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#291874/mep¶
O¶
JEFFREY EPSTEIN,¶
e Plaintiff,¶
I¶
vs.¶
O¶
u SCOTT ROTHSTEIN individually, u J. individually, and w L.M., individually,¶
x¶
a¶
co ?.1¶
AMENDED EXHIBIT LIST OF COUNTERDA4FF. L¶
COMES NOW the Counterplaintiff, by and through his undersigned attorneys and hereby lists his ems fdf trial as follows:¶
•¶
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA¶
CASE NO.: 502009CA040800)OOO1MBAG¶
A¶
Defendant,¶
| DEF. PLF. | DATE | A | |
|---|---|---|---|
| OFFERED | MAICIS /r | ||
| D | DESCRIPTION OF EXHIBITS EXHIBITS EXPECTED TO BE USED All applicable criminal statutes | ||
| ( S ." ' | IllV | ||
| 2. | O | All applicable Florida Statutes All applicable Rules of Evidence | |
| 4. | Video of Defendant, Jeffrey Epstein's home and route from Plaintiff to Defendant's home | ||
| 5. | Order confirmation from Amazon.com for purchase of books "SM I for Erotic Slaves and Their Owners" | ||
| 6 | Non-Prosecution Agreement |
Case No.: 502009CA040800XXXXMBAG¶
EXHIBIT LIST OF COUNTERPLAINTIFF,¶
Page 2 of I I¶
| PLF. DATE DEF. | |
|---|---|
| OFFERED MARK | ADMIT |
| TED DESCRIPTION OF EXHIBITS | |
| 7. | Jane Doe 102 Complaint |
| 8. | Messages taken from message pads found Defendant's home |
| 9. | Documents related to Jeffrey Epste" ucal by Alfredo Rodrigues |
| 10 | Jeffrey Epstein flight logs |
| 11. | Jeffrey Epstein phone re ds |
| 12. | rte s |
| 13 | Jail Visi gs |
| 14. | Je e s probation file |
| 15. | I p ble cause affidavits related to criminal investigation of Jeffi |
| E in | |
| 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 |
| li | ellir |
| O | Complaint Jane Doe v. Epstein and all subsequent Amended Comple |
| 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 |
Case No.: 502009CA040800XXXXMBAG¶
EXHIBIT LIST OF COUNTERPLAINTIFF,¶
Page 3 of 11¶
| PLF. DEF. DATE OFFERED NO. NO. 26. 27 | MARK ADMIT TED DESCRIPTION OF EXHIBITS or any modeling agencies Yearbooks of plaintiff, Jane Doe |
|---|---|
| 28 | 2002 Palm Beach High Scholar B ok |
| 29. | 2001 Palm Beach High Book |
| 30. | 2003 Palm Beach Gardent School Year Book |
| 31 | Affidavit and Apr' for Search Warrant on Jeffrey Epstein's ht 7' |
| 32 | Tape recoptlilk\ r tOanscript of recording of conversation between Je Epstein and George Rush |
| 33. | Notepads found in Jeffrey Epstein's home and/or during trash pulls outside oflltis home during criminal investigation |
| 34. | I to Palm Beach State Attorney's Criminal file against Jeffrey Epstei |
| 35. | II documents related to Jeffrey Epstein's 6/30/08 conviction |
| 36. | Jeffrey Epstein's criminal plea colloquy Epstein |
| l | itlir |
| 38. | Records from the Florida Department of Law Enforcement related to Jeffrey Epstein |
| 39. | All statements made by Jeffrey Epstein List of properties and vehicles in Larry Visoski's name |
| *41. | All of Jeffrey Epstein's Responses to Requests for Production, Requ. 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 |
| 42 | All discovery related responses of Jeffrey Epstein in this matter and |
| 43. | Jeffrey Epstein's Answers and Affirmative Defenses in all civil case against him |
[REDACTED] adv. Epstein¶
Case No.: 502009CA040800XXXXMBAG¶
EXHIBIT LIST OF COUNTERPLAINTIFF, [REDACTED]¶
Page 4 of 11¶
| 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, 08-E 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. 502008CA028051XXX AB and E.W. v. Jeffrey Epstein, Case No. 502008CP003626XXXXN | ||||
