#291874/mep

#291874/mep JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, 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)OOO(MBAG 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. NO. PLF. NO. DATE OFFERED MARK ADMIT 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. NO. PLF. NO. DATE OFFERED MARK ADMIT 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 II. 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 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) EFTA01140115 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 3 of I I DEF. NO. PLF. NO. DATE OFFERED MARK ADMIT 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 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 EFTA01140116 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 4 of I I DEF. NO. PLF. NO. DATE OFFERED MARK ADMIT 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. 502008CP003626XXXXMB 47 Jeffrey Epstein Deposition Testimony and discovery responses in State Court case Jeffrey Epstein v. Scott Rothstein, et al. Case No 502009C A040800XXXXMBAG 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. 51Photos of all of Jeffrey Epstein's properties, cars, boats and planes 52. Prob Affidavits prepared against Jeffrey Epstein and 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 EFTA01140117 Edwards adv. Epstein Case No.: 502009CAC140800XXXXMBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 5 of I I DEF. NO. PLF. NO. DATE OFFERED MARK ADMIT 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 mails 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 EFTA01140118 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 6 of II DEF. NO. PLF. NO. DATE OFFERED MARK ADMIT TED DESCRIPTION OF EXHIBITS 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 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 Vanessa Zalis 90. Ted's Sheds Documents 91Documents related to property searches of Jeffrey Epstein's properties 92 Arrest Warrant of Sarah Kellen 93. Police report regarding Alexandra Hall picking up money dated 11-28-04 EFTA01140119 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 7 of I I DEF. NO. PLF. NO. DATE OFFERED MARK ADMIT TED DESCRIPTION OF EXHIBITS 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 100. Victim's GED testing information and results 101. JEGE, Inc. Passenger Manifest 102. Hyperion Air Passenger Manifest 103. Flight information for Dana Burns 104. Passenger List Palm Beach flights 2005 105. Jeffrey Epstein notepad notes 106. Pleadings of lane Doe 1 and 2 v. US case 107. Jeffrey Epstein 5h Amendment Speech 108. Reiter letter to Krisher dated 5-1-06 109. Jail receipts of Jeffrey Epstein 110. Alexandra Hall Police Report dated 11-28-04 III. Compulsory Medial Examination of victim, CMA 112. Victim's school records and transcripts 113. Victim Notification letter dated 7-9-08 EFTA01140120 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 8 of 11 DEF. NO. PLF. NO. DATE OFFERED MARK ADMIT TED DESCRIPTION OF EXHIBITS 114 Victim's employment records from MOP 115. Police report of Juan Alessi theft at Jeffrey Epstein's home 116 Victim's Medical Records from Milton Girls Juvenile Facility 117 Victim's Medical Records from Dr. Randee Speciale 118 Victim's Medical Records from Wellington Regional Hospital 119 Victim's Medical Records from St. Mary's Medical Center 120 Victim's Medical Records from United Health 121. All surveillance conducted by law enforcement on Jeffrey Epstein's home 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 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 Victims' Witness Lists 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 131Curriculum vitaes of any and all listed experts 132. Curriculum vitae of Dr. Ryan Hall EFTA01140121 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page 9 of I I DEF. NO. PLF. NO. DATE OFFERED MARK ADMIT TED DESCRIPTION OF EXHIBITS 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 Victims 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 141All items and documents reviewed by Dr. Ryan Hall 142 All exhibits listed on the Epstein's Exhibit List 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. mo rtality-tables144. 145 Edwards' reserves all objections to Epstein's Exhibits 146. Edwards reserves the right to supplement and/or amend his Exhibit List 147. By listing an Exhibit, Edwards is not waiving his right to object to same at 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. EFTA01140122 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS Page I 0 of I I DEF. NO. PLF. NO. DATE OFFERED MARK ADMIT TED DESCRIPTION OF EXHIBITS 151All time records and hourly billing documentation produced in discovery. 152 All deposition testimony and discovery responses by Epstein submitted in this action. 153. All pleadings filed by Epstein in the Rothstein bankruptcy proceeding. 154. All submissions by Epstein in connection with the Rothstein deposition. 155. All Settlement Agreements between Epstein and victims 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 Jack S ola/ 2014. law.com; [email protected] 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 Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Phone: (561)-659-8300 Fax: (561)-835-8691 Attorneys for Jeffrey Epstein Bradley J. Edwards, Esquire staff.efile®pathtojustice.com Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, FL 425 North Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954) 524-2820 Fax: (954) 524-2822 Fred Haddad, Esquire [email protected]; haddadfm®aol.com Fred Haddad, P.A. One Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 Phone: (954)-467-6767 Fax: (954)-467-3599 Attorneys for Jeffrey Epstein Marc S. Nurik, Esquire [email protected] Law Offices of Marc S. Nurik One E Broward Blvd., Suite 700 Fort Lauderdale, FL. 33301 Phone: (954)-745-5849 Fax: (954)-745-3556 Attorneys for Scott Rothstein Tonja Haddad Coleman, Esquire tonja®tonjahaddad.com; Debbie®Tonjahaddad.com Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Phone: (954)467-1223 Fax: (954)-337-3716 Attorneys for Jeffrey Epstein EFTA01140124