C, PALM BEACH A.M. IN HIGHWAY, WEST PALM BEACH, COU NTY CO UR THO USE , 205 NO RTH DIXIE FLORIDA FOR THE CALENDAR CALL. (10 days have been reserved for the trial of this cause). The trial will be scheduled sometime during the calendar, at a date and time to be provided calendar call, subject to the court's ordering at the a later case setting. II. UNIFORM PRETRIAL PROCED URE A. On the last business day no later than 60 DAYS PRIOR TO CALENDAR CALL, panics shall exchange lists of all trial exh the ibits, names and addresses of all trial witnesses. and names and addresses of all expert witnesse s. B. On the last business day no later than 50 DAY panics shall exchange lists of names and addr S PRIOR TO CALENDAR CALL. the esses of all rebuttal witnesses. Page I of 5 EXHIBIT A EFTA00801466 Order Setting Jury Trial and Directing Pretrial And Mediation Case No: 50-2009-CA-0408 Procedures 00-XXXX-MB C. In addition to names and addresses of each expert retaine with regard to this cause, d to formulate an expert opinion both on the initial listing provide: and on rebuttal, the parties sha ll I. the subject matter about which the expert is expected 2. the substance of the fac to testify; ts and opinions to which the exp 3. a summary of the ground ert is expected to testify; s for each opinion; 4. a copy of any written reports issued by the expert regarding 5. a copy of the expert's cur this case; and riculum vitae. D. On the last business day no later than 30 DAYS PRIOR parties shall confer and: TO CALENDAR CALL, the I. discuss settlement; 2. simplify the issues and stipulate, in writing, as to as ma possible; ny facts and issues as 3. prepare a Pre-Trial Sti pulation in accordance with paragr 4. list all objections to tria aph E; and l exhibits. E. PRETRIAL STIPULA TIONS MUST BE FILED. It sha Plaintiff to see that the Pre-Tr ll be the duty of counsel for the ial Stipulation is drawn, execut and filed with the Clerk no late ed by counsel for all parties, r than 20 DAYS PRIOR TO UNILATERAL. PRETRIAL CALENDAR CALL. STATEMENTS ARE DISALLO APPROVED BY THE COUR WED, UNLESS T, AFTER NOTICE AND HE CAUSE. Counsel for all parties AR ING SHOWING GOOD are charged with good faith coo The Pre-Trial Stipulation sha peration in this regard. ll contain in separately numbered par 1. a list of all pending mo agraphs: tions including MOTIONS IN MOTIONS requiring action by LIM INE and DAUBERT the Court and the dates those mo hearing (MOTIONS IN LIMINE tions are set for shall not be heard the day of All Daubed Motions must be trial or thereafter). 2. stipulated facts which req heard 20 days before the start of the trial. uire no proof at trial which may fact; be read to the trier of 3. a statement of all issues of fact for determination at trial; 4. each party's number ed list of trial exhibits with spe schedules attached to the Stipulatio cific objections, if any, to 5. each party's numbered list of n; trial witnesses with addresses (in rebuttal witnesses); the list of cluding all known witnesses shall be on separate schedu the Stipulation; les attached to 6. a statement of estimated trial time; 7. names of attorneys to try cas 8. number of peremptory cha e: llenges per party; and 9. each party's proposed jury instructions and verdic supporting authority, as schedules t form, with citations to attached to the Stipulation. Page 2 of 5 EFTA00801467  Order Setting Jury Trial and Directing Pretrial An Case No: 50-2009-CA- d Mediation Procedures 040800-XXXX-MB F. FILING OF PR ETRIAL STIPULATION. Court Approved Unila Failure to file the Pre-Tria teral Stipulation as abov l Stipulation or a stricken from the Court e provided may result 's calendar at its soundin in the case being g or other sanctions. G. ADDITIONAL EXHIBITS. WITNESSE be strictly limited to S OR OBJECTIONS. At exhibits and witnesses dis trial, the parties shall schedules attached to closed and objections reserv the Pr ed on and E. absent agreement e-Trial Stipulation prepared in accordance with paragrap the specifically stated in the hs D Court upon