AO 187 (Rev. 7/87) Witness List
AO 187 (Rev. 7/87) Witness List
United States District Court SOUTHERN DISTRICT OF FLORIDA
JANE DOE,
Plaintiff
Vs.
JEFFREY EPSTEIN, ct al.
Defendant.
Related Cases: CASE NUMBER: 08-CV-80893-CIV
MARRA/JOHNSON
PLAINTIFF JANE DOE'S EXHIBIT LIST
08-80119, 08-80232, 08-80380, 08-80381,
08-80994, 08-80811, 08-80893, 09-80469,
09-80591, 09-80656, 09-80802, 09-81092
PRESIDING JUDGE
Hon. Judge Marra PLAINTIFFS ATTORNEY
Bradley J. Edwards, Esq. DEFENDANTS' ATTORNEY
Robert Craton, Esq.
TRIAL DATE(S) July 19 — July 30, 2010 COURT REPORTER COURTROOM DEPUTY
DEF.
NO. PLF.
NO. DATE
OFFERED MARKED ADMITTED 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 Defendant, Jeffrey Epstein's home and route from
Plaintiff to Defendant'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
EFTA00728817
PLAINTIFF DOE. EXHIBIT LIST CONTINUATION
Dos vs. Epstein - CASE NO. 08-CV-501393•CIV-MARRAMOHNSON
DEF.
NO. PLF.
NO. DATE
OFFERED MARKED ADMITTED DESCRIPTION OF EXHIBITS
8. Messages taken from message pads found at Defendant's home
9 Documents related to Jeffrey Epstein produced by Alfredo
Rodriguez
10. Jeffrey Epstein flight logs
11. 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. Plaintiffs and other 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
21All 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)
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 plaintiff, Jane Doe
28.
29.
30.
31. Affidavit and Application for Search Warrant on Jeffrey
Epstein's home
EFTA00728818
PLAINTIFF DOE. EXHIBIT LIST CONTINUATION
Do* vs. Epstein—CASE NO. 08-CV-10393-CIV-MARRAUOHNSON
DEF.
NO. PLF.
NO. DATE
OFFERED MARKED ADMITTED DESCRIPTION OF EXHIBITS
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
41All 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
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,
0941092
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 Deposit. imony and discovery responses
in State Court cases v. Jeffr pstein, Case No.
502008CA028051 and v. Jeffrey Epstein,
Case No. 502008CP003626XXXXMB
47 Jeffrey Epstein Deposition Testimony and discovery responses
in State Court case Jeffrey Epstein v. Scott Rothstein, et al. Case
No. 502009CA040800)000CMBAG
48 Any and all newspaper articles, online articles or publications
related to Jeffrey Epstein
49. Report and Analysis of Jeffrey Epstein's assets
EFTA00728819
PLAINTIFF DOE, EXHIBIT LIST CONTINUATION
Doe vs Epstein - CASE NO. 08-CV-110893-CIV-MARRA/JOHNSON
DEF.
NO. PI,.
NO. DATE
OFFERED MARKED ADMITTED DESCRIPTION OF EXHIBITS
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
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 Plaintiff
57. Expert Dr. L. Dennison Reed's Report of Plaintiff
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. Fuller, mmunications of Jeffrey Epstein, Jeff MC2 all
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
EFTA00728820
PLAINTIFF DOE. EXHIBIT UST CONTINUATION
Do* vs. Epstsln - CASE NO. 08-CV-80893-CIVAIARFLA/JOHNSON
DEE.
NO. PLF.
NO. DATE
OFFERED MARKED ADMTITED DESCRIPTION OF EXHIBITS
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
81List 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
88. All subpoenas issued to State Grand Jury
89 Documents related to the rental of a vehicle for
90 Ted's Sheds Documents
91. Documents related to property searches of Jeffrey Epstein's
properties
92. Arrest Warrant of
93 Police report regarding 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
EFTA00728821
PLAINTIFF 00E, EXHIBIT LIST CONTINUATION
D0 vs. EpaWin — CASE NO. 08-CV480893-C1V-MARRA/JOHNSON
DEF.
NO. PLF.
