EFTA01085219.pdf
#291874/mep IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT, IN AND
FOR PALM BEACH COUNTY, FLORIDA
CASE NO.: 502009CA040800)OOOCMBAO
JEFFREY EPSTEIN,
Plaintiff,
vs.
SCOTT ROTI [STEIN, individually,
BRADLEY J. EDWARDS, individually, and
L.M., individually,
Defendant,
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. PLF. DATE
OFFERED MARK ADMIT
NO. NO. TED DESCRIPTION OF EXHIBITS
EXHIBITS EXPECTED TO BE USED
I. All applicable criminal statutes
t
2. 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. PLF. DATE
MARK ADMIT
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
TED
7. Jane Doe 102 Complaint
8 Messages taken from message pads found at Defendant's home
Documents related to Jeffrey Epstein produced by Alfredo Rodrigue:
9.
Jeffrey Epstein flight logs
10
Jeffrey Epstein phone records
11.
hone records
12
Jail Visitation Logs
13
Jeffrey Epstein's probation file
14.
All probable cause affidavits related to criminal investigation ofleffi
15.
Epstein
All evidence, infonnation and documents taken or possessed by FBI
16. related to criminal investigation of Jeffrey Epstein
Plaintiffs and other victims' statements to the FBI related to criminal
17. investigation of Jeffrey Epstein
Video of Search Warrant of Jeffrey Epstein's home being executed
IS.
Application for Search Warrant of Jeffrey Epstein's home
19
Complaint Jane Doe v. Epstein and all subsequent Amended Comply
20.
All records of homes, properties, bank accounts and any and all reco
21.
related to Jeffrey Epstein's assets
Jeffrey Epstein's passport (or copy)
22.
Jeffrey Epstein's driver's license (or copy)
23
List of corporations owned by Jeffrey Epstein
24
All documents evidencing relationship between Jeffrey Epstein and .
25.
Luc Brunel
EFTA01085220
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 3 of II
DEF. PLF. DATE MARK ADMIT
NO. NO. OFFERED TED DESCRIPTION OF EXHIBITS
All documents evidencing relationship between Jeffrey Epstein and I'
26.
or any modeling agencies
Yearbooks of plaintiff, Jane Doe
27
2002 Royal Palm Beach High School Year Book
28
2001 Royal Palm Beach High School Year Book
29
2003 Palm Beach Gardens High School Year Book
30.
Affidavit and Application for Search Warrant on Jeffrey Epstein's hr
31
Tape recording or transcript of recording of conversation between Je
32
Epstein and George Rush
Notepads found in Jeffrey Epstein's home and/or during trash pulls
33.
outside of his home during criminal investigation
The Palm Beach State Attorney's Criminal file against Jeffrey Epstei
34.
All documents related to Jeffrey Epstein's 6/30/08 conviction
35.
Jeffrey Epstein's criminal plea colloquy
36.
37. Public records from the Department of Corrections related to Jeffrey
Epstein
Records from the Florida Department of Law Enforcement related to
38
Jeffrey Epstein
All statements made by Jeffrey Epstein
39
List of properties and vehicles in Larry Visoski's name
40.
All of Jeffrey Epstein's Responses to Requests for Production, Requ.
41
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
All discovery related responses of Jeffrey Epstein in this matter and ,
42
08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08.
80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092
Jeffrey Epstein's Answers and Affirmative Defenses in all civil case
43.
against him
EFTA01085221
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 4 of I I
DEF. PLF. DATE
MARK ADMIT
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
TED
All Complaints in which Jeffrey Epstein was a plaintiff or defendant
44
Jeffrey Epstein's Deposition testimony and discovery responses in th
45.
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
Jeffrey Epstein's Deposition testimony and discovery responses in St
46
Court cases LM v. Jeffrey Epstein, Case No. 502008CA0280513OO(
AB and E.W. v. Jeffrey Epstein, Case No. 502008CP003626XXXXI%
Jeffrey Epstein Deposition Testimony and discovery responses in SU-
47.
