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Draft: efta02772259

•

#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.DATEA
OFFEREDMAICIS /r
DDESCRIPTION OF EXHIBITS EXHIBITS EXPECTED TO BE USED All applicable criminal statutes
( S ." 'IllV
2.OAll 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"
6Non-Prosecution Agreement

Case No.: 502009CA040800XXXXMBAG

EXHIBIT LIST OF COUNTERPLAINTIFF,

Page 2 of I I

PLF. DATE DEF.
OFFERED MARKADMIT
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
10Jeffrey Epstein flight logs
11.Jeffrey Epstein phone re ds
12.rte s
13Jail 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
liellir
OComplaint 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)
23Jeffrey Epstein's driver's license (or copy)
24List of corporations owned by Jeffrey Epstein
25All 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. 27MARK ADMIT TED DESCRIPTION OF EXHIBITS or any modeling agencies Yearbooks of plaintiff, Jane Doe
282002 Palm Beach High Scholar B ok
29.2001 Palm Beach High Book
30.2003 Palm Beach Gardent School Year Book
31Affidavit and Apr' for Search Warrant on Jeffrey Epstein's ht 7'
32Tape 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
litlir
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
42All 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 OFFEREDMARKADMIT TEDDESCRIPTION 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 MARKADMIT
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
69tion 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. ODocuments 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
78List 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 MARKADMIT
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
84Letter 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/
884 r'irpenas issued to State Grand Jury
89.cuments related to the rental of a vehicle for
90.Ted's Sheds Documents
ICZIlfr
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 OFFEREDMARKADMIT TEDDESCRIPTION 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 MARKADMIT
TED DESCRIPTION OF EXHIBITS
120Plaintiff'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 )
IIIIIIV
132.Curriculum vitae of Dr. Ryan
133.My articles or publications of Dr. Ryan
A- S
‘b -IAny 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
137Transcript and video (DVD) of IME of Plaintiff
138All 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
OFFEREDMARK ADMIT TEDDESCRIPTION OF EXHIBITS
140.All items and documents reviewed by Dr. Richard
I 41.All items and documents reviewed by Dr.an
142All exhibits listed on the Defendanibit ist
143.Demonstrative aids and exhilig, but not limited to, anatorr
charts, diagrams and mod, , photographs and similar mater
including blow-ups ofo id items.
144.Any and all mortalitabl
145.Plaintiffs reseal lt- tions to Defendant's Exhibits
146.Plaintie right to supplement and/or amend this Exhibit I
I 47.B Exhibit, Plaintiff is not waiving their right to object to soes not waive their right to amend same.
148.A ibits listed by Epstein subject toobjections. RII pleadings and attachments in the action under the Crime Victims
Rights Act prosecuted by Bradleyon 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 SI?*
153. ‘,..)All pleadings filed by Epstein in the Rothstein bankruptcy proceedinAll 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

Draft: efta02772259

Other records

Prepared source

• 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 | | | --------- | -------- | --------- | --------------------------------------------------------------------------------------------…