Draft: efta02765538

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

Case No. 50-2009CA040800XXJ0CMI3AG¶

JEFFREY EPSTEIN,¶

PlaintiffiCounter-Defendant,¶

v.¶

SCOTT ROTHSTEIN individually, and J. individually,¶

Defendants/Counter-Plaintiff.¶

A¶

Cos¶

PLAINTIFF/COUNTER-DEFENDANT JEFF FIN'S RESPONSE TO MOTION TO STRIKE EPSTEINtT ELY SUPPLEMENTAL EXHIBITS AND TO STRIKE ALL EXHIBITS A ANY REFERENCE TO DOCUMENTS CONTAINING PRIVILEGED MATERIALS LISTED ON OEM PRIVILEGE¶

Plaintiff/Counter-Defendant Jeffre ("Epstein") responds to Defendant/Counter-Plaintiff J. Motio pstein's Untimely Supplemental Exhibits and to Strike All Exhibits and Any R Documents Containing Privileged Materials Listed on Privilege Log.¶

ISSUES TO BE DECIDED BY THE COURT¶

AeThe ' ues for the Court to decide include: (1) are the exhibits identified by Epstein relevant- re the documents, when created, protected by the work product discovery doctrine; and (3) e work-product protection been waived based on (a) production to Razorback, (b) issue injection, (c) crime fraud exception, (d) fraud on the court, and (e) delivery by the Special based on instructions from Mr. Scarola to provide to whatever documents the Special deems producible.¶

IN I ROMIG I !ON¶

has asserted the disc was stolen. Epstein's cu rent counsel has disclosed in detail how it received the disc. See Affidavit of Tina L. has also wrongfully called into questions the ethics of Mr. Link and Ms. Rockenbach. See Affidavit of Timothy P. Chinaris. The disc was not stolen from anyone!¶

The disc of 27,000+ pages of e-mails came from Epstein's former counse e It is unknown if the disc of e-mails that is the subject of Motion by directly, IMF counsel, the Bankruptcy Trt a Special assertion that the "27,500-page disc" was never pm t) ' to firm and Rockenbach is facially flawed and lacking even a evidence to justify it and is itself that somehow it has been unethically and inappropri ,frgre t) ned by Mr. Link and Ms. unprofessional and unethical to accuse couns g the disc. Furthermore, the chronology i i ISic provided to the Court to suppo s b> less assertion is incomplete. For instance, at a March 15, 2011, hearing before t 'Master, counsel stated, "The situation we have here is one where we hav turn over the documents themselves for in-camera inspection. They're available to you. look at them. We have told you to turn over anything and emything that y kink relevant, material, not privileged by attorney-client privilege, not work-produe it to them." (3/15/11 Hearing Transcript, p. 43) (Excerpt, Exhibit A). Possi to he disc that is the subject of Motion came from the Special . At this point in time, it is simply unknown and, frankly, not germane to the real issues to be decided by the Court. has studiously avoided any meaningful substantive discussion as to those issues which are central to Motion.¶

We do know that in July 2011, counsel told the Court that had "nothing to hide" in the alleged privileged documents and was just concerned about waiving the attorneyclient privilege:¶

...as much as we might like to take all of this and put it on the floor in the courtroom for Your Honor and everybody else in the world to take a look at because we have nothing to hide we can't do that.

¶

See 7/13/11 hearing transcript, p. 58 (Excerpt, Exhibit B). Based on ence that asks this Court to exclude, it is clear that does have so hide. He is asking the Court to strike that evidence because it proves his claim f tCma s prosecution has no merit.¶

A. Privilege Log Confusion¶

Motion is based largely on un b accusations of wrongdoing and unethical behavior by Mr. Link and says the disc was stolen) and a February 23, 2011, privilege log. Ed re es to address the relevance of the evidence. Understandably, he cannot becaus ce is the death of his claim. From a review of the Court's records, the February 2 1 p ege log appears to be null and void. For instance, on May 7, 2012, the Court found February 23, 2011, privilege log was insufficient on its face and ordered ards o provide "a more complete privilege log" within 30 days. (Exhibit C.) On Au 0 2, the Court vacated that Order without prejudice, and ordered to produ privilege log as referenced in this Court's May 7, 2012 Order." (Exhibit D.) Epstein's counsel has not found a subsequent privilege log.¶

Furthermore, the description of documents on the February 23, 2011, privilege log is seriously misleading and inadequately describes the participants or contents to be able to determine whether the documents were subject to privilege or if portions should have been produced in¶

redacted form. In addition, has identified Bate stamp ranges, and multiple documents are contained within those ranges that have not been listed individually.¶

The following are illustrative examples:¶

• 4408-4412 is an 10/17/09 e-mail exchange between and Cassell where, asks Cassell if there was any way he could "bait [Epstein] into suing me".

	DATE	TO	FROM	DESCRIPTION	PlfliThi$GE
04403-					W/Atorn y Client
					nd t reasonably,"

• 4399-4400 is an 10/17/09 e-m ~ discussing how much better a irs had settled for $155,000. [The date on the privilege log is not ev huge between and Cassell or this document.]

	DATE	TO	FROM	DESCRIPTION	PRIVILEGE
4387- 4402	8/19/09	Paul Cassell	Bradley Edwards	Victim Complaints, Forensic accounts, & Epstein's Fraudulent Transfers	W/P; Attorney Client Privilege; irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights

1,S iple e-mails dated 10/23/09 about direct participation with Rothstein, ,..; ,.. .. and others to avoid the structured settlement statute for an Epstein case (the following is just a sampling from the privilege log)¶

	DATE	TO	FROM	DESCRIPTION	PRIVILEGE
08033-08070	10/23/09	Attorneys at RRA	Mike Fistos	Legal Research RE: Causes of action against Epstein	W/P; Attorney Client Privilege; irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights
25997	10/23/09	Scott Rothstein	Adler	Legal Research RE: causes of action against Epstein	W/P; Attorney Client Privilege; irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights
26741-26763	10/23/09	Attorneys at RRA	Adler	Legal Research RE: causes of action against Epstein	W/P; Attorney Client Privilege; irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights

14. Rex ims of Documents¶

A duplicate of the disc has been provided to counsel. Epstein's current counsel has not reviewed of the \LP7,000 pages on the disc. However, from the 110 items listed on the Appendix th m the disc, 44 (less than half) are listed on the February 23, 2011, privilege log, 14 ed as exhibits at May 2013 deposition, and 52 others were neither used as exhibits or identified on the privilege log.¶