good cause Pre-Trial Stipulation or ord shown. Failure to reserv er of the party desiring to use e objections constitutes a an exhibit or witness dis waiver. A pursuant to paragraph D co vered after counsel have shall immediately fur conferred description of the exhib nish the Court and other co it or with the witness' name un se l with a matter of the witness' and address and the expe testimony, together with cted subject exhibit or witness. Use the reason for the late disco of the exhibit or witne very of the cause shown or to prevent ss may be allowed by the Court manifest injustice. for good H. DISCOVERY. Unles s otherwise agreed in the Pre- be completed no later tha Trial Stipulation, all discover• n 10 DAYS BEFORE must CALL, absent agreeme THE DATE SET FOR CALE nt for later discovery sp ND AR Stipulation or for oth ecifically stated in the Pr er good cause shown. ABSE e-Trial FAILURE TO CO NT A TRUE EMERGE MPLETE DISCOVERY NCY, GROUNDS FOR CONT SHALL NOT CONSTI INUANCE. TUTE 1. PRE-TRIAL CONFER ENCE. No pre-trial conference is set by the Court on its pursuant to Fla. R. Civ. P. 1.2 own motion. If a pre-trial 00 party, counsel shall meet an conference is set upon motion of d prepare a stipulation pursu a file the stipulation no later tha ant to paragraphs D and E an d request a prc-trial conferen n 5 DAYS BEFORE THE CONFERENCE. Failure ce in a timely fashion constitu to requirement of Rule 1.200. tes a waiver of the notice of Motions for Summary Judg trial conference. ment will not be heard at any pre- J. UNIQUE QUESTIONS OF LAW. Prior to calen directed to exchange and sim dar call, counsel for the partie ultaneously submit to the s arc with citations to legal au Court appropriate memoran thority in support of any da reasonably be anticipated unique legal questions which to arise during the trial. ma y K. MODIFICATION TO UN IFORM PRE-TRIAL PROC of the parties filed with EDURE. Upon written stipulat the court, the Pm-Trial Proc ion inclusive, may be modified edure, except for items ft D-F, in accordance with the partie extent that the stipulation ma s' stipulation. except to the y interfere with the Court's sc or hinder the orderly progre he duling of the matter for trial ss of the trial. Page 3 of 5 EFTA00801468 Order Setting Jury Trial and Directing Pretri al And Mediation Procedures Case No: 50-2009-CA-040800-XXXX-M B L. PREMARKING EXHIBITS. Prior to trial, each party shall meet with and assist the clerk in marking for identification all exhib its, as directed by the clerk. M. DEPOSITION DESIGNATIONS. No later than 20 DAYS PRIOR TO CALENDAR CALL, each party shall serve his, her, or its designation of depositions, or portions of depositions, each intends to offer as testimony in his, her or its case in chief. No later than 10 DAYS PRIOR TO CALENDAR CALL each opposing party shall serve his, her, or its counter (or "fairness") designations to portions of depositions designated, together with objections to the depositions. or portions thereof, originally designated. No later than calendar call, each party shall serve his, her or its objections to counter designations served by an opposing party. III. MEDIATION A. All parties are required to participate in mediation. I. The appearance of counsel who will try the case and repres entatives of each party with full authority to enter into a complete compromise and settlement is mandatory. If insurance is involved, an adjuster with authority up to the policy limits or the most recent demand, whichever is lower, shall attend. 2. At least ONE WEEK BEFORE THE CONFERENCE, all panic s shall file with the mediator a brief, written summary of the case containing a list of issues as to each party. If an attorney or party filing the summary wishes its content to remain confidential, he/she must advise the mediator in writing when the report is filed. 3. All discussions, representations, and statements made at the media tion conference shall be privileged consistent with Florida Statutes sectio ns 44.102 and 90.408. 