Court case Jeffrey Epstein v. Scott Rothstein, et al. Case No.
502009CA040800XXXXMBAG
Any and all newspaper articles, online articles or publications related
48. Jeffrey Epstein
Report and Analysis of Jeffrey Epstein's assets
49
Video footage (DVD) of walk through site inspection of Jeffrey Epst
50. home.
Photos of all of Jeffrey Epstein's properties, cars, boats and planes
51.
Probable Cause Affidavits prepared against Jeffrey Epstein and Saral
52.
Audio tape of
53.
Photographs, videos and books taken in the search warrant of Jeffrey
54.
Epstein's home
Documents related to or evidencing Jeffrey Epstein's donations to la.
55. enforcement
Victim Notification Letter from US Attorney's Office to Plaintiff
56.
57. Expert Dr. L. Dennison Reed's Report of Plaintiff
Palm Beach Police Department Incident Report dated 4/20/06
58
All reports and documentation generated by Palm Beach Police
59.
Department related to Jeffrey Epstein
All Witness Statements generated by Palm Beach Police Department
60. relating to Jeffrey Epstein
Passenger Manifests of Jeffrey Epstein's aircraft and private plane fl
61. logs
EFTA01085222
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 5 of I I
DEF. PLF. DATE
NO. NO. 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
Documents related to Jeffrey Epstein's investments
79.
EFTA01085223
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 6 of II
DEF. PLF. DATE MARK ADMIT
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
TED
Letter from Chief o Barry Krischler
80
List of planes owned by Jeffrey Epstein
81.
Letter from Guy Fronstin to Assistant State Attorney dated 1-11-06
82
Letter from Guy Fronstin to Assistant State Attorney dated 1-13-06
83.
Letter from Guy Fronstin to Assistant State Attorney dated 2-17-06
84
Letter from Guy Fronstin to Assistant State Attorney dated 4-6-06
85
Letter from Guy Fronstin to Assistant State Attorney dated 4-10-06
86
Letter from Goldberger dated 6-22-06
87
All subpoenas issued to State Grand Jury
88.
Documents related to the rental of a vehicle for
89
Ted's Sheds Documents
90.
Documents related to property searches of Jeffrey Epstein's propertir
91.
Arrest Warrant of
92
Police report regarding icking up money dated 11-2
93.
List of Trilateral Commission Members of 2003
94
Alan Dershowitz Letter dated 4-19-06 and Statute 90.410
95
Guy Fronstin letter dated 4-17-06
96.
Jeffrey Epstein Account Information
97
Jeffrey Epstein Criminal Closeout Sheet
98
Jeffrey Epstein Polygraph Test and Results
99.
EFTA01085224
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 7 of I I
DEF. PLF. DATE
MARK ADMIT
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
TED
Plaintiff's GED testing information and results
100.
JEGE, Inc. Passenger Manifest
101.
Hyperion Air Passenger Manifest
102.
Flight information for
103.
104. Passenger List Palm Beach flights 2005
Jeffrey Epstein notepad notes
105.
Pleadings of Jane Doe 1 and 2 v. US case
106.
Jeffrey Epstein 5 Amendment Speech
107.
Reiter letter to Krisher dated 5-1-06
108.
Jail receipts of Jeffrey Epstein
109.
Police Report dated 11-28-04
110.
Compulsory Medial Examination of victim, CMA
111.
Plaintiff's school records and transcripts
112
Victim Notification letter dated 7-9-08
113.
Plaintiffs employment records from IHOP
114.
Police report of Juan Alessi theft at Jeffrey Epstein's home
115.
Plaintiff's Medical Records from Milton Girls Juvenile Facility
116.
Plaintiff's Medical Records from Dr. Randee Speciale
117.
Plaintiff's Medical Records from Wellington Regional Hospital
118.