Epstein's team has reviewed approximately 4,000 — 5,000 of the 27,000 e-mails. Many of the e-mails have no relevance to the issues of this case and were not printed (for instance, e-mails relating to musical and sporting events and other non-business-related communications).¶

counsel's contention, therefore, that only privileged information is contained on the disc that he alleges Epstein's current counsel somehow wrongfully obtained is untrue.¶

In reviewing as carefully as possible from a forensic look-back standpoint, there are significant gaps in the correspondence, documents and records to fully understand how various document issues were resolved. The following are examples of what may have occu Aed:¶

• All 27,000 pages on the disc have been produced to both Epstein an Razorback. (See April 8, 2011, and June 7, 2011, letters which a to indicate that Razorback's counsel received 27,000+ pages ofd in the Epstein matter). (Exhibits E and F.)
• The 1,600 identified and withheld by from appear to have already been produced to Razorback claim of work product protection. in mails immating any
• The 27,000+ pages ma have been revie aced to by the Special as requeste y carola.
• may have maintained teYdisc containing the 1,600 privileged, never-before produ ail and has a copy of that disc. We found no copy ch a isc in the files we obtained from =, and none ect e-mails Epstein seeks to use as evidence came from

Adding to the confusio the isc shows that the 27,000 documents were burned to it in December 2010. Unfortu it seems that no one can say with certainty who delivered the disc to at is known now is that these documents were produced to Epstein by e or the Special without a signed Confidentiality Agreement. The pro p is for the Court to review all of the alleged work product "privileged" documents to determine the relevancy and whether any work-product protection still exists. Importantly, none of the appendix documents were communications to or from clients (L.M., E.W. or Jane Doe). All of the documents are internal RRA communications or communications with the media. 'The trial of this case should be about uncovering the truth related to claim against Epstein, which contends is directly related to the truth of Epstein's claims against not about hidingrelevant evidence) All of the lawyers in this case have ethical obligations to our profession to bring the truth to light.¶

C. Factual Inconsistencies¶

From a review of the documents, it is unclear how many documents were reviewed by and produced and when this occurred. There are conflicting statements in the record and those made by counsel. Epstein addresses some of the factual in ncies and confusion created by law firm: regarding the production by of ments to the¶

Date	Event	No. of Documents
9/20/10	[REDACTED] Motion provides that 27,590 pages were provided to the Special [REDACTED]	27,590
11/2/10	[REDACTED] informed the Bankruptcy Court that the RRA Trustee had produced <b>74,000</b> pages of documents on two compact discs ( <i>this event was not included in [REDACTED] chronology to the Court</i> )	74,000
11/30/10	Edwards' Motion for Stay of Subpoena in this action provides that Edwards had to review more than <b>70,000</b> pages of materials to identify responsiveness and to assert an appropriate privilege ( <i>this event was not included in [REDACTED] chronology to the Court</i> )	70,000
12/16/10	LM advised the Bankruptcy Court that there would be approximately 24,000 pages produced	24,000
1/25/11	[REDACTED] Motion provides that 8,408 pages were produced to Epstein	8,408
2/23/11	[REDACTED] Motion provides that 12,711 pages were produced to Epstein	12,711 (bringing the total produced to 21,119)

Date	Event	No. of Documents
5/7/12	Motion provides that	163 (bringing the
	E nic
10/10/13	MI testified that he had

*All of the 163 pages (representing 89 documents) produced by Edwardg 7, 2012, are found on the disc that claims was stolen and are identified an Edwards' February 23, 2011, privilege log. That means, 89 documents listed on the lege log that claims has never been produced to Epstein were used in this ji ggt shout objection. Those 89 documents which are on the disc and contained o 54kt p igi1L<ge log were identified individually as exhibits on Epstein's Exhibit List since No c S p., , 2017. (See Epstein's Trial Exhibit Nos. 88-216) (Exhibit M.) That brings the t f 10 documents on the disc are already in the Court Kg)¶

D. Documents Were Tu er to Razorback's Counsel¶

It is clear that Ed cou v nsel turned over 27,000+ pages to Razorback's counsel. What is unclear is if th ere the same documents that Epstein's current counsel recently found on the disc in Fo files which also contains 27,000+ pages. That is another unknown. How documents that now claims were not to be produced to anyone were produced to Razorback, then any claim of privilege has been waived.¶

By way of background, on April 8, 2011, Razorback's counsel confirmed:¶

Accordingly, this letter is intended to confirm the terms and conditions of the production by your client, to us of all documents, without redaction, and notwithstanding any claim of privilege made or that could be made, that the Bankruptcy Trustee Herbert Stettin caused to be turned over or delivered to the Special¶

pursuant to the special rocess described above and any further documents that has in his possession, custody or control responsive to our subpoena (collectively, the "Epstein Related Documents"). ...¶

(Exhibit K)¶

Furthermore, on June 7, 2011, Razorback's counsel wrote to =, Jaffee:¶

I am troubled by our discussion yesterday afternoon with respect to the copying of the documents identified for copying within th fourteen boxes of documents related to the Epstein cases, as we the dispute concerning the production of the 27,000 plus or pages of e-mails which were to be transferred on to th ti drive provided by my office.¶

(Exhibit F.)¶

K. l'iminu of Id en tifvine Exhibits¶

has asked the Court to strike highly is tQ, C uments Epstein has identified and disclosed as trial exhibits because they are de • S his case and question his credibility, not because they will cause any undue pre use of their alleged late disclosure. testified in 2013 that he reviewed re e e-mail that Epstein has listed on his Exhibit List. Moreover, was a d' 'pant in all but a small few of the e-mails now seeks to exclude. This cannot in good faith claim surprise. Motion should be denied use E stein has good cause for the timing of the new exhibits and the parties agreed in the r rial Stipulation that they can amend their Exhibit Lists after the filing of the Stipul¶

Ce )¶

EPSTEIN'S EXHIBITS¶

Epstein is not seeking a trial by ambush. Rather, Epstein has produced documents as his current counsel has located them. The documents are relevant in this case and Epstein has good cause for the timing of their production. Epstein is the one who will be prejudiced if he is not allowed to introduce and use the exhibits at trial. Epstein summarizes the exhibits below:¶

A. Rothstein, Rosenfeldt and Adler E-mails¶

Epstein identified and disclosed a number of emails from the Rothstein, Rosenfeldt and Alder firm that directly contradict sworn testimony and statements in this case. Specifically, has testified under oath that he had no involvement with Rothstein related to the Epstein cases and that he has suffered anxiety every single day since December 7, 2009, wen Epstein filed his Complaint against him. M, however, was not being truthful. ocuments Epstein's counsel recently discovered show, among other things, 1) Edwa ii r participation with Rothstein and others to avoid the structured settlement sta o Epstein case; 2) admission that he was baiting Epstein to sue him na so that he could force Epstein to waive his constitutionally protected Fifth Ame 9 )nt t; and 3) admission S, that L.M., E.W. and Jane Doe were prostitutes an ' ' a and that their cases were "weak." c i¶

i t has testified that Rothstein v s, e involvement in the Epstein cases:¶

Where you everA e tcys nt a meeting where Mr. Rothstein was also prese e Epstein cases were discussed? Q.¶