4. The mediator has no power to compel or enforce a settlem ent agreement. If a settlement is reached, it shall be the responsibility of the attorneys or reduce the agreement to writing and to comply with Florida Rule partie s to of Civil Procedure 1.730(b), unless waived. B. The Plaintiffs attorney shall be responsible for scheduling mediation. The parties should agree on a mediator. If they are unable to agree, any party may apply to the Court for appointment of a mediator in conformity with Rule 1.720 (0, Fla. IL Civ. P. The lead attorney or party shall file and serve on all parties and the media tor a Notice of Mediation giving the time, place, and date of the mediation and the mediator's name. The mediator shall be paid $175.00 per hour, unless otherwise agreed by the parties. C. Completion of mediation prior to calendar call is a prerequisite to trial. If mediation is not conducted, or if a party fails to participate in media tion, the case. at the Court's discretion, may be stricken from the trial calendar, pleadings may be stricken, and other sanctions may be imposed. Page 4 of 5 EFTA00801469  Order Setting Jury Trial and Directing Pretrial And Mediation Procedures Case No: 50-2009-CA-040800-XXXX-MB D. Any party opposing mediation may proceed under Florida Rule of Civil Procedure 1,700(b). IV. NONCOMPLIANCE NONCOMPLIANCE WITH ANY PORTION OF THIS ORDER MAY RESULT IN THE STRIKING OF THE CASE, WITNESSES, OR EXHIBITS, OR IMPOSITION OF SUCH OTHER SANCTIONS AS ARE JUST. DONE AND ORDERED in West Palm Beach, Palm Beach County, Florida this 8th day of February, 2016. IX)NAL LE Circuit J Copies furnished to: WILLIAM CHESTER BREWER JR, 250 AUSTRALI AN AVE S, STE 1400, WEST PALM BEACH, FL 33401 JACK SCAROLA, 2139 PAI.M BEACII LAKES BIND, WEST PALM BEACH, FL 33409 JACK A. GOLDBERGER, 250 AUSTRALIAN AVE S. STE 1400, WEST PALM BEACH, FL 33401 BRADLEY J. EDWARDS, 425 N ANDREWS AVE, STE 2, FT. LAUDERDA LE, FL 33301 FRED HADDAD, ONE. FINANCIAL. PLAZA, STE 2612, FT. LAUDERDA LE, FL 33394 TONJA HADDAD COLEMAN, 5315 SE 7T" ST.. STE. 301. FT. LAUDERDA LE, FL 33301 MARC S. NURIK, ONE E. BROWARD BLVD.. STE. 700, FT. LAUDERDA LE, FL 33301 Page 5 of 5 EFTA00801470 Filing # 45239135 E-Filed 08/15/2016 04:18:21 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800)0CaMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, SECOND AMENDED AND SUPPLEMENTAL WITNESS LIST OF COUNTERPLAINTIFF BRADLEY J. EDWARDS Pursuant to this Court's Order Setting Trial and Directing Pretrial and Mediation Procedures dated February 8, 2016, Counter-plaintiff, BRADLEY J. EDWARDS, by and through his undersigned attorneys, hereby files his Second Amended and Supplemental Witness List for trial as follows: 1. Bradley J. Edwards 2. Jeffrey Epstein 3. Avarell Cordero 4. AI fl rohntt.;•, EXHIBIT B EFTA00801471 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Second Amended and Supplemental Witness List of CountetplaintiffBradle Page 2 of 3 y I. Edwards 5. Donni 6. Robert Josefsberg, Esquire Podurst Orseck, P.A. 7. Howard Rubinstein 8. Steven Hoffenberg 9. 10. Juan Alessi 11. Maria Alessi 12. Dave Rogers (pilot) 13. OEM 14. 15. 16. 17. Marie Villafana (US Attys Office) 18. Any and all FBI agents who assisted in the investigation of Jeffrey Epstei n 19. Detective Recarey 20. Palm Beach Police Chief Reiter 21. All victims identified in the local, state and federal investigations EFTA00801472 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Second Amended and Supplemental Witness List of Counterplaintiff Bradley J. Edwards Page 3 of 5 22. All attorneys who have prosecuted claims against Jeffrey Epstein on behalf of other victims 23. All other named victims. 24. All persons referenced in Edwards' Motion for Summary Judgment. 25. All witnesses listed by the Counterdefendant and Co-Defendant. 26. All experts named by the Counterdefendant and Co-Defendant. 27. Any and all witnesses whose names appear in depositions, interrogatories, or requests for production provided by Bradley J. Edwards. 