EFTA01113986.pdf
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT,
INAND FOR PALM BEACH COUNTY,
FLORIDA
CASE NO.: 502009CA040800XXXXMBAG
JEFFREY EPSTEIN,
Plaintiff/Counter-Defendant, JUDGE: DAVID CROW
VS.
SCOTT ROTHSTEIN,
individually, BRADLEY J.
EDWARDS, individually,
Defendants/Counter-Plaintiff,
EPSTEIN'S OBJECTIONS TO EDWARDS'S REVISED EXHIBIT LIST
Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his
undersigned counsel and pursuant to Paragraph D4 of this Court's Order Setting Jury
Trial and Directing Pretrial and Mediation Procedures, hereby objects to the following of
Defendant/Counter-Plaintiff Bradley Edwards's trial exhibits:
All applicable criminal statutes
All applicable Florida Statutes
All applicable Rules of Evidence
Video of Jeffrey Epstein's home and route from victim to Epstein's home- Irrelevant
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"
Non-Prosecution Agreement
EFTA01113986
102 Complaint
Messages taken from message pads found at Epstein's home-
Documents related to Jeffrey Epstein produced by Alfredo Rodriguez
Jeffrey Epstein flight logs
Jeffrey Epstein phone records
phone records
Jail Visitation Logs
Jeffrey Epstein's probation file
All probable cause affidavits related to criminal investigation of Jeffrey Epstein
All evidence, information and documents taken or possessed by FBI related to criminal
investigation of Jeffrey Epstein
Victims' statements to the FBI related to criminal investigation of Jeffrey Epstein
Video of Search Warrant of Jeffrey Epstein's home being executed
Application for Search Warrant of Jeffrey Epstein's home
Complaint Jane Doe v. Epstein and all subsequent Amended Complaints
All records of homes, properties, bank accounts and any and all records related to Jeffrey
Epstein's assets- ok for punies only?
Jeffrey Epstein's passport (or copy)
Jeffrey Epstein's driver's license (or copy)
List of corporations owned by Jeffrey Epstein ok for punies only?
All documents evidencing relationship between Jeffrey Epstein and Jean Luc Brunel
All documents evidencing relationship between Jeffrey Epstein and MC2 or any
modeling agencies
Yearbooks of Jane Doe
EFTA01113987
2002 Royal Palm Beach High School Year Book
2001 Royal Palm Beach High School Year Book
2003 Palm Beach Gardens High School Year Book
Affidavit and Application for Search Warrant on Jeffrey Epstein's home
Tape recording or transcript of recording of conversation between Jeffrey Epstein and
George Rush
Notepads found in Jeffrey Epstein's home and/or during trash pulls outside of his home
during criminal investigation
The Palm Beach State Attorney's Criminal file against Jeffrey Epstein
All documents related to Jeffrey Epstein's 6/30/08 conviction
Jeffrey Epstein's criminal plea colloquy
Public records from the Department of Corrections related to Jeffrey Epstein
Records from the Florida Department of Law Enforcement related to Jeffrey Epstein
All statements made by Jeffrey Epstein
List of properties and vehicles in Larry Visoski 's name
All of Jeffrey Epstein's Responses to Requests for Production, Requests for Admission,
Answers to Intel rngatories 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
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
Jeffrey Epstein's Answers and Affirmative Defenses in all civil cases against him
All Complaints in which Jeffrey Epstein was a plaintiff or defendant
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
EFTA01113988
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)OOOCMB
Jeffrey Epstein Deposition Testimony and discovery responses in State Court case Jeffrey
Epstein v. Scott Rothstein, et al. Case No. 502009CA040800XXXXMBAG
Any and all newspaper articles, online articles or publications related to Jeffrey Epstein
Report and Analysis of Jeffrey Epstein's assets- punies trial only
Video footage (DVD) of walk through site inspection of Jeffrey Epstein's home.