A. No.¶

3/23/10 Depo., 112:3 xceipt, Exhibit G.) In addition, when asked how involved Rothstein was in the 11/10/17 Dep (Excerpt, Exhibit H.) In fact, the e-mails recently discovered and disclosed a ibits conclusively demonstrate significant involvement by Rothstein. claimed that he "hardly talked to the guy."¶

piing of the illustrative documents has already been provided to the Court in Epstein's Appendix in support of his Response in Opposition to Motion in Limine seeking to limit the evidence in this case. and his counsel should not be allowed to hide these documents from the jury.¶

B. Exhibits Relating to L.M., E.W., and Jane Doe¶

During the November 29, December 5 and December 7, 2017, hearings, the Court advised the parties that Epstein would need, in essence, to prove each allegation of his original Complaint, including the statement that three clients' claims were "weak." The Court also indicated it would allow to discuss his three clients' claims against Epstein. In additi n, at those hearings, advised his three clients would testify at trial, along with another alleged victim of Epstein.¶

Because of these rulings, Epstein's counsel shifted their foe cause to finding additional evidence to support that c • ' s were weak. Epstein had sufficient information demonstrating the weakness o a clients' claims at the time of the filing of the original proceeding. In light of the rdfings that L.M., E.W. and Jane Doe could take the witness stand in this malic' s /Scs ea ution action, Epstein's counsel began conducting extensive background rese on ch of clients and reviewing the documents from the underlying ' reparation for cross-examining them as to their credibility. This was a large u ert • g because Epstein's three clients have very long criminal histories relating to inc. I throughout the state. In fact, some of the law enforcement agencies have y p d to public records requests. Nevertheless, on February 2, 2018, Epstein's co need what had been gathered to that date. Supplemental public records were p~o counsel on February 16 and March 2, 2018. °fending probable¶

The documents are directly relevant to witnesses' credibility, trustworthiness, and background. L.M. and E.W. have both been arrested for prostitution. L.M. admitted to law enforcement that she was involved in prostitution because her mother was a prostitute. All three clients have been arrested for shoplifting, have drug problems, and all have admitted to lying.¶

attack his reputation and character: disbarment.¶

In fact, L.M. admitted to committing perjury to the United States Government even after she was provided with immunity.¶

C. Alan Dershowitz¶

Epstein has identified exhibits relating to a defamation lawsuit filed in January 2015 against Alan Dershowitz (one of Epstein's attorneys).' In that action, alleged:¶

Despite having previously been the victim of character assassination by the Defendant ALAN M. DERSHOWITZ'S associate and client, Jeffrey Epstein, J. en s a h' favorable national reputation particularly related to his defending the rights of child victims of sexual abuse.

¶

(Dershowitz, Complaint, I 8, emphasis added.)¶

alleged that Dershowitz made a media Ete.ct )Q him (and Paul G. Cassell) to¶

DERSHOWITZ initiated a blic media assault on the reputation and character of L J. and PAUL G. CASSEL accusing th of in tionally lying in their filing, of having leveled lmovvi y false...accusations against the Defendant DERSHOWITZ, wi out ever conducting any investigation of the creditability of t ons, and of having acted unethically to the extent that eir Iful misconduct warranted and required¶

(Dershowitz, Comp t, ¶ lit 7.) h¶

In Ap 0l wards, Cassell and Dershowitz resolved their respective claims and I informed the Court that the filing of their action against Dershowitz was a "tactical ." (Dershowitz, Notice of Withdrawal of Motion for Partial Summary Judgment.)¶

In order to maximize his recovery on his claims against Dershowitz, had to and did allege that his reputation had recovered (from any effects of Epstein's suit against him) and¶

J. and Paul G. Cassell v. Alan Dershowitz, 17th Judicial Circuit, Broward County Case No. CACE-15-000072.¶

that Dershowitz' defaming public statements caused harm to his reputation. Now that has admitted that suing Dershowitz was a tactical mistake, he claims that Epstein is once again the cause of harm to his reputation. Epstein, therefore, identified exhibits that contradict this position.¶

D. Website and Verdicts¶

Epstein has identified as trial exhibits printouts from current website d verdicts and judgments referenced therein. touts his jury verdicts, includin 4btdicts he has received since Epstein filed suit ($7.1 million, $5.7 million, $24 million, e • important for the jury to understand and see how has not "suffered" from ing of the lawsuit against him.¶

E. Property Records¶

Epstein has identified as trial exhibits info St yo real property ownership i i d to show the jury how success after mbs• v suit has allowed him to invest in more expensive and larger real estate.¶

F. CVRA Documents¶

has taken the °si < i *)that the Crime Victims' Rights Act action against the United States Govemme motive for Epstein filing suit against him. Because that action will play a key, Epstein identified additional pleadings from that action. Epstein points out th himself identified the entire action on his Exhibit List. Trial Exhibi¶

CONTINUA OF THE LAWSUIT IS AN ISSUE¶

During the December 5, 2017, hearing, counsel made clear that he intended to prove that Epstein did not have probable cause to file the action or to continue it. Specifically, counsel argued:¶

1 MR. SCAROLA: ...
2 .... We contend there was no probable
3 cause to initiate this proceeding, there was
4 no probable cause to continue the
5 proceeding. The initiation and continuation
6 of the proceeding caused damage to [REDACTED]
7 [REDACTED], both because no probable cause ever
8 existed. So it was both initiated and
9 continued in the absence of probable cause.¶

(12/5/17 Transcript, p. 46) (Excerpt, Exhibit I).¶

The parties have further stipulated in the Pre-trial Stipulation that the continuation of the action will be addressed at trial:¶

2.B. If Epstein had probable cause to initiate the original civil proceeding against [REDACTED] at the time the case was initially filed, whether a reasonably cautious person would have continued to prosecute the civil proceeding against Edwards, based on new information acquired by Epstein after the case was filed. (The parties agree that in the absence of material disputed facts, the issue of whether Epstein's claim against Edwards was maintained when probable cause no longer existed is an issue to be determined by the Court.)¶

2.C. Epstein's Position: Whether Epstein instituted or continued his civil proceeding against Edwards maliciously and without probable cause for the primary purpose of injuring [REDACTED] or recklessly and without regard for whether the proceeding was justified. (This issue is based on the Standard Jury Instruction, but [REDACTED] disputes it is appropriate.)¶