Plaintiff's Medical Records from St. Mary's Medical Center
119.
EFTA01085225
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
EXHIBIT LIST OF COIJNTERPLAINTIFF, BRADLEY EDWARDS
Page 8 of 11
DEF. PLF. DATE
MARK ADMIT
NO. NO. OFFERED
TED
DESCRIPTION OF EXHIBITS
Plaintiff's Medical Records from United Health
120.
All surveillance conducted by law enforcement on Jeffrey Epstein's I
121
Emails received from Palm Beach Records related to Jeffrey Epstein
122.
All items listed on the Palm Beach Police Property Report Lists
123
All items taken in the execution of the search warrant of Jeffrey Epst
124.
home: 358 EL BRILLO WAY, PALM BEACH FL 33480
All copies of convictions related to Jeffrey Epstein
125
Jeffrey Epstein criminal records
126.
All documents .roduced b Palm Beach Police Department prior to t
127
deposition of
Photographs of all persons listed on Plaintiff's Witness List
128.
Statements, deposition transcripts, videotaped depositions and transc
129
taken in connection with this and all related cases and exhibits theret
Any and all expert witness reports and/or records generated in preps]
130. for this litigation by any party to this cause
Curriculum vitaes of any and all listed experts
131
Curriculum vitae of Dr. Ryan Hall
132
My articles or publications of Dr. Ryan Hall
133.
Any articles or publications of Dr. Richard Hall
134.
Any articles or publications of Dr. L. Dennison Reed
135.
All items and documentation review by Dr. L. Dennison Reed
136.
Transcript and video (DVD) of IME of Plaintiff
137
All exhibits to Dr. L. Dennison Reed's Deposition
138
All exhibits to Dr. Richard Hall's Deposition
139.
EFTA01085226
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
EXHIBIT LIST OF COIJNTERPLAINTIFF, BRADLEY EDWARDS
Page 9 of II
DEF. PLF. DATE ADMIT
MARX
NO. NO. OFFERED TED DESCRIPTION OF EXHIBITS
All items and documents reviewed by Dr. Richard Hall
140.
All items and documents reviewed by Dr. Ryan Hall
141
All exhibits listed on the Defendant's Exhibit List
142
Demonstrative aids and exhibits including, but not limited to, anatorr
143
charts, diagrams and models, surveys, photographs and similar mater
including blow-ups of the aforesaid items.
Any and all mortality tables
144.
Plaintiffs reserve all objections to Defendant's Exhibits
145.
Plaintiffs reserve the right to supplement and/or amend this Exhibit 1
146.
By listing an Exhibit, Plaintiff is not waiving their right to object to s
147.
trial and does not waive their right to amend same.
All exhibits listed by Epstein subject to Edwards' objections.
148.
All pleadings and attachments in the action under the Crime Victims
149
Rights Act prosecuted by Bradley Edwards on behalf of victims of
Epstein's criminal molestations.
All attachments to Edwards' Motion for Summary Judgment.
150.
All time records and hourly billing documentation produced in disco
151
— — -
All deposition testimony and discovery responses by Epstein submit'
152. this action.
All pleadings filed by Epstein in the Rothstein bankruptcy proceedin
153.
7- -- - -
All submissions by Epstein in connection with the Rothstein deposit
154.
All Settlement Agreements between Epstein and victims of his sexut
155.
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.
7-1
Jack 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.
Attorneys for Jeffrey Epstein
Marc S. Nurik, Esquire
orneys ore ey ps em Law Offices of Marc S. Nurik
Bradley J. Edwards, Esquire
Farmer, Jaffe, Weissing, Edwards, Fistos &
Lehrman, FL Attorneys for Scott Rothstein
Tonja I laddad Coleman, Esquire
Fred Haddad, P.A.
Attorneys for Jeffrey Epstein
EFTA01085229
FIFTEENTH JUDICIAL CIRCUIT, IN AND
FOR PALM BEACH COUNTY, FLORIDA
CASE NO.: 502009CA040800)OOOCMBAO
JEFFREY EPSTEIN,
Plaintiff,
vs.