Photos of all of Jeffrey Epstein's properties, cars, boats and planes punies trial only
Probable Cause Affidavits prepared against Jeffrey Epstein and
Audio tape o
Photographs, videos and books taken in the search waimnt of Jeffrey Epstein's home
Documents related to or evidencing Jeffrey Epstein's donations to law enforcement
Victim Notification Letter from US Attorney's Office to Victim
Expert Dr. L. Dennison Reed's Report of Victim
Palm Beach Police Department Incident Report dated 4/20/06
All reports and documentation generated by Palm Beach Police Department related to
Jeffrey Epstein
All Witness Statements generated by Palm Beach Police Department relating to Jeffrey
Epstein
Passenger Manifests of Jeffrey Epstein's aircraft and private plane flight logs
Passenger lists for flights taken by Jeffrey Epstein
Letter from Jeffrey Epstein to Alberto Pinto regarding house island project
Jeffrey Epstein's bank statements-punies trial only
Jeffrey Epstein's tax returns- punies trial only
EFTA01113989
MC2 emails involving communications of Jeffrey Epstein, Jeff Puller
Pappas Suat, Jean Luc Brunel and Amanda Grant
DVD of plea and colloquy taken on 6-30-08
Transcript of plea and colloquy taken on 6-30-08
Massage Table
Lotions taken from Jeffrey Epstein's home during search warrant
Computers taken from Jeffrey Epstein's home during search warrant
Vibrators, dildos and other sex toys taken from Jeffrey Epstein's home during search
warrant
No Contact Orders entered against Jeffrey Epstein
Criminal Score Sheet regarding Jeffrey Epstein
Documents evidencing Jeffrey Epstein's Community Control and Probation
Jeffrey Epstein's Sex Offender Registration
Jeffrey Epstein's Booking photograph
CAD calls to 358 EL BRILLO WAY, PALM BEACH FL 33480
List of Jeffrey Epstein's House contacts
Documents related to Jeffrey Epstein's investments- punies trial only
Letter from Chief Michael Reiter to Barry Krischler
List of planes owned by Jeffrey Epstein
Letter from Guy Fronstin to Assistant State Attorney dated 1-11-06
Letter from Guy Fronstin to Assistant State Attorney dated 1-13-06
Letter from Guy Fronstin to Assistant State Attorney dated 2-17-06
Letter from Guy Fronstin to Assistant State Attorney dated 4-6-06
EFTA01113990
Letter from Guy Fronstin to Assistant State Attorney dated 4-10-06
Letter from Goldberger dated 6-22-06
All subpoenas issued to State Grand Jury
Documents related to the rental of a vehicle for'
Ted's Sheds Documents
Documents related to property searches of Jeffrey Epstein's properties- punies trial only
Arrest Warrant o
Police report regardin picking up money dated 11-28-04
List of Trilateral Commission Members of 2003
Alan Dershowitz Letter dated 4-19-06 and Statute 90.410
Guy Fronstin letter dated 4-17-06
Jeffrey Epstein Account Information- punies trial only
Jeffrey Epstein Criminal Closeout Sheet-
Jeffrey Epstein Polygraph Test and Results
Victim's GED testing information and results
JEGE, Inc. Passenger Manifest
Hyperion Air Passenger Manifest
Flight infonnation fo
Passenger List Palm Beach flights 2005
Jeffrey Epstein notepad notes
Pleadings of 1 and 2 v. US case
Jeffrey Epstein 5th Amendment Speech
Reiter letter to Krisher dated 5-1-06
EFTA01113991
Jail receipts of Jeffrey Epstein
Police Report dated 11-28-04
Compulsory Medial Examination of victim, CMA
Victim's school records and transcripts
Victim Notification letter dated 7-9-08
Victim's employment records from IHOP
Police report of Juan Alessi theft at Jeffrey Epstein's home
Victim's Medical Records from Milton Girls Juvenile Facility
Victim's Medical Records from Dr. Randee Speciale
Victim's Medical Records from Wellington Regional Hospital
Victim's Medical Records from St. Mary's Medical Center
Victim's Medical Records from United Health
All surveillance conducted by law enforcement on Jeffrey Epstein's home
Emails received from Palm Beach Records related to Jeffrey Epstein
All items listed on the Palm Beach Police Property Report Lists
All items taken in the execution of the search warrant of Jeffrey Epstein's home: 358 EL