Edwards' Alternate Position: Whether Epstein instituted or continued his civil proceeding against [REDACTED] with legal and/or actual malice. (Epstein disputes this issue because it does not follow the Standard Jury Instruction.)¶

2.D. Epstein's Position: Whether the continuation of the civil proceeding by Epstein against [REDACTED] resulted directly and in natural and continuous sequence from Epstein's actions and, but for Epstein's actions, the proceeding would not have been continued. ([REDACTED] disagrees that this is an issue and is of the position that, having conceded that Epstein is responsible for initiating the claim, and having waived any "advice of counsel" defense, it is impossible for Epstein to contend that responsibility for maintenance of the¶

action up until the time of its voluntary dismissal is attributable to anyone but Epstein himself.)¶

Pre-Trial Stipulation. (Exhibit J.)¶

has the burden of proof. The e-mails recently disclosed as trial exhibits are critical to the cross examination of both as to his credibility and as support for the continuation of the proceeding and Epstein will be prejudiced if he is not allowed to introduce th at trial.¶

HISTORY OF DISCLOSURE OF TRIAL EXHIBITS4S.,¶

A. July 20, 2017, Order Specially Setting Jury Trial¶

The Court's July 20, 2017, Order Specially Setting Jury Trial C 0 vi )1es, in pertinent part:¶

ADDITIONAL EXHIBITS, WITNESSES OIi. BJ IONS. At trial, the parties shall be strictly limited !ON and witnesses disclosed and objections reserved on the s 6chdes attached to the Pre-Trial Stipulation prepared in accortianec with paragraphs D and E, absent agreement specificallyslated in the Pre-Trial Stipulation or order of the Court upon good cause shown. A party desiring to use an exhibit or witness diaCovered after counsel have conferred pursuant to paragraph D other counsel with a d reason for the late exhibit or with shown or to p II inunediately furnish the Court and f the exhibit ..., together with the f the exhibit or witness. Use of the allowed by the Court for good cause fest injustice.¶

Order,' G (Exhibit K).¶

Pursuant e Tria Order, the deadline for the parties to exchange Exhibit Lists was 60 days prior to 'al; t is, by October 6. 2017.¶

B. s Exhibit Lists¶

Epstein's current counsel appeared in this case on November 1, 2017. At that time, Epstein's operative Exhibit Lists contained only twenty-one items, many of which were identified categorically. (Composite Exhibit L.) In order to better identify the documents, Epstein filed an Amended Exhibit List on November 16, 2017, listing the documents individually that previously were identified in categories. (Exhibit M.) In the Amended Exhibit List, Epstein also identified some general categories, such as:¶

• 13. All documents produced by any party or non-party in this matter,
• 18. L.M. v. Epstein, court filings, etc.
• 30. L.M. v. Epstein (federal court), court filings, etc.
• 35. E.W. v. Epstein, court filings, etc. AO,4 1
• 48. Jane Doe v. Epstein, court filings, etc.
• 59. Jane Doe 2 v. Epstein, court filings, etc.
• 68. Rothstein Rosenfeld Adler v. Rothstein, c flit, etc.
• 84. Razorback Funding v. Rothstein, , etc.
• 323. All public records and new Ah ii to Scott Rothstein, Rothstein Rosenfeldt Adler,' le and any witnesses listed by either party
• 324. All court dockets in all matters against Jeffrey Epstein relating to any aims.
• 328. All rebu eachment exhibits.
• 330. All newly C• undovered documents/exhibits.

On Novem 29, ember 5 and December 7, 2017, important rulings were made by this Court that di im ted the evidence that would be presented at trial. For instance, the Court determin ards would be allowed to provide evidence about his three clients' underlying claims an at Epstein would need to prove each allegation of his Complaint, including that clients' claims were "weak." These rulings resulted in additional evidence needed for trial.¶

On December 19, 2017, Epstein's counsel provided counsel with a flash drive containing the exhibits identified on Epstein's November 16, 2017, Amended Exhibit List, and¶

stated, "In light of the Court's recent rulings, we anticipate amending our Exhibit List after we have had an opportunity to review Mr. Epstein's former counsels'files." (Exhibit N.)¶

On February 2, February 16, and March 2, 2018, Epstein's counsel provided counsel with additional exhibits that fell within Exhibit Nos. 18, 25, 48, 323 and 324. (Composite Exhibit 0.) Those documents were identified above. In the February 2, 2018, transmittal, Epstein's counsel advised, "We are still obtaining additional public records an 'de those to you upon our receipt."¶

In addition, on February 22, 2018, Epstein's counsel's office Q counsel's office that Epstein would be updating his Exhibit List to list ea m 1 vidually as required by the Clerk's guidelines for submission of trial exhibits. (E t re¶

On March 5, 2018, Epstein filed his Cle ts i Si List which identified each item individually that had been previously provid S, ' counsel. (Exhibit Q.)¶

C. Exhibit Lists¶

amended his Exhi t tiple times as well, serving his last list on December 7, 2017, after the original dea any of the items on list are listed categorically and not in compliance wi lerk's guidelines to identify each exhibit separately.¶

D. Decembe . Pre-Trial Stipulation¶

As a y the Court's Order Specially Setting Jury Trial, in their Pre-Trial Stipulation, the p that "Theparties do not waive their right to amend their Exhibits Lists and to identify additional objections for those exhibits that have not yet been disclosed and/or provided to correspond with the parties' respective Exhibit Lists." Thus, the parties agreed that amendments to their Exhibit Lists could be filed after the filing of the Pre-Trial Stipulation.¶

CONCLUSION¶

Mr. Link and Ms. Rockenbach did not steal the disc!¶

There is no doubt that the exhibits recently discovered and identified by Epstein's counsel are relevant to the issues to be tried. Epstein does not believe any attorney-client privilege (none of the exhibits are to or from a RRA lawyer and one of IIM clients — Jane Doe, E. . or L.M.) or work product protection applies to the identified exhibits. The evidence ca tly into question the veracity and truthfulness of in this case. It would be • age of justice for the jury not to see the real . There is uncertainty about sc containing the 27,000 pages of e-mails that was recently discovered by Epste• ' counsel in the boxes came from. The documents do not clarify i di as provided to by, the Trustee, or the Special M 'iSii tiibit difficult is the fact that none of the documents contained on the disc bear any s "Slic n o • lity legend or watermark. What is clear is that Mr. Link and Ms. Rockenbach d' At ....e t st the disc. Although Epstein's counsel has not had the opportunity yet to review o ges on the disc, their review of 5,000 pages reveals a hodgepodge of mostly irrelev few relevant documents. The uncertainty regarding when and how these materials duced to should not dictate whether or not to admit relevant and non deg or no longer privileged evidence directly germane to the issues that hi made central to this case, as well as the credibility and trustworthiness of %rii.s • a central witness in this case.¶