SCOTT ROTI [STEIN, individually,
BRADLEY J. EDWARDS, individually, and
L.M., individually,
Defendant,
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. PLF. DATE
OFFERED MARK ADMIT
NO. NO. TED DESCRIPTION OF EXHIBITS
EXHIBITS EXPECTED TO BE USED
I. All applicable criminal statutes
t
2. 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. PLF. DATE
MARK ADMIT
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
TED
7. Jane Doe 102 Complaint
8 Messages taken from message pads found at Defendant's home
Documents related to Jeffrey Epstein produced by Alfredo Rodrigue:
9.
Jeffrey Epstein flight logs
10
Jeffrey Epstein phone records
11.
hone records
12
Jail Visitation Logs
13
Jeffrey Epstein's probation file
14.
All probable cause affidavits related to criminal investigation ofleffi
15.
Epstein
All evidence, infonnation and documents taken or possessed by FBI
16. related to criminal investigation of Jeffrey Epstein
Plaintiffs and other victims' statements to the FBI related to criminal
17. investigation of Jeffrey Epstein
Video of Search Warrant of Jeffrey Epstein's home being executed
IS.
Application for Search Warrant of Jeffrey Epstein's home
19
Complaint Jane Doe v. Epstein and all subsequent Amended Comply
20.
All records of homes, properties, bank accounts and any and all reco
21.
related to Jeffrey Epstein's assets
Jeffrey Epstein's passport (or copy)
22.
Jeffrey Epstein's driver's license (or copy)
23
List of corporations owned by Jeffrey Epstein
24
All documents evidencing relationship between Jeffrey Epstein and .
25.
Luc Brunel
EFTA01085220
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 3 of II
DEF. PLF. DATE MARK ADMIT
NO. NO. OFFERED TED DESCRIPTION OF EXHIBITS
All documents evidencing relationship between Jeffrey Epstein and I'
26.
or any modeling agencies
Yearbooks of plaintiff, Jane Doe
27
2002 Royal Palm Beach High School Year Book
28
2001 Royal Palm Beach High School Year Book
29
2003 Palm Beach Gardens High School Year Book
30.
Affidavit and Application for Search Warrant on Jeffrey Epstein's hr
31
Tape recording or transcript of recording of conversation between Je
32
Epstein and George Rush
Notepads found in Jeffrey Epstein's home and/or during trash pulls
33.
outside of his home during criminal investigation
The Palm Beach State Attorney's Criminal file against Jeffrey Epstei
34.
All documents related to Jeffrey Epstein's 6/30/08 conviction
35.
Jeffrey Epstein's criminal plea colloquy
36.
37. Public records from the Department of Corrections related to Jeffrey
Epstein
Records from the Florida Department of Law Enforcement related to
38
Jeffrey Epstein
All statements made by Jeffrey Epstein
39
List of properties and vehicles in Larry Visoski's name
40.
All of Jeffrey Epstein's Responses to Requests for Production, Requ.
41
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
All discovery related responses of Jeffrey Epstein in this matter and ,
42
08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08.
80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092
Jeffrey Epstein's Answers and Affirmative Defenses in all civil case
43.
against him
EFTA01085221
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 4 of I I
DEF. PLF. DATE
MARK ADMIT
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
TED
All Complaints in which Jeffrey Epstein was a plaintiff or defendant
44
Jeffrey Epstein's Deposition testimony and discovery responses in th
45.
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
Jeffrey Epstein's Deposition testimony and discovery responses in St
46
Court cases LM v. Jeffrey Epstein, Case No. 502008CA0280513OO(
AB and E.W. v. Jeffrey Epstein, Case No. 502008CP003626XXXXI%
Jeffrey Epstein Deposition Testimony and discovery responses in SU-
47.