NO. DATE
OFFERED MARKED ADMITTED DESCRIPTION OF EXHIBITS
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. Plaintiff's GED testing information and results
101. JEGE, Inc. Passenger Manifest
102. Hyperion Air Passenger Manifest
103. Flight information for
104. Passenger List Palm Beach flights 2005
105. Jeffrey Epstein notepad notes
106. Pleadings of Jane Doe 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. Police Report dated 11-28-04
111. Compulsory Medial Examination of victim,
112. Plaintiff's school records and transcripts
113. Victim Notification letter dated 7-9-08
114. Plaintiff's employment records from IHOP
115. Police report of.luan Alessi theft at Jeffrey Epstein's home
116. Plaintiff's Medical Records from Juvenile Facility
117. Plaintiff's Medical Records from
118. Plaintiff's Medical Records from Wellington Regional Hospital
119. Plaintiffs Medical Records from St. Mary's Medical Center
EFTA00728822
PLAINTIFF DOE. EXHIBIT LIST CONTINUATION
Dos vs Epstein — CASE NO. 08-CV-110893-CIV-MARRA/JOHNSON
DEF.
NO. PLF.
NO. DATE
OFFERED MARKED AumurrED DESCRIPTION OF EXHIBITS
120. Plaintiff's Medical Records from United Health
121. All surveillance conducted by law enforcement on Jeffrey
Epstein's home
122 Entails 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 Plaintiff's Witness List
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
131. Curriculum vitaes of any and all listed experts
132. Curriculum vitae of Dr. Ryan Hall
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 Plaintiff
138. All exhibits to Dr. L. Dennison 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. All exhibits listed on the Defendant's Exhibit List
EFTA00728823
PLAINTIFF DOE. EXHIBIT LIST CONTINUATION
Doe vs Epstein — CASE NO. 08-CV-80893-ClIbMARRA/JOHNSON
DEF.
NO. PLF.
NO. DATE
OFFERED MARKED ADMITTED DESCRIPTION OF EXHIBITS
143. Demonstrative aids and exhibits including, but not limited to,
anatomical charts, diagrams and models, surveys, photographs
and similar material including blow-ups of the aforesaid items.
144. Any and all mortality tables
145. Plaintiffs reserve all objections to Defendant's Exhibits
146. Plaintiffs reserve the right to supplement and/or amend this
Exhibit List
147 By listing an Exhibit, Plaintiff is not waiving their right to object
to same at trial and does not waive their right to amend same.
Plaintiff reserves the right to amend this list.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that the original of the above and a copy of the foregoing has been provided this
'$ day of June 2010 via U.S. Mail and email transmittal to all those on the attached service
Bradley J. Edwards
FARMER, JAFFE, WEISSING,
EDWARDS, FISTOS & LEHRMAN, P.L.
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
Telephone (954) 524-2820
Facsimile (954) 524-2822
Florida Bar No.: 542075
E-mail:
and
Paul G. Cassell
Pro Hac Vice
332 S. 1400 E.
Salt Lake City, UT 84112
Telephone: 801-585-5202
Facsimile: 801-585-6833
E-Mail:
EFTA00728824
📷 Images in this document (8 detected; 6 largest described)
AI-generated factual descriptions of embedded images (llava:13b). These are searchable across the corpus.
[Image 1] The image shows a document with text, which appears to be a certificate or a letter. The document is titled "CERTIFICATE OF SERVICE" and includes a table with columns for "Date," "Service," and "Proof of Service." There is a signature at the bottom, indicating that the document has been signed by a person. The text is too small to read in detail, but it seems to be a formal document related to leg
[Image 2] The image shows a document with a table and text. The document appears to be a list or a record of some sort, possibly related to legal or administrative matters. The text is too small to read clearly, but it seems to be a formal document with headings and bullet points. There are no visible names, dates, places, or logos that can be discerned from this image. The document is not a photograph but
[Image 3] The image shows a document with a table titled "PLAN OF OPERATIONS FOR THE STATE OF FLORIDA." The table contains various entries with numbers and descriptions, likely outlining procedures or protocols for a specific operation or event. The document appears to be a formal or official document, possibly related to law enforcement or emergency management, given the context of the table entries. The t
[Image 4] The image shows a document with a table titled "List of Documents to be Submitted to the Court." The table is organized with columns for "Case Number," "Date," "Description," and "Page Number." There are entries listed under each column, indicating the type of document, the date it was created, a brief description of the document's content, and the page number where the document can be found. The
[Image 5] The image shows a document with a table titled "CLASSIFICATION OF CONFIDENTIAL INFORMATION." The table is divided into columns with headings such as "Date," "Case Number," "Case Title," "Description of Confidential Information," and "Reason for Classification." There are entries in the table with various dates, case numbers, titles, descriptions, and reasons for classification. The document appear
[Image 6] The image shows a document with a table titled "PLANNED WORK LIST CONTROL". The table is divided into columns with headings such as "DATE", "WORK ORDER NUMBER", "WORK ORDER DESCRIPTION", "RESPONSIBLE", "STATUS", and "REMARKS". There are entries filled out in the table, including dates, work order numbers, descriptions, names of responsible parties, status indicators, and remarks. The document appe