#291874/mep

#291874/mep JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTI [STEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800)OOOCMBAO AMENDED 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. NO. PLF. NO. DATE OFFERED MARK ADMIT TED DESCRIPTION OF EXHIBITS EXHIBITS EXPECTED TO BE USED I. All applicable criminal statutes 2. t All applicable Florida Statutes 3. All applicable Rules of Evidence 4. Video of Defendant, Jeffrey Epstein's home and route from Plaintiff tc Defendant's home 5. Order confirmation from Amazon.com for purchase of books "SM 1 Realistic Introduction," "Slave Craft: Roadmap for Erotic Servitude- Principles, Skills and Tools" and "Training Miss Abernathy: A Wor: for Erotic Slaves and Their Owners" 6. Non-Prosecution Agreement EFTA01085219 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 2 of I I DEF. NO. PLF. NO. DATE OFFERED MARK ADMIT TED DESCRIPTION OF EXHIBITS 7. Jane Doe 102 Complaint 8 Messages taken from message pads found at Defendant's home 9. Documents related to Jeffrey Epstein produced by Alfredo Rodrigue: 10 Jeffrey Epstein flight logs 11. Jeffrey Epstein phone records 12 hone records 13 Jail Visitation Logs 14. Jeffrey Epstein's probation file 15. All probable cause affidavits related to criminal investigation ofleffi Epstein 16. All evidence, infonnation 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 IS. 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 Comply 21. All records of homes, properties, bank accounts and any and all reco 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 . Luc Brunel EFTA01085220 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 3 of II DEF. NO. PLF. NO. DATE OFFERED MARK ADMIT TED DESCRIPTION OF EXHIBITS 26. All documents evidencing relationship between Jeffrey Epstein and I' or any modeling agencies 27 Yearbooks of plaintiff, 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 31Affidavit and Application for Search Warrant on Jeffrey Epstein's hr 32 Tape recording or transcript of recording of conversation between Je 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 Epstei 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, Requ. for Admission, Answers to Interrogatories in this matter, and cases l 80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-808 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 42 All discovery related responses of Jeffrey Epstein in this matter and , 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 case against him EFTA01085221 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 4 of I I DEF. NO. PLF. NO. DATE OFFERED MARK ADMIT TED DESCRIPTION OF EXHIBITS 44 All Complaints in which Jeffrey Epstein was a plaintiff or defendant 45. Jeffrey Epstein's Deposition testimony and discovery responses in th and cases 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 084 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 46 Jeffrey Epstein's Deposition testimony and discovery responses in St Court cases LM v. Jeffrey Epstein, Case No. 502008CA0280513OO( AB and E.W. v. Jeffrey Epstein, Case No. 502008CP003626XXXXI% 47. Jeffrey Epstein Deposition Testimony and discovery responses in SU- Court case Jeffrey Epstein v. Scott Rothstein, et al. Case No. 502009CA040800XXXXMBAG 48. Any and all newspaper articles, online articles or publications related Jeffrey Epstein 49 Report and Analysis of Jeffrey Epstein's assets 50. Video footage (DVD) of walk through site inspection of Jeffrey Epst home. 51. Photos of all of Jeffrey Epstein's properties, cars, boats and planes 52. Probable Cause Affidavits prepared against Jeffrey Epstein and Saral 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 la. 