BRILLO WAY, PALM BEACH FL 33480
All copies of convictions related to Jeffrey Epstein
Jeffrey Epstein criminal records
All documents produced by Palm Beach Police Department prior to the deposition of
Detective Recarey
Photographs of all persons listed on Victims' Witness Lists
Statements, deposition transcripts, videotaped depositions and transcripts taken in
connection with this and all related cases and exhibits thereto
EFTA01113992
Any and all expert witness reports and/or records generated in preparation for this
litigation by any party to this cause
Curriculum vitaes of any and all listed experts
Curriculum vitae of Dr. Ryan Hall
Any articles or publications of Dr. Ryan Hall
Any articles or publications of Dr. Richard Hall
Any articles or publications of Dr. L. Dennison Reed
All items and documentation review by Dr. L. Dennison Reed
Transcript and video (DVD) of IME of Victims
All exhibits to Dr. L. Demlison Reed's Deposition
All exhibits to Dr. Richard Hall's Deposition
All items and documents reviewed by Dr. Richard Hall
All items and documents reviewed by Dr. Ryan Hall
All exhibits listed on the Epstein's Exhibit List
Demonstrative aids and exhibits including, but not limited to, anatomical charts, diagrams
and models, surveys, photographs and similar material including blow-ups of the foresaid
items.- need to see before we agree
Any and all mortality tables
Edwards' reserves all objections to Epstein's Exhibits
Edwards reserves the right to supplement and/or amend his Exhibit List
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.
All exhibits listed by Epstein subject to Edwards' objections.
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.
EFTA01113993
All attachments to Edwards' Motion for Summary Judgment.
All time records and hourly billing documentation produced in discovery.
All deposition testimony and discovery responses by Epstein submitted in this action.
All pleadings filed by Epstein in the Rothstein bankruptcy proceeding.
All submissions by Epstein in connection with the Rothstein deposition.
All Settlement Agreements between Epstein and victims of his sexual molestations.
EFTA01113994
FIFTEENTH JUDICIAL CIRCUIT,
INAND FOR PALM BEACH COUNTY,
FLORIDA
CASE NO.: 502009CA040800XXXXMBAG
JEFFREY EPSTEIN,
Plaintiff/Counter-Defendant, JUDGE: DAVID CROW
VS.
SCOTT ROTHSTEIN,
individually, BRADLEY J.
EDWARDS, individually,
Defendants/Counter-Plaintiff,
EPSTEIN'S OBJECTIONS TO EDWARDS'S REVISED EXHIBIT LIST
Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his
undersigned counsel and pursuant to Paragraph D4 of this Court's Order Setting Jury
Trial and Directing Pretrial and Mediation Procedures, hereby objects to the following of
Defendant/Counter-Plaintiff Bradley Edwards's trial exhibits:
All applicable criminal statutes
All applicable Florida Statutes
All applicable Rules of Evidence
Video of Jeffrey Epstein's home and route from victim to Epstein's home- Irrelevant
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"
Non-Prosecution Agreement
EFTA01113986
102 Complaint
Messages taken from message pads found at Epstein's home-
Documents related to Jeffrey Epstein produced by Alfredo Rodriguez
Jeffrey Epstein flight logs
Jeffrey Epstein phone records
phone records
Jail Visitation Logs
Jeffrey Epstein's probation file
All probable cause affidavits related to criminal investigation of Jeffrey Epstein
All evidence, information and documents taken or possessed by FBI related to criminal
investigation of Jeffrey Epstein
Victims' statements to the FBI related to criminal investigation of Jeffrey Epstein
Video of Search Warrant of Jeffrey Epstein's home being executed
Application for Search Warrant of Jeffrey Epstein's home
Complaint Jane Doe v. Epstein and all subsequent Amended Complaints
All records of homes, properties, bank accounts and any and all records related to Jeffrey
Epstein's assets- ok for punies only?
Jeffrey Epstein's passport (or copy)
Jeffrey Epstein's driver's license (or copy)
List of corporations owned by Jeffrey Epstein ok for punies only?
