Draft: efta02760035

#291874/mep¶

JEFFREY EPSTEIN,¶

Plaintiff,¶

VS.¶

SCOTT ROTHSTEIN, individually, J. S individually, and L.M.,¶

Defendant,¶

IN THE CIRCUIT COURT OF THE bENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA¶

CASE NO.: 502009CA040800XXXXMBAG¶

CO ASA¶

REVISED c EXHIBIT LIST OF COUNTERPLA4s¶

COMES NOW the Counterplaintiff, BRAD I ARDS, by and through his undersigned attorneys and hereby lists his exhibits for trial aA fo ss:\ ,¶

DEF. PLF. DATE NO. NO. OFFERED	wc.)1,..yr4 DESCRIPTION OF EXHIBITS EXHIBITS EXPECTED TO BE USED
t	ar
I. ft	All applicable criminal statutes
2.	All applicable Florida Statutes 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

adv. Epstein¶

HIBIT LIST OF COUNTERPLAINTIFF,¶

lifilirkge 2 of 13¶

DEF. PLF. DATE
OFFERED	MARK ADMIT
	TED DESCRIPTION OF EXHIBITS Abernathy:
	A Workbook for Erotic Slaves and Their ers"
6.	Non-Prosecution Agreement
7.	Jane Doe 102 Complaint
8.	Messages taken from m g and at Epstein's home
9	Documents relate effr pstein produced by Alfredo Rodriguez
10.	Jeffrey Epst ' i s
I I.	le in one records
12	's phone records
13.	ThikVisitation Logs
14.	Jeffrey Epstein's probation file Jeffrey Epstein C'S)
16. t	r. by FBI related to criminal investigation of Jeffrey Fp.. Jeffrey Epstein
IS	Video of Search Warrant of Jeffrey Epstein's home being executed
19.	Application for Search Warrant of Jeffrey Epstein's home
10	Complaint Jane Doe v. Epstein and all subsequent Amended Complaints
/ I	All records of homes, properties, bank accounts and any and all records related to Jeffrey Epstein's assets
-i-i.	Jeffrey Epstein's passport (or copy)

Case No.: 502009CA040800XXXXMBAG¶

XHIBIT LIST OF COUNTERPLAINTIFF,¶

Page 3 of 13¶

DEF. NO.	PLF. NO.	DATE OFFERED	MARK	ADMITTED	DESCRIPTION OF EXHIBITS
	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 Jane Doe
	28				2002 [REDACTED] 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 [REDACTED] 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,

adv. Epstein Case No.: 502009CA040800XICOMMAG XHIBIT LIST OF COUNTERPLAINTIFF, Page 4 of 13¶

DEF. NO.	PLF. NO.	DATE OFFERED	MARK	ADMIT TED	DESCRIPTION OF EXHIBITS
					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 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. 502008CA028051XXXXIMB 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 502009CA040800XXXXMBAG
	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.
	51.				Photos of all of Jeffrey Epstein's properties, cars, boats and planes
	52				Probable Cause Affidavits prepared against Jeffrey Epstein and [REDACTED]
	53.				Audio tape of [REDACTED]
	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

adv. Epstein Case No.: 502009CA040800XXXXMBAG XHIBIT LIST OF COUNTERPLAINTIFF, Page 5 of 13¶

DEF. PLF. DATE
OFFERED	MARK ADMIT
	TED	DESCRIPTION OF EXHIBITS
56.		Victim Notification Letter from US Attorney's Office to Victim
57		Expert Dr. L. Dennison Report o ictim
58		Palm Beach Police Department I t Re rt dated 4/20/06
59.		All reports and documentati gc d by Palm Beach
		Police Department relat 'to effr Epstein
60.		All Witness Statements enerated by Palm Beach
		Police Departmen lating tolJeffrey Epstein
61		Passenger ts Jeffrey Epstein's aircraft and private plane flight
62		Passeng ights taken by Jeffrey Epstein
63.		m ffrey Epstein to Alberto Pinto regarding d project
64.	,fr	ell_ Epstein's bank statements effrey Epstein's tax returns and Amanda Grant
	Ca )	DVD of plea and colloquy taken on 6-30-08 Transcript of plea and colloquy taken on 6-30-08
	Ii iiiiir
67. ec	.,	Massage Table
68. O		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

Case No.: 502009CA0408003OOOaNBAG¶

XHIBIT LIST OF COIJNTERPLAINTIFF,¶

Page 6 of 13¶

DEF. PLF. DATE
OFFERED MARK	ADMIT
TED	DESCRIPTION OF EXHIBITS
74.	Documents evidencing Jeffrey Epstein's Community Control and Probation
75.	Jeffrey Epstein's Sex Offender Rc tion
76.	Jeffrey Epstein's Booking ph
	14/ ,
77.	CAD calls to 358 EL BILL Y, PALM BEACH FL 33480
78	List ofJeffrey E ' 's House contacts
79	Documentsrel effrey Epstein's investments
80	Lett f Michael Reiter to Barry Krischler
81	is es owned by Jeffrey Epstein
82	to from Guy Fronstin to Assistant tate 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 Letter from Guy Fronstin to Assistant State Attorney dated 4-10-06
87	Letter from Goldberger dated 6-22-06 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