| 47. | Jeffrey Epstein Deposition Testimony and discovery responses in Sta 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 [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 la enforcement | ||||
| 56. | Victim Notification Letter from US Attorney's Office to Plaintiff | ||||
| 57. | Expert Dr. L. Dennison [REDACTED] 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 |
Case No.: 502009CA040800XXXXMBAG¶
EXHIBIT LIST OF COUNTERPLAINTIFF,¶
Page Sail¶
| DEF. PLF. DATE | |
|---|---|
| OFFERED MARK | ADMIT |
| TED DESCRIPTION OF EXHIBITS | |
| 62. | Passenger lists for flights taken by Jeffrey Epstein |
| 63. | Letter from Jeffrey Epstein to Alberto Pint 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, |
| Maritza Vasquez, Pa Soot, Jean Luc Brunel and Amanda Grant | |
| 66. | DVD of plea an lb y taken on 6-30-08 |
| 67. | Transcript a colloquy taken on 6-30-08 |
| 68. | bl |
| 69 | tion ken from Jeffrey Epstein's home during search warrant |
| 70. | mputers 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 No Contact Orders entered against Jeffrey Epstein Criminal Score Sheet regarding Jeffrey Epstein Illit. |
| 74. O | 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 |
Case No.: 502009CA040800XXXXMBAG¶
EXHIBIT LIST OF COUNTERPLAINTIFF,¶
Page 6 of II¶
| DATE DEF. PLF. | |
|---|---|
| OFFERED MARK | ADMIT |
| TED DESCRIPTION OF EXHIBITS | |
| 80. | Letter from Chief Michael Reiter to Barry ICrischler |
| 81. | List of planes owned by Jeffrey Epstein |
| 82. | Letter from Guy Fronstin to Assist to A omey dated 1-11-06 |
| 83. | Letter from Guy Fronstin to A ate Attorney dated 1-13-06 |
| 84 | Letter from Guy Fronstin As 'stant State Attorney dated 2-17-06 -all. |
| 85. | Letter from Gu nsti to Assistant State Attorney dated 4-6-06 .i..- |
| Letter fro G Fr stin to Assistant State Attorney dated 4-10-06 t | |
| 87. | LettfirciHiG dberger dated 6-22-06 |
| / 14/ | |
| 88 | 4 r'irpenas issued to State Grand Jury |
| 89. | cuments related to the rental of a vehicle for |
| 90. | Ted's Sheds Documents |
| ICZ | Ilfr |
| 92. | Arrest Warrant of |
| 93. c-SIS- | Police report regarding picking up money dated 11-2 List of Trilateral Commission Members of 2003 |
| 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 |
Case No.: 502009CA040800XXXXMBAG¶
EXHIBIT LIST OF COUNTERPLAINTIFF,¶
Page 7 of II¶
| 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 [REDACTED] Burns | ||||
| 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 th 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. | Plaintiff's school records and transcripts | ||||
| 113. | Victim Notification letter dated 7-9-08 | ||||
| 114. | Plaintiff's 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 |
Case No.: 502009CA040800XXXXMBAG¶
EXHIBIT LIST OF COUNTERPLAINTIFF,¶
Page 8 of 11¶
| DEF. DATE PLF. | |
|---|---|
| OFFERED MARK | ADMIT |
| TED DESCRIPTION OF EXHIBITS | |
| 120 | Plaintiff's Medical Records from United Health |
| 121. | All surveillance conducted by law enforce ent on Jeffrey Epstein's I |
| 122. | Emails received from Palm Beach re led to Jeffrey Epstein |
| 123. | All items listed on the Palm B li Property Report Lists |
| 124. | All items taken in the exetinicmpf the search warrant of Jeffrey Epst |
| home: 358 EL BRILjaia kei.!PALM BEACH FL 33480 | |
| All copies of con ctio related to Jeffrey Epstein | |
| 126. | Jeffrey Ep e n "nal records |