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 fl logs EFTA01085222 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 5 of I I DEF. NO. PLF. NO. DATE OFFERED MARK ADMIT TED DESCRIPTION OF EXHIBITS 62 Passenger lists for flights taken by Jeffrey Epstein 63. Letter from Jeffrey Epstein to Alberto Pinto regarding house island p 64. Jeffrey Epstein's bank statements Jeffrey Epstein's tax returns 65. MC2 emails involving communications of Jeffrey Epstein, Jeff Fuller, 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 hom( 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 EFTA01085223 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 6 of II DEF. NO. PLF. NO. DATE OFFERED MARK ADMIT TED DESCRIPTION OF EXHIBITS 80 Letter from Chief o 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 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 propertir 92 Arrest Warrant of 93. Police report regarding icking up money dated 11-2 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 EFTA01085224 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 7 of I I DEF. NO. PLF. NO. DATE OFFERED MARK ADMIT TED DESCRIPTION OF EXHIBITS 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 5 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, CMA 112 Plaintiff's school records and transcripts 113. Victim Notification letter dated 7-9-08 114. Plaintiffs employment records from IHOP 115. Police report of Juan Alessi theft at Jeffrey Epstein's home 116. Plaintiff's Medical Records from Milton Girls Juvenile Facility 117. Plaintiff's Medical Records from Dr. Randee Speciale 118. Plaintiff's Medical Records from Wellington Regional Hospital 119. Plaintiff's Medical Records from St. Mary's Medical Center EFTA01085225 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG EXHIBIT LIST OF COIJNTERPLAINTIFF, BRADLEY EDWARDS Page 8 of 11 DEF. NO. PLF. NO. DATE OFFERED MARK ADMIT TED DESCRIPTION OF EXHIBITS 120. Plaintiff's Medical Records from United Health 121All surveillance conducted by law enforcement on Jeffrey Epstein's I 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 Epst 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 .roduced b Palm Beach Police Department prior to t deposition of 128. Photographs of all persons listed on Plaintiff's Witness List 129 Statements, deposition transcripts, videotaped depositions and transc taken in connection with this and all related cases and exhibits theret 130. Any and all expert witness reports and/or records generated in preps] for this litigation by any party to this cause 131Curriculum vitaes of any and all listed experts 132 Curriculum vitae of Dr. Ryan Hall 133. My 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 EFTA01085226 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG EXHIBIT LIST OF COIJNTERPLAINTIFF, BRADLEY EDWARDS Page 9 of II DEF. NO. PLF. NO. DATE OFFERED MARX ADMIT TED DESCRIPTION OF EXHIBITS 140. All items and documents reviewed by Dr. Richard Hall 141All items and documents reviewed by Dr. Ryan Hall 142 All exhibits listed on the Defendant's Exhibit List 143 Demonstrative aids and exhibits including, but not limited to, anatorr charts, diagrams and models, surveys, photographs and similar mater 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 1 147. By listing an Exhibit, Plaintiff is not waiving their right to object to s trial and does not waive their right to amend same. 148. All exhibits listed by Epstein subject to Edwards' objections. 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' Motion for Summary Judgment. 151All time records and hourly billing documentation produced in disco — — - All deposition testimony and discovery responses by Epstein submit'152. this action. 153. All pleadings filed by Epstein in the Rothstein bankruptcy proceedin -- - - 154. 7- i All submissions by Epstein n connection with the Rothstein deposit 155. All Settlement Agreements between Epstein and victims of his sexut molestations. Plaintiff reserves the right to amend this list. EFTA01085227 Edwards adv. Epstein Case No.: 502009CA040800)OOCXMBAG EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page loot II I HEREBY CERTIFY that a true and correct copy of the foregoing has been finished by E- Service to all counsel on the attached list, this day of June, 2013. 7-1Jack Scarola Florida Bar No.: 169440 Searcy Denney Scarola Barnhart & Shipley, P.A. war EFTA01085228 Edwards adv. Epstein Case No.: 502009CA040800000CMBAG EXHIBIT LIST OF COUNTERPLAINT1FF, BRADLEY EDWARDS Page I I of 11 COUNSEL LIST Jack A. Goldberger, Esquire Atterbury, Goldber er & Weiss, P.A. orneys ore ey ps em Bradley J. Edwards, Esquire Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, FL Fred Haddad, P.A. Attorneys for Jeffrey Epstein Marc S. Nurik, Esquire Law Offices of Marc S. Nurik Attorneys for Scott Rothstein Tonja I laddad Coleman, Esquire Attorneys for Jeffrey Epstein EFTA01085229