Accordingly, Epstein respectfully requests that Motion be denied and that he be allowed to introduce the exhibits identified on his Clerk's Exhibit List at the trial of this matter.¶

CERTIFICATE OF SERVICE¶

I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on March 7, 2018, through the Court's e-filing portal pursuant to Florida Rule of Judicial Administration 2.516(b)(1).¶

LINK & ROCKENBACH, PA 1555 Palm Beach Lakes Boulevard, Suite 301 West Palm Beach, Florida 33401 (561) 727-3600; (561) 727-3601 [fax]

¶

Byis/ Scott J. Link¶

Scott J. Link (FBN 60299 Kara Berard Rockenbac 44903) Primary: Scottglinttljtw.com Angela M. Many (F Primary: Ka tlinkrocklaw.com Primary: Second Seco S Eservice(alinkrocklaw.com nkrocklaw.com¶

(S /e' S i Counsel fo r PPlaintiff/Counter-Defendant "isi me ffrey Epstein¶

4 RVICE LIST¶

Jack Scarola Searcy, Denny, Scarola, 2139 Palm Beach bakes evard West Palm Bea L 33 me scarolatea Co-C law com r Defendant/Counter-Plaintiff' dwards & Shipley, P.A. Nichole J. Segal Burlington & Rockenbach, P.A. Courthouse Commons, Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 njsQFLAppellateLaw.com kbt@FLAppellateLaw.com Co-Counseicaendant/Counter-Plaintiff J.¶

<p><b>J. [REDACTED]</b> <b>Pottinger LLC</b> 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 <a href="mailto:brad@epllc.com">brad@epllc.com</a> <a href="mailto:staff.efile@pathtojustice.com">staff.efile@pathtojustice.com</a> <i>Co-Counsel for Defendant/Counter-Plaintiff</i> <b>J. [REDACTED]</b></p>	<p>Marc S. Nurik Law Offices of Marc S. Nurik One E. Broward Boulevard, Suite 700 Ft. Lauderdale, FL 33301 <a href="mailto:marc@nuriklaw.com">marc@nuriklaw.com</a> <i>Counsel for Defendant Scott Rothstein</i></p>
<p>Jack A. Goldberger Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 <a href="mailto:jgoldberger@agwpa.com">jgoldberger@agwpa.com</a> <a href="mailto:smahoney@agwpa.com">smahoney@agwpa.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i> <i>Jeffrey Epstein</i></p>	<p><b><u>VIA EMAIL</u></b> Paul Cassell 383 S. University Str. Salt Lake City, UT 84112-0730 <a href="mailto:cassellp@law.utah.edu">cassellp@law.utah.edu</a> <i>Co-Counsel for L.M., E.W. and Jane Doe</i></p>
	<p><b><u>VIA EMAIL</u></b> Jay Howell Jay Howell & Associates 644 Cesery Blvd., Suite 250 Jacksonville, FL 32211 <a href="mailto:jayhowell.com">jayhowell.com</a> <i>Co-Counsel for L.M., E.W. and Jane Doe</i></p>

EXHIBIT A¶

NOT A CERTIFIED COPY¶

MEETING HELD BEFORE SPECIAL CARNEY¶

IN RE:¶

IN THE CIRCUIT COURT OF THE 15TH JUDICI CIRCUIT IN AND FOR PALM BEACH COUNTY, FLOR¶

Complex Litigation, Fla. R. Civ. Pro¶

C ::) CASE NO. 50 2009CA040800XXXXMb 'q¶

JEFFREY EPSTEIN,¶

Plaintiff, vs.¶

SCOTT-ROTHSTEIN, indivi J. EDWARDS, i and L.M., individua¶

Defen¶

DATE T Tuesday, (March 15,)(FEU) TIM 10:05 AM - 12:35 PM PLR: SEARCY DENNEY SCAROLA BARNHART .6 yy 6S West Palm Beach, Florida 33409 SHIPLEY 2139 Palm Beach Lakes Boulevard¶

Lee Lynott, Registered Merit Reporter Registered Professional Reporter Certified Shorthand. Reporter Hi-Tech/United Reporting, Inc. 1218 SE 3rd Avenue Fort Lauderdale, FL 33316

¶

2¶

APPEARANCES:¶

WHITE, BURNETT, P.A. BY: LILLY ANN, ESQUIRE ACKERMAN, ESQUIRE KNIGHT, ESQUIRE One Financial Plaza - 21st Floor 100 Southeast 3rd Avenue Fort Lauderdale, Florida 33394¶

FARMER, JAFFE, WEISSING, EDWARDS, FIST AN, P.L.¶

BY: 425 N. Andrews Avenue Fort Lauderdale, Flor¶

SEARCY DENNEY SCAROLJC-$AITRT & SHIPLEY BY: JACK SCAROLA, ESQUIRE 2139 lik.Beach Lakes Boulevard We alarBeach, Florida 33409¶

< 42*ALSO PRESENT:¶

III!!!!)¶

NBERGER via telephone¶

1 2 3 4 5 6 7 within 10 days or 30 days, I've forgotten exactly which, from the issuance of the subpoena or from the notice of the subpoena. But again, accepting 'that he doesn't have' the documents and doesn't know :what's in the documents at this point, what they are, again, I'm not sure quite as troubled by that.¶

8 9 10 11 12 13 14 15 But as I say, we still get to the-question: . How does he object. to it? Because the_objection was only a privilege objectionNIthink there is a pretty fair argumen5,,aConld be made at, . that point that it waives-the overbreadth objection and what miteleft with is a privilege objeCtion, Mhich!would.require a privilege ,l,T,)7¶

16 17 18 19 20 21\ 22 23 MR.' SCALI4A: I have multiple responses for th a srThe first is that,. Gosman tells us how we -sdealc,pwith circumstances where we're in gray areas. And what Gosman explicitly holds is _ ,!1 that an implied waiver of privilege is not favored in Florida law. There must be an expressed waiver. There, clearly, has been no expressed waiver under these circumstances.¶

24 25 But let's move on from procedure to substance, if we could. This is not a¶

circumstance where an adverse party seeking discovery makes the determination of the appropriateness of a privilege objection. That determination is to be made initially by you and subsequently by whichever judge or judges have to make that determination.¶

The issue has got to be: Have you been provided with sufficient information in order to make those determinations?¶