| 127. | Allpi n roduced by Palm Beach Police Department prior to t |
| depNiti tof Detective Recarey | |
| 128. | otogtaphs of all persons listed on Plaintiff's Witness List |
| 129. | tements, deposition transcripts, videotaped depositions and transc for this litigation by any party to this cause Curriculum vitaes of any and all listed experts |
| O S ) | |
| II | IIIIV |
| 132. | Curriculum vitae of Dr. Ryan |
| 133. | My articles or publications of Dr. Ryan |
| A- S | |
| ‘b -I | Any articles or publications of Dr. Richard |
| 135. | Any articles or publications of Dr. L. Dennison |
| 136. | All items and documentation review by Dr. L. Dennison |
| 137 | Transcript and video (DVD) of IME of Plaintiff |
| 138 | All exhibits to Dr. L. Dennison Deposition |
| 139. | All exhibits to Dr. Richard Deposition |
Case No.: 502009CA040800/OOOCMBAG¶
EXHIBIT LIST OF COUNTERPLAINTIFF,¶
Page 9 of 11¶
| DEF. PLF. DATE | ||
|---|---|---|
| OFFERED | MARK ADMIT TED | DESCRIPTION OF EXHIBITS |
| 140. | All items and documents reviewed by Dr. Richard | |
| I 41. | All items and documents reviewed by Dr. | an |
| 142 | All exhibits listed on the Defendan | ibit ist |
| 143. | Demonstrative aids and exhili | g, but not limited to, anatorr |
| charts, diagrams and mod | , , photographs and similar mater | |
| including blow-ups of | o id items. | |
| 144. | Any and all mortali | tabl |
| 145. | Plaintiffs rese | al lt- tions to Defendant's Exhibits |
| 146. | Plainti | e right to supplement and/or amend this Exhibit I |
| I 47. | B Exhibit, Plaintiff is not waiving their right to object to s | oes not waive their right to amend same. |
| 148. | A ibits listed by Epstein subject to | objections. RII pleadings and attachments in the action under the Crime Victims |
| Rights Act prosecuted by Bradley | on behalf of victims of Epstein's criminal molestations. | |
| 150. | All attachments to C Ibis action. | Motion for Summary Judgment. All time records and hourly billing documentation produced in disco All deposition testimony and discovery responses by Epstein submit |
| A S | I?* | |
| 153. ‘,..) | All pleadings filed by Epstein in the Rothstein bankruptcy proceedin | All submissions by Epstein in connection with the Rothstein deposit |
| 155. | All Settlement Agreements between Epstein and victims of his sexur molestations. |
Plaintiff reserves the right to amend this list.¶
[REDACTED] adv. Epstein¶
Case No.: 502009CA040800XXXXMBAG¶
EXHIBIT LIST OF COUNTERPLAINTIFF, [REDACTED] [REDACTED]¶
Page 10 of 11¶
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, this 25th day of June, 2013.¶
jsx@searcylaw.com; mep@searcylaw.com¶
Florida Bar No.: 169440¶
Searcy Denney Scarola Barnhart & Shipley, P.A.¶
2139 Palm Beach Lakes Boulevard¶
West Palm Beach, Florida 33409¶
Phone: (561) 686-6300¶
Fax: (561) 383-9451¶
Attorneys for Bradley J. Edwards¶
NOTA CERTIFIED LOGO¶
[REDACTED] adv. Epstein¶
Case No.: 502009CA040800XXXXMBAG¶
EXHIBIT LIST OF COUNTERPLAINTIFF, [REDACTED] [REDACTED]¶
Page 11 of 11¶
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¶
[REDACTED] J. [REDACTED], Esquire
staff.efile@pathtojustice.com
[REDACTED], Jaffe, Weissing, [REDACTED], Fistos &
Lehrman, FL
425 North Andrews Avenue, Suite 2
Fort Lauderdale, FL 33301
Phone: (954) 524-2820
Fax: (954) 524-2822¶
Fred Haddad, Esquire
Dee@FredHaddadLaw.com;
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
marc@nuriklaw.com
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¶