Court case Jeffrey Epstein v. Scott Rothstein, et al. Case No.
502009CA040800XXXXMBAG
Any and all newspaper articles, online articles or publications related
48. Jeffrey Epstein
Report and Analysis of Jeffrey Epstein's assets
49
Video footage (DVD) of walk through site inspection of Jeffrey Epst
50. home.
Photos of all of Jeffrey Epstein's properties, cars, boats and planes
51.
Probable Cause Affidavits prepared against Jeffrey Epstein and Saral
52.
Audio tape of
53.
Photographs, videos and books taken in the search warrant of Jeffrey
54.
Epstein's home
Documents related to or evidencing Jeffrey Epstein's donations to la.
55. enforcement
Victim Notification Letter from US Attorney's Office to Plaintiff
56.
57. Expert Dr. L. Dennison Reed's Report of Plaintiff
Palm Beach Police Department Incident Report dated 4/20/06
58
All reports and documentation generated by Palm Beach Police
59.
Department related to Jeffrey Epstein
All Witness Statements generated by Palm Beach Police Department
60. relating to Jeffrey Epstein
Passenger Manifests of Jeffrey Epstein's aircraft and private plane fl
61. logs
EFTA01085222
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 5 of I I
DEF. PLF. DATE
NO. NO. 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
Documents related to Jeffrey Epstein's investments
79.
EFTA01085223
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 6 of II
DEF. PLF. DATE MARK ADMIT
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
TED
Letter from Chief o Barry Krischler
80
List of planes owned by Jeffrey Epstein
81.
Letter from Guy Fronstin to Assistant State Attorney dated 1-11-06
82
Letter from Guy Fronstin to Assistant State Attorney dated 1-13-06
83.
Letter from Guy Fronstin to Assistant State Attorney dated 2-17-06
84
Letter from Guy Fronstin to Assistant State Attorney dated 4-6-06
85
Letter from Guy Fronstin to Assistant State Attorney dated 4-10-06
86
Letter from Goldberger dated 6-22-06
87
All subpoenas issued to State Grand Jury
88.
Documents related to the rental of a vehicle for
89
Ted's Sheds Documents
90.
Documents related to property searches of Jeffrey Epstein's propertir
91.
Arrest Warrant of
92
Police report regarding icking up money dated 11-2
93.
List of Trilateral Commission Members of 2003
94
Alan Dershowitz Letter dated 4-19-06 and Statute 90.410
95
Guy Fronstin letter dated 4-17-06
96.
Jeffrey Epstein Account Information
97
Jeffrey Epstein Criminal Closeout Sheet
98
Jeffrey Epstein Polygraph Test and Results
99.
EFTA01085224
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
EXHIBIT LIST OF COUNTERPLAINTIFF, BRADLEY EDWARDS
Page 7 of I I
DEF. PLF. DATE
MARK ADMIT
NO. NO. OFFERED DESCRIPTION OF EXHIBITS
TED
Plaintiff's GED testing information and results
100.
JEGE, Inc. Passenger Manifest
101.
Hyperion Air Passenger Manifest
102.
Flight information for
103.
104. Passenger List Palm Beach flights 2005
Jeffrey Epstein notepad notes
105.
Pleadings of Jane Doe 1 and 2 v. US case
106.
Jeffrey Epstein 5 Amendment Speech
107.
Reiter letter to Krisher dated 5-1-06
108.
Jail receipts of Jeffrey Epstein
109.
Police Report dated 11-28-04
110.
Compulsory Medial Examination of victim, CMA
111.
Plaintiff's school records and transcripts
112
Victim Notification letter dated 7-9-08
113.
Plaintiffs employment records from IHOP
114.
Police report of Juan Alessi theft at Jeffrey Epstein's home
115.
Plaintiff's Medical Records from Milton Girls Juvenile Facility
116.
Plaintiff's Medical Records from Dr. Randee Speciale
117.
Plaintiff's Medical Records from Wellington Regional Hospital
118.