All documents evidencing relationship between Jeffrey Epstein and Jean Luc Brunel
All documents evidencing relationship between Jeffrey Epstein and MC2 or any
modeling agencies
Yearbooks of Jane Doe
EFTA01113987
2002 Royal Palm Beach High School Year Book
2001 Royal Palm Beach High School Year Book
2003 Palm Beach Gardens High School Year Book
Affidavit and Application for Search Warrant on Jeffrey Epstein's home
Tape recording or transcript of recording of conversation between Jeffrey Epstein and
George Rush
Notepads found in Jeffrey Epstein's home and/or during trash pulls outside of his home
during criminal investigation
The Palm Beach State Attorney's Criminal file against Jeffrey Epstein
All documents related to Jeffrey Epstein's 6/30/08 conviction
Jeffrey Epstein's criminal plea colloquy
Public records from the Department of Corrections related to Jeffrey Epstein
Records from the Florida Department of Law Enforcement related to Jeffrey Epstein
All statements made by Jeffrey Epstein
List of properties and vehicles in Larry Visoski 's name
All of Jeffrey Epstein's Responses to Requests for Production, Requests for Admission,
Answers to Intel rngatories 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
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
Jeffrey Epstein's Answers and Affirmative Defenses in all civil cases against him
All Complaints in which Jeffrey Epstein was a plaintiff or defendant
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
EFTA01113988
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)OOOCMB
Jeffrey Epstein Deposition Testimony and discovery responses in State Court case Jeffrey
Epstein v. Scott Rothstein, et al. Case No. 502009CA040800XXXXMBAG
Any and all newspaper articles, online articles or publications related to Jeffrey Epstein
Report and Analysis of Jeffrey Epstein's assets- punies trial only
Video footage (DVD) of walk through site inspection of Jeffrey Epstein's home.
Photos of all of Jeffrey Epstein's properties, cars, boats and planes punies trial only
Probable Cause Affidavits prepared against Jeffrey Epstein and
Audio tape o
Photographs, videos and books taken in the search waimnt of Jeffrey Epstein's home
Documents related to or evidencing Jeffrey Epstein's donations to law enforcement
Victim Notification Letter from US Attorney's Office to Victim
Expert Dr. L. Dennison Reed's Report of Victim
Palm Beach Police Department Incident Report dated 4/20/06
All reports and documentation generated by Palm Beach Police Department related to
Jeffrey Epstein
All Witness Statements generated by Palm Beach Police Department relating to Jeffrey
Epstein
Passenger Manifests of Jeffrey Epstein's aircraft and private plane flight logs
Passenger lists for flights taken by Jeffrey Epstein
Letter from Jeffrey Epstein to Alberto Pinto regarding house island project
Jeffrey Epstein's bank statements-punies trial only
Jeffrey Epstein's tax returns- punies trial only
EFTA01113989
MC2 emails involving communications of Jeffrey Epstein, Jeff Puller
Pappas Suat, Jean Luc Brunel and Amanda Grant
DVD of plea and colloquy taken on 6-30-08
Transcript of plea and colloquy taken on 6-30-08
Massage Table
Lotions taken from Jeffrey Epstein's home during search warrant
Computers taken from Jeffrey Epstein's home during search warrant
Vibrators, dildos and other sex toys taken from Jeffrey Epstein's home during search
warrant
No Contact Orders entered against Jeffrey Epstein
Criminal Score Sheet regarding Jeffrey Epstein
Documents evidencing Jeffrey Epstein's Community Control and Probation
Jeffrey Epstein's Sex Offender Registration
Jeffrey Epstein's Booking photograph
CAD calls to 358 EL BRILLO WAY, PALM BEACH FL 33480
List of Jeffrey Epstein's House contacts
Documents related to Jeffrey Epstein's investments- punies trial only
Letter from Chief Michael Reiter to Barry Krischler
List of planes owned by Jeffrey Epstein
Letter from Guy Fronstin to Assistant State Attorney dated 1-11-06
Letter from Guy Fronstin to Assistant State Attorney dated 1-13-06
Letter from Guy Fronstin to Assistant State Attorney dated 2-17-06