28. Impeachment and rebuttal witnesses as necessary, without waiving any objections thereto. EXPERTS Experts include all listed witnesses involved in the prosecution of civil claims against Jeffrey Epstein arising out of Epstein's serial abuse of minor females. Counter-plaintiff reserves the right to amend this list prior to trial upon proper notice to the Counter-defendant. EFTA00801473  Edwards adv. Epstein Case No.: 502009CA040800VCXXMBAG Second Amended and Supplemental Witness List of Counterplaintiff Bradle Page 4 of 5 y J. Edwards I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all Counsel on the attached list, this b day of X115'1 2016. JACK SCA9tOLA Florida Bat No.: 169440 Anorne/E-Mail(s): and E-Mail: arty Denney Scuo .lilli la Ban llt!../ . 1pey i, l l 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Fax • Fax: Attorney or ra • ey . Edwards EFTA00801474 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Second Amended and Supplemental Witness List of Counterplaintiff Bradley J. Edwards Page 5 of 5 COUNSEL LIST William Chester i3rewer. Esouire Marc S Nurik Fc.a ire 250 S Australian Avenue, Suite 1400 One E Broward Blvd., Suite 700 West Palm Beach, Ft 33401 Fort 33301 Phone: Pho Fax: Fax: Attorneys for Jeffrey Epstein Attorneys for Scott Rothstein re Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue S, Suite 1400 West Palm h F 33401 Phone Fax: Attorneys for Jeffrey Epstein Bradley J. Edwards, Esquire Fanner Jaffe Weissing Edwards Fistos & Lehrman, P.L. 425 N Andrews Avenue, Suite 2 Fort Lauder 301 Phone: Fax: Tonja Haddad C lem Esquire Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale FL 33301 Phone: Fax: Attorneys for Jeffrey Epstein EFTA00801475  IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA04080(DOCCXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant. AMENDED EXPERT WITNESS LIST OF BRADLEY J. EDWARDS Bradley J. Edwards, by and through his undersigned attorneys, hereby amends his expert witness list for trial as follows: Experts include all listed attorneys involved in the prosecution of civil claims against Jeffrey Epstein arising out of Epstein's serial abuse of minor females. They will testify based upon their background, training, and experience as civil litigators, and the personal involvement that each had in prosecuting claims against Jeffrey Epstein, about the legal and ethical propriety of the actions taken by Bradley Edwards in fulfilling his obligations to the victims of Epstein's criminal assaults. All expert witnesses timely listed by Jeffrey Epstein, subject to Edwards' objections. Impeachment and rebuttal witnesses as necessary, without waiving any objections thereto. EXHIBIT C EFTA00801476 Edwards adv. Epstein Amended Expert Witness List Case No.: 502009CA040800XXXXMBAG Bradley J. Edwards reserves the right to amend this list prior to trial upon proper notice to counsel for Jeffrey Epstein. I HEREBY CERTIFY that a true and correct copy o the forego ing was sent via E-Serve to all Counsel on the attached list, this 11 11 1—da 2013. Jack No.: 169440 P E-mail: ndary E-mail(s earcy Denney Scarola Barnhart 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: Fax: Attorneys or . Edwards 2 EFTA00801477 Edwards adv. Epstein Amended Expert Witness List Case No.: 502009CA040800XXXXMBAG COUNSEL LIST Jack A. Goldberger Esquire Fort Lauderdale, FL 33394 Phone: Fax: Atterbury, Goldberger & Weiss, P.A. Attorneys for Jeffrey Epstein 250 Australian Avenue South, Suite 1400 West Palm Beach. FL 33401 Marc S. Nurik, Esquire Phone: Fax: Law Offices of Marc S. Nurik Attorneys for Jeffrey Epstein One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Bradley J. Edwards, Esquire Phone: Fax: Farmer, Jaffe, Weissing, Edwards, Fistos & Attorneys for Scott Rothstein Lehrman, FL 425 North Andrews Avenue, Suite 2 Tonja Haddad Coleman, Esquire Fort Lauderdale, FL 33301 ton jaRtonjahaddad .com ; Phone: Fax: Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fred Haddad, Es uire Fort Lauderdale, FL 33301 Phort• Fax: Fred Haddad, P.A. Attorneys for Jeffrey Epstein One Financial Plaza, Suite 2612 EFTA00801478