/ T-I-G addresses the sitnation'Where a privilege log is provided -it:lien of the production of documents. - The situation we have) (here is one where we have turned over the) (documents themSglveS lor in-camera inspection.) (Theylre_aygilsble to you.) You can look at them. (we_havd' told_you to turn over anything and) (everything that you think is relevant, material") rivileged by attorney-client privileges) 4:Sorkiproduc) (Give it to them)¶

O You don't need a privilege log where the document is described, because you have the document. You don't need a privilege log that tells you who the author of the document was, because you have the document and it identifies who the author was. You don't need a privilege¶

1 log that tells you to whom the documents were
2 directed, because the documents tell you to whom
3 they were directed..¶

4 Every inadequacy that they have described in
5 the privilege log is overcome by the fact that
6 we have voluntarily made the documents
7 themselves available and are prepared to answer
8 whatever questions you may have relating to
9 those documents during the course of an
10 in-camera inspection, if you determine that
11 that's what needs to be done.¶

12 SPECIAL [REDACTED] CARNEY: I'm not -- Let me
13 pause here for a second, because I'm not sure
14 you and I are on the same page on this.¶

15 What I'm understanding is, the procedure
16 that seems to be set out as the appropriate
17 procedure on a privilege log issue is: Once the
18 privilege log has been filed, there is a
19 hearing. It's not an in-camera inspection at
20 that point. It is a hearing where the other
21 side challenges, if they will, the privilege.
22 What their position is is, they can't challenge
23 it without more information.¶

24 For example, the memo to confidential
25 source. They can't challenge that without the¶

information as to whether there would be a 2 3 4 privilege or whether that's something that falls outside of the privilege, because it's a disclosure.¶

5 6 7 8 9 10 11 MR. SCAROLA: We are on the same page, because I agree with you that the standard procedure is: First, the preliminary determination as to whether the documents_are discoverable, if not, privileged. Then the filing of a privilege log as o diicoverable material that is claimedAtche¶

12 13 14 15 16 17 18 N\ That log identifid ocUMents with sufficient particnia ies so that the parties seeking the diS"cOverican challenge the . assertion wf/privilege and then an in-camera ,fr ' inspection to make a determination after the 'chellenge is raised as to whether the challenge .—is or is not valid.¶

19 21 22 23 24 25 ( O What I am suggesting to you is, we have voluntarily skipped ahead and provided everything for an in-camera inspection which we would ordinarily not be obliged to do. And because we have waived our right to have the defense establish a prima facie showing for an in-camera inspection, the inadequacies that they 1 2 are arguing exists in the privilege log become absolutely irrelevant.¶

3 4 5 6 7 8 The documents are there for a determination as to whether any of them are privileged. And if there is any questions that arise with the. ..44sv documents in front of you as to whether th re ic or are not privileged or otherwise disc a, CIM:4Ini e we're prepared to respond to those es .¶

9 10 11 12 13 ) We have met our obligation b voluntarily producing the documents for without putting the part the burden of establ ra inspection ing discovery to ome prima facie basis for the in- nspection.¶

14 15 16 17 18 19 20 That's the purpose of the privilege • / log, so that,they have a basis to challenge the assertion of privilege and to require that certain documents be inspected in-camera. We've / - waiVed it. We've given you everything.. I don't *low that there is anything more, certainly, that we.are obliged to do.¶

21 22 23 24 SPECIAL CARNEY: (Just so we're clear.) (Actually)(in terms of the Stapp documents) (I) (still don't have the Stamp documented) (I've never had the Stamp documents)¶

25 MR. SCAROLA: (They are available.) (Pm are)¶

available. (We've offered them before) (offer them to you again) (Review them. we'll Whatever (you think is discoverable,_give it to them) (That's the bottom line)¶

All: of their objections, their T-I-G objections are based upon a procedure thatc, circumstances. O 1Ssimply does not apply under these¶

...4."¶

SPECIAL CARNEY: Just.nn nt. Let me be sure I'm understan actly what you're saying here. I'm o• o use, as an example, the confide s rce. A st¶

" k8 i € What you're s in- that, out of the 15,000 statem . th are listed here, there are vario 1 ions that are raised to various . Addressing specifically the co dential source entry, that at this point (SP.the xt step would be an in-camera inspection the court to determine whether the ..4i?,b, (::!)confidential source actually meets a privilege or not a privilege.¶

What I'm understanding the reason for an in-camera inspection would be, so that there wouldn't be a•release of the name of the confidential source until such time as the court

¶

2 3 4 5 6 7 8 9 10 11 12 13 MR. SCAROLA: The legal argument has been made that there is no privilege in civil litigation to protect the identity of confidential sources. I'm going to get to that argument. They have cited the cases that support the fact that confidential source information is work-product informatien. It's the work-product privilege that applies. There is no confidential source pr ege. There is a work-product privilege t t rs the identity of persons who are p n information that is not subsequently be used at trial.¶

14 15 4Cctiar-If I may, goi g to address that issue and u be happy to --¶

16 SPE IAL CARNEY: Okay.¶

17 18 19 20 21 22 23 MR. SCAROLA: Yes, you have the document. 'You know what the document says. You can make a determination as to whether it is covered by the work-product privilege or it is not covered by the work-product privilege based upon your review of the document in your in-camera inspection of the document.¶

24 25 SPECIAL CARNEY: Before we get to that, let's cover a couple of areas right now¶

makes that determination.¶

1 2 3 4 5 6 that are raised by the plaintiff. One, plaintiff is indicating that there are three potential sources who could assert the privilege and there aught be some clarification in the privilege log as to which of the sources is asserting the privilege.¶

7 MR. SCAROLA: Why?¶

8 SPECIAL CARNEYf Well, t¶

9 10 11 12 13 14 15 16 MR. SCAROLA: If it is a client rad and a claimant again Epstein, why must Brad identi e defense which client it is? Maybe ' is a lient who hasn't Trirc yet filed a clai ga Mr. Epstein. Why should Mr. Ep n b entitled to know the identity at erson who is asserting an attorne -c1 e t privilege?¶

17 18 19 20 21 22 23 24 nd this brings us to what I think is a very simpo ant and fundamental point here: The ivilege belongs to the client; it does not belong to Mr. , it does not belong to R.R.A., it does not belong to the Trustee. Mr. , R.R.A., Mr. Rothstein, the Trustee have .no ability to waive a privilege that does not belong to them.¶

25 Every case that has been cited by opposing¶

EXHIBIT B¶

NOT A CERTIFIED COPY¶

3¶

4¶

5¶

6¶

7¶

8¶

9¶

10¶

11¶

12¶

13¶

14¶

15¶

16¶

17¶

18¶

19¶

20¶

21¶

22¶

23¶

24¶

JEFFREY EPSTEIN,¶

Plaintiff,¶

VS.¶

IN THE CIRCUIT COURT, 15TH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA¶