Plaintiff's Medical Records from St. Mary's Medical Center
119.
EFTA01085225
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
EXHIBIT LIST OF COIJNTERPLAINTIFF, BRADLEY EDWARDS
Page 8 of 11
DEF. PLF. DATE
MARK ADMIT
NO. NO. OFFERED
TED
DESCRIPTION OF EXHIBITS
Plaintiff's Medical Records from United Health
120.
All surveillance conducted by law enforcement on Jeffrey Epstein's I
121
Emails received from Palm Beach Records related to Jeffrey Epstein
122.
All items listed on the Palm Beach Police Property Report Lists
123
All items taken in the execution of the search warrant of Jeffrey Epst
124.
home: 358 EL BRILLO WAY, PALM BEACH FL 33480
All copies of convictions related to Jeffrey Epstein
125
Jeffrey Epstein criminal records
126.
All documents .roduced b Palm Beach Police Department prior to t
127
deposition of
Photographs of all persons listed on Plaintiff's Witness List
128.
Statements, deposition transcripts, videotaped depositions and transc
129
taken in connection with this and all related cases and exhibits theret
Any and all expert witness reports and/or records generated in preps]
130. for this litigation by any party to this cause
Curriculum vitaes of any and all listed experts
131
Curriculum vitae of Dr. Ryan Hall
132
My articles or publications of Dr. Ryan Hall
133.
Any articles or publications of Dr. Richard Hall
134.
Any articles or publications of Dr. L. Dennison Reed
135.
All items and documentation review by Dr. L. Dennison Reed
136.
Transcript and video (DVD) of IME of Plaintiff
137
All exhibits to Dr. L. Dennison Reed's Deposition
138
All exhibits to Dr. Richard Hall's Deposition
139.
EFTA01085226
Edwards adv. Epstein
Case No.: 502009CA040800XXXXMBAG
EXHIBIT LIST OF COIJNTERPLAINTIFF, BRADLEY EDWARDS
Page 9 of II
DEF. PLF. DATE ADMIT
MARX
NO. NO. OFFERED TED DESCRIPTION OF EXHIBITS
All items and documents reviewed by Dr. Richard Hall
140.
All items and documents reviewed by Dr. Ryan Hall
141
All exhibits listed on the Defendant's Exhibit List
142
Demonstrative aids and exhibits including, but not limited to, anatorr
143
charts, diagrams and models, surveys, photographs and similar mater
including blow-ups of the aforesaid items.
Any and all mortality tables
144.
Plaintiffs reserve all objections to Defendant's Exhibits
145.
Plaintiffs reserve the right to supplement and/or amend this Exhibit 1
146.
By listing an Exhibit, Plaintiff is not waiving their right to object to s
147.
trial and does not waive their right to amend same.
All exhibits listed by Epstein subject to Edwards' objections.
148.
All pleadings and attachments in the action under the Crime Victims
149
Rights Act prosecuted by Bradley Edwards on behalf of victims of
Epstein's criminal molestations.
All attachments to Edwards' Motion for Summary Judgment.
150.
All time records and hourly billing documentation produced in disco
151
— — -
All deposition testimony and discovery responses by Epstein submit'
152. this action.
All pleadings filed by Epstein in the Rothstein bankruptcy proceedin
153.
7- -- - -
All submissions by Epstein in connection with the Rothstein deposit
154.
All Settlement Agreements between Epstein and victims of his sexut
155.
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.
7-1
Jack 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.
Attorneys for Jeffrey Epstein
Marc S. Nurik, Esquire
orneys ore ey ps em Law Offices of Marc S. Nurik
Bradley J. Edwards, Esquire
Farmer, Jaffe, Weissing, Edwards, Fistos &
Lehrman, FL Attorneys for Scott Rothstein
Tonja I laddad Coleman, Esquire
Fred Haddad, P.A.
Attorneys for Jeffrey Epstein
EFTA01085229