790.pdf

NOT A CERTIFIED COPY Filing# 8869027 Electronically Filed 01/07/2014 11 :03:54 AM #29187 4/mep JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, I IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800:XXXXMBAG ----------------- 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 1. 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 NOT A CERTIFIED COPY Edwards adv. Epstein Case No.: 502009CA040800:XXXXMBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 2 of 11 DEF. PLF. DATE MARK ADMIT NO. NO. OFFERED TED DESCRIPTION OF EXHIBITS Abernathy: A Workbook for Erotic Slaves and Their Owners" 6. Non-Prosecution Agreement 7. Jane Doe 102 Complaint 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 11. Jeffrey Epstein phone records 12. Sarah Kellen's 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. Complaint Jane Doe 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 22. Jeffrey Epstein's passport (or copy) 23. Jeffrey Epstein's driver's license (or copy) NOT A CERTIFIED COPY Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 3 of 11 DEF. PLF. DATE MARK ADMIT NO. NO. OFFERED TED DESCRIPTION OF EXHIBITS 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 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 ofJeffrey 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 NOT A CERTIFIED COPY Edwards adv. Epstein Case No.: 502009CA040800:XXXXMBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 4 of 11 DEF. PLF. DATE MARK ADMIT NO. NO. OFFERED 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. 502008CA028051XXXXMB AB and E.W. v. Jeffrey Epstein, Case No. 502008CP003626:XXXXMB 47. Jeffrey Epstein Deposition Testimony and discovery responses in State Court case Jeffrey Epstein v. Scott Rothstein, et al. Case No 502009CA040800XXXXMBAG 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 and Sarah Kellen 53. Audio tape of Haley Robson 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 NOT A CERTIFIED COPY Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 5 of 11 DEF. PLF. DATE MARK ADMIT NO. NO. OFFERED TED DESCRIPTION OF EXHIBITS 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 65. MC2 emails involving communications of Jeffrey Epstein, Jeff Fuller, Maritza Vasquez, Pappas Suat, Jean Luc Brunel and Amanda Grant 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 NOT A CERTIFIED COPY Edwards adv. Epstein Case No.: 502009CA040800:XXXXMBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 6 of 11 DEF. PLF. DATE MARK ADMIT NO. NO. OFFERED TED DESCRIPTION OF EXHIBITS Control and Probation 75. Jeffrey Eps