CASE NO.: 50 2009 CA 040800XXXXMBAG¶

SCOTT ROTHSTEIN, individually, J. , individually, And L.M., individually,¶

Defendants. G * * * * * * * * * * * * * * * * * * * * * * * *¶

o¶

FEARING BEFORE: HONORABLE \D . CROW¶

DATE TAKEN:¶

TIME: . to 4:45 p.m.¶

PLACE: P each County Courthouse 2 N. Dixie Highway, Room 9C est Palm Beach, Florida 33401¶

REPORTED 44B 1(s,: C Kathleen M. Ames, RPR¶

2¶

3¶

4¶

5¶

6¶

7¶

8¶

9¶

OF: , BURNETT, P.A. 901 Point West 777 S. Flagler Drive West Palm Beach, Florida 33401-6170¶

OF: WEINBERG, P.C. 20 Park Plaza, Ste. 1000 Boston, Massachusetts 02116¶

L. ACKERMAN, JR., ESQUIRE KNIGHT, ESQUIRE¶

WEINBERG, ESQUIRE¶

JACK A. GOLDBERGER, ESQUIRE¶

10 OF: ATTERBURY, GOLDBERGER & WEISS, One Clearlake Centre, Ste. 1 250 Australian Avenue South West Palm Beach, Florida¶

11¶

12¶

13¶

14 JACK SCAROLA, ESQUIRE¶

15 OF: SEARCY, DE SHIPLEY 2139 Pal West .Palm, CAROLA, BARNHART & ch Lakes Boulevard each, Florida 33409¶

16¶

17¶

18¶

19¶

20¶

21¶

22¶

23¶

24¶

CO¶

APPEARING ON BEHALcsse THE PLAINTIFF¶

4 54 r¶

ARING ON BEHALF OF DEFENDANT,¶

2¶

3¶

4¶

5¶

6¶

7¶

8¶

9¶

10¶

11¶

12¶

13¶

14¶

15¶

16¶

17¶

18¶

19¶

20¶

21¶

22¶

23¶

24¶

25¶

MR. ACKERMAN: Okay. We can't really effectively take discovery --¶

MR. SCAROLA: No objection.¶

THE COURT: I'm sorry?¶

MR. SCAROLA: No objection.¶

THE COURT: Okay.¶

MR. SCAROLA: I don't mean to interrupt t can 0 save some time.¶

THE COURT: Okay. Let him have ve inutes and we'll come back and let you say whate •u want, Mr. Ackerman, okay. Go ahead, sir. okay. And then come¶

MR. SCAROLA: Tt3 specific documents that have been identified ckerman from among those documents that hav b agreement that the ( like to use. As long as it is provided to them pursuant to an 1 ould expressly nde stood that by agreeing to the use of those specif* do ments we have not prejudiced any assertion of priv 0 with regard to any other documents, we're prep red to allow them to use them. They are worthless. I really don't care whether he uses them or not. I just don't want to impact upon any other privilege argument that we may make by making that concession. I am obliged to make sure that we continue to protect all of our other privileges because we don't have the right to waive¶

1 2 attorney-client privilege. Unlike the Fifth Amendment privilege, which is controlled by Mr. Epstein, as much as (we might like to take all of this and put it on the floor) (in this courtroom for Your Honor and everybody else in the) (world to take a look at because we have nothing to hide, we) can't do that.¶

7 THE COURT: I understand that.¶

8 9 MR. SCAROLA: Okay. So we're oblig our privilege. kA;t,Sert¶

10 THE COURT: It's not your p¶

11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 befo MR. SCAROLA: We privilege on behalf of our the clients who we repres but also because that material to ongoi protect the work-p ct obligatio other p ends 0 That's the position that we are in. Now, are obk fl assert the cl eCi " Not only on behalf of Ad \ llIose claims were settled formation is relevant and s against Mr. Epstein, we must privilege, as well, because of the we have to protect the interests of those ever get to questions about privilege and an obligation to prepare a privilege log, and an in camera inspection, the threshold issue is relevance. And it was as a consequence of Your Honor's recognition of the fact that there was a threshold relevance issue that Your Honor stayed enforcement of any subpoena or production request in this Court until such time as the pleadings were clarified¶

EXHIBIT C¶

NOT A CERTIFIED COPY¶

IN THE CIRCUIT COURT OF THE 15^th JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA¶

CIVIL DIVISION AG
CASE NO. 502009CA040800XXXXMB
Judge David F. [REDACTED]¶

JEFFREY EPSTEIN,¶

Plaintiff/Counter-Defendant,¶

v.¶

SCOTT ROTHSTEIN, individually, and
[REDACTED] J. [REDACTED], individually,
Defendants/Counter-Plaintiffs.¶

FILED
2012 MAY - 8 PM 4:02
JIM RONK BOCK, CLERK
PALM BEACH COUNTY, FL
CIRCUIT CIVIL 5¶

ORDER ON PLAINTIFF JEFFREY EPSTEIN'S
MOTION TO COMPEL PRODUCTION OF DOCUMENTS FROM
DEFENDANT [REDACTED] EDWARDS AND FOR SANCTIONS¶

THIS MATTER came before the Court on Plaintiff Jeffrey Epstein's Motion to Compel Production of Documents from Defendant [REDACTED] and for Sanctions in the above-styled case. This Court having reviewed the Motion, having heard argument of counsel, and being otherwise fully advised in the premises, it is hereby¶

ORDERED AND ADJUDGED as follows: The Defendant¶

Bradley Edwards shall within 30
days of the date of this order file
a more complete privilege log. The Court
finds the privilege log is insufficient on its
face and does not comply with the requirements
of F.R.C.P 1.280(b)(5) and TIG Ins. Corp v.
Johnson, 799 Suzd 339 (Fla 4th Dec 2001). In¶

Epstein v. Rothstein and [REDACTED]
Case No. 502009CA040800XXXXXMB/Division AG
Order on Epstein's Motion to Compel and for Sanctions
Page 2 of 2¶

all other respects the motion is denied at this
time
DONE AND ORDERED in [REDACTED] at West Palm Beach, Palm Beach County, Florida¶

this 7^th day of April, 2012.¶

May¶

Copies furnished to:¶

Joseph L. Ackerman, Jr., Esq.
Fowler White Burnett, P.A.
901 Phillips Point West
777 South Flaglet Drive
West Palm Beach, FL 33401¶

Lilly Ann [REDACTED], Esq.
The L.S Law Firm
Four Seasons Tower, 15^th Floor
1441 Brickell Avenue
Miami, FL 33131¶