Letter from Guy Fronstin to Assistant State Attorney dated 4-6-06
EFTA01113990
Letter from Guy Fronstin to Assistant State Attorney dated 4-10-06
Letter from Goldberger dated 6-22-06
All subpoenas issued to State Grand Jury
Documents related to the rental of a vehicle for'
Ted's Sheds Documents
Documents related to property searches of Jeffrey Epstein's properties- punies trial only
Arrest Warrant o
Police report regardin picking up money dated 11-28-04
List of Trilateral Commission Members of 2003
Alan Dershowitz Letter dated 4-19-06 and Statute 90.410
Guy Fronstin letter dated 4-17-06
Jeffrey Epstein Account Information- punies trial only
Jeffrey Epstein Criminal Closeout Sheet-
Jeffrey Epstein Polygraph Test and Results
Victim's GED testing information and results
JEGE, Inc. Passenger Manifest
Hyperion Air Passenger Manifest
Flight infonnation fo
Passenger List Palm Beach flights 2005
Jeffrey Epstein notepad notes
Pleadings of 1 and 2 v. US case
Jeffrey Epstein 5th Amendment Speech
Reiter letter to Krisher dated 5-1-06
EFTA01113991
Jail receipts of Jeffrey Epstein
Police Report dated 11-28-04
Compulsory Medial Examination of victim, CMA
Victim's school records and transcripts
Victim Notification letter dated 7-9-08
Victim's employment records from IHOP
Police report of Juan Alessi theft at Jeffrey Epstein's home
Victim's Medical Records from Milton Girls Juvenile Facility
Victim's Medical Records from Dr. Randee Speciale
Victim's Medical Records from Wellington Regional Hospital
Victim's Medical Records from St. Mary's Medical Center
Victim's Medical Records from United Health
All surveillance conducted by law enforcement on Jeffrey Epstein's home
Emails received from Palm Beach Records related to Jeffrey Epstein
All items listed on the Palm Beach Police Property Report Lists
All items taken in the execution of the search warrant of Jeffrey Epstein's home: 358 EL
BRILLO WAY, PALM BEACH FL 33480
All copies of convictions related to Jeffrey Epstein
Jeffrey Epstein criminal records
All documents produced by Palm Beach Police Department prior to the deposition of
Detective Recarey
Photographs of all persons listed on Victims' Witness Lists
Statements, deposition transcripts, videotaped depositions and transcripts taken in
connection with this and all related cases and exhibits thereto
EFTA01113992
Any and all expert witness reports and/or records generated in preparation for this
litigation by any party to this cause
Curriculum vitaes of any and all listed experts
Curriculum vitae of Dr. Ryan Hall
Any articles or publications of Dr. Ryan Hall
Any articles or publications of Dr. Richard Hall
Any articles or publications of Dr. L. Dennison Reed
All items and documentation review by Dr. L. Dennison Reed
Transcript and video (DVD) of IME of Victims
All exhibits to Dr. L. Demlison Reed's Deposition
All exhibits to Dr. Richard Hall's Deposition
All items and documents reviewed by Dr. Richard Hall
All items and documents reviewed by Dr. Ryan Hall
All exhibits listed on the Epstein's Exhibit List
Demonstrative aids and exhibits including, but not limited to, anatomical charts, diagrams
and models, surveys, photographs and similar material including blow-ups of the foresaid
items.- need to see before we agree
Any and all mortality tables
Edwards' reserves all objections to Epstein's Exhibits
Edwards reserves the right to supplement and/or amend his Exhibit List
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.
All exhibits listed by Epstein subject to Edwards' objections.
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.
EFTA01113993
All attachments to Edwards' Motion for Summary Judgment.
All time records and hourly billing documentation produced in discovery.
All deposition testimony and discovery responses by Epstein submitted in this action.
All pleadings filed by Epstein in the Rothstein bankruptcy proceeding.
All submissions by Epstein in connection with the Rothstein deposition.
All Settlement Agreements between Epstein and victims of his sexual molestations.
EFTA01113994