Case No.: 502009CA040800X3C3C3CMBAG¶

HIBIT LIST OF COUNTERPLAINTIFF,¶

Page 7 of 13¶

DEF. NO.	PLF. NO.	DATE OFFERED	MARK	ADMIT TED	DESCRIPTION OF EXHIBITS
	93.				Police report regarding [REDACTED] 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
	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 [REDACTED]
	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.				[REDACTED] Police Report dated 11-28-04
	111.				Compulsory Medial Examination of victim, CMA
	112.				Victim's school records and transcripts

adv. Epstein Case No.: 502009CA040800X)OOCMBAG P HIBIT LIST OF COUNTERPLAINTIFF, age 8 of 13¶

DEF. NO.	PLF. NO.	DATE OFFERED	MARK	ADMIT TED	DESCRIPTION OF EXHIBITS
	113.				Victim Notification letter dated 7-9-08
	114.				Victim's employment records from IHOP
	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
	131.				Curriculum vitaes of any and all listed experts

DEF. PLF.	DATE
	OFFERED MARK ADMIT TED	DESCRIPTION OF EXHIBITS
132.		Curriculum vitae of Dr. Ryan
133.		Any articles or publications of Dr. Ryan all
134.		Any articles or publications of Dr and all
		Any articles or publications 'son
136.		All items and documen ion view by Dr. L. Dennison
137.		Transcript and VD) of1ME of Victims
138.		All exhi r L. Dennison Deposition
139.		Al its Dr. Richard Deposition
140.		II s and documents reviewed by Dr. Richard
141.		11 items and documents reviewed by Dr. Ryan
142.	ICZIIIIIV	All exhibits listed on the Epstein's Exhibit List
	c-	reserves all objections to Epstein's Exhibits reserves the right to supplement and/or amend his Exhibit List
147.		By listing an Exhibit, is not waiving his right to amend same.
148		All exhibits listed by Epstein subject to objections.
149.		All pleadings and attachments in the action under the Crime Victims Rights Act prosecuted by

Case No.: 502009CA040800XXXXIABAG¶

P HIB1T LIST OF COUNTERPLAINTIFF,¶

age 10 of 13¶

DEF. NO.	PLF. NO.	DATE OFFERED	MARK	ADMIT TED	DESCRIPTION OF EXHIBITS
	150.				All attachments to [REDACTED] Motion for Summary Judgment.
	151.				All 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 Roth [REDACTED] bankruptcy proceeding.
	154.				All submissions by Epstein in connection with the Rothstein deposition.
	155.				All Settlement Agreements between Epstein and victims of his sexual molestations.
	156.				Phone Journal taken from Epstein's home and produced to the FBI h Alfredo Rodriguez
	157.				Photo depicting [REDACTED], Ghislaine Maxwell and Prince Andrew
	158.				All flight logs for any Epstein owned or controlled aircraft
	159.				Epstein emails or correspondence with anyone related in any way to case or related cases
	160.				Evidence of contributions to the Palm Beach Police Dept.

Plaintiff reserves th to amend this list.¶

ric iS¶

[REDACTED] adv. Epstein¶

Case No.: 502009CA040800XXXXXMBAG¶

REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, [REDACTED] [REDACTED]¶

Page 11 of 13¶

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by¶

attached list,¶

Service to all counsel on the
this _____¶

date of _____ 11 Nov 2016.¶

Jack Scaarol¶

jsx (pear aw.com; mep@searcylaw.com ¶

Florida ar No.: 169440¶

S arc Denney Scarola Barnhart & Shipley, P.A.¶

Palm Beach Lakes Boulevard¶

est Palm Beach, Florida 33409¶

Phone: (561) 686-6300¶

Fax: (561) 383-9451¶

Attorneys for Bradley J. [REDACTED]¶

NOTA CERTIFICATION¶

Case No.: 502009CA040800X300CMBAG¶

REVISED EXHIBIT LIST OF COUNTERPLAINTIFF,¶

Page 12 of 13¶

COUNSEL LIST¶

Jack A. Goldberger, Esquire¶

igoldberizerO,agwva.com;smahonevOagwva.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¶

J. . Esquire¶

n Jaffe, Weissing, Fistos & Lelmnan, 4 \ 4¶

ce.com¶

425 North Andrews Avenue, Suite 2¶

Fort Lauderdale, FL 33301¶

Phone: (954) 524-2820¶

Fax: (954) 524-2822¶

William Chester IM, Esquire¶

wcblawla,aol.com; w law¶

250 S Australian Avenue, Sui¶

West Palm Beach, FL 33401¶

Phone: (561) 655-4777¶

Fax: (561) 835-8691¶

Attorneys for Je ps¶

Marc S. Nuri¶

m¶

Law Office rc S. Nurik¶

One E Blvd., Suite 700¶

Fort Laude I; FL 33301¶

Phone: (954)-745-5849¶

Fax: (954)-745-3556¶

Attorneys for Scott Rothstein¶

A Cos¶

[REDACTED] adv. Epstein¶

Case No.: 502009CA040800XXXXXMBAG¶

REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, [REDACTED] [REDACTED]¶

Page 13 of 13¶

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¶

NOTA CERTIFIED COPY¶

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REVISED c EXHIBIT LIST OF COUNTERPLA4s¶

HIBIT LIST OF COUNTERPLAINTIFF,¶

XHIBIT LIST OF COUNTERPLAINTIFF,¶

XHIBIT LIST OF COIJNTERPLAINTIFF,¶

P HIB1T LIST OF COUNTERPLAINTIFF,¶

COUNSEL LIST¶