Jack Scarola, Esq.
Searcy Denney Scarola Barnhart & Shipley, P.A.
2139 Palm Beach Lakes Blvd.
West Palm Beach, FL 33409¶

Jack A. Goldberger, Esq.
Atterbury, Goldberger & Weiss, P.A.
250 Australian Avenue, South, Suite 1400
West Palm Beach, FL 33401-5012¶

Marc S. Nurik, Esq.
Law Offices of Marc S. Nurik
One E. Broward Blvd., Suite 700
Fort Lauderdale, FL 33301¶

[REDACTED] J. [REDACTED], Esq.
[REDACTED], Jaffe, Weissing, [REDACTED], Fistos & Lehrman, P.L.
425 North Andrews Avenue, Suite 2
Fort Lauderdale, FL 33301¶

COPY¶

EXHIBIT D¶

NOT A CERTIFIED COPY¶

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

CASE NO.: 502009CA040800XXXXMBAG¶

JEFFREY EPSTEIN,¶

Plaintiff(s),¶

vs.¶

SCOTT ROTHSTEIN, individually,
[REDACTED] J. [REDACTED], individually, and
L.M., individually,¶

Defendant(s).¶

FILED
2012 Aug 17 PM 3:41
PALM BEACH COUNTY, FL
CIRCUIT CLERK¶

ORDER ON OUTSTANDING DISCOVERY MOTIONS¶

THIS CAUSE having come to be considered on August 3, 2012, on outstanding discovery motions, and the Court having reviewed the file and being fully advised in the premises, it is hereby,¶

ORDERED and ADJUDGED that EDWARDS' Motion for Clarification is GRANTED, and this Court's Order of May 7, 2012 is vacated without prejudice. [REDACTED] shall file a written response specifically addressing the production sought in Paragraph 13 of EPSTEIN's Motion to Compel and Amend Protective Order of March 9, 2012 as Ordered in this Court's April 10, 2012 Order. The response shall identify non-privileged responsive documents previously produced, shall be accompanied by all non-privileged responsive documents not previously produced, if any, and shall identify, in a proper privilege log as referenced in this Court's May 7, 2012 Order, responsive documents withheld from production on the basis of any assertion of privilege. This response shall be filed within 10 days from the date of this Order.¶

[REDACTED] adv. Epstein
Case No.: 502009CA040800XXXXMBAG
Order on Outstanding Discovery Motions¶

DONE AND ORDERED at West Palm Beach, Palm Beach County, Florida, this 17th
day of Aug, 2012.¶

Copies have been furnished to all counsel on the attached counsel list.¶

NOT A CEIR TITLED¶

[REDACTED] adv. Epstein
Case No.: 502009CA040800XXXXXMBAG
Order on Outstanding Discovery Motions¶

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¶

[REDACTED] J. [REDACTED], Esquire
brad@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¶

Marc S. Nurik, Esquire
marc@nuriklaw.com
One E Broward Blvd., Suite 700
Fort Lauderdale, FL 33301
Phone: (954)-745-5849
Fax: (954)-745-3556¶

Tonja Haddad Coleman, Esquire
tonja@tonjahaddadpa.com
524 S Andrews Avenue, Suite 200N
Fort Lauderdale, FL 33301
Phone: (954)-467-1223
Fax: (954)-337-3716¶

Lilly Ann [REDACTED] Esquire
lsanchez@thelsfirm.com
The L-S Law Firm
1441 Brickell Avenue, 15th Floor
Miami, FL 33131
Phone: (305)-503-5503
Fax: (305)-503-6801¶

Jack Scarola, Esquire
Searcy Denney Scarola Barnhart & Shipley
2139 Palm Beach Lakes Boulevard
West Palm Beach, FL 33409
Phone: 561-686-6300
Fax: 561-383-9451
Attorneys for [REDACTED]¶

EXHIBIT E¶

NOT A CERTIFIED COPY¶

¶

Ft. Lauderdale, Florida • Washington, DC • Quito, Ecuador¶

James D. Silver
954.847.3324 Direct Line
jsilver@conradscherer.com¶

April 8, 2011¶

VIA E-Mail:jsx@searceylaw.com¶

Jack Scarola
Searcy Denney Barnhart & Shipley
2139 Palm Beach Lakes Blvd.
West Palm Beach, FL 33409¶

Re: Epstein/Rothstein/ [REDACTED]¶

Dear Jack:¶

You sent me a proposal by letter dated April 7, 2011 regarding production to me and my firm of all of the documents that had been turned over to the Special [REDACTED], Judge Carney (the "Special [REDACTED]"), in the special master process that has been on-going before Judge Ray in the RRA bankruptcy case. We spoke by telephone at length late today and reached agreement to your proposal, subject to the modified language that we discussed. I have taken the language from your letter and revised it below based on what we had discussed. Of course, I also had to change the language to reflect that the letter is now being written by me.¶

Accordingly, this letter is intended to confirm the terms and conditions of the production by your client, [REDACTED] Edwards, to us of all documents, without redaction, and notwithstanding any claim of privilege made or that could be made, that the Bankruptcy Trustee Herbert Stettin caused to be turned over or delivered to the Special [REDACTED] pursuant to the special [REDACTED] process described above and any further documents that [REDACTED] has in his possession, custody or control responsive to our subpoena (collectively, the "Epstein Related Documents"). The terms and conditions of our agreement are as follows:¶

1. 1. We will stipulate to stay enforcement of our current subpoena solely as it relates to the Epstein Related Documents subject to the terms and conditions of this agreement;
2. 2. You will produce to us all of the Epstein Related Documents for an "attorneys eyes only" review with the express agreement that the production is pursuant to the common interest privilege and does not constitute a waiver of any privilege otherwise applicable to the documents;

Established 1974
Rex Conrad 1935-1999 | William Scherer
Conrad & Scherer, LLP | 633 South Federal Highway, Fort Lauderdale, Florida 33301
Mailing Address | P.O. Box 14723, Fort Lauderdale, FL 33302
Phone 954.462.5500 | Fax 954.463.9244
www.conradscherer.com¶

3. We will preserve the strict confidentiality of all materials produced to us pursuan^t to this agreement unless:

• a. the same information is or was obtained from an independent source;
• b. you agree to release or modify the restriction on our use of particular materials or; C- we obtain acourt order authorizing our use of the materials or determining C1N that the materials in question are not privileged.
• d. we are compelled to produce or disclose the materials or information derived from them.

4. We agree that neither the documents themselves nor any information obtained from the documents produced to us pursuant to this agreement, subject to paragraph 3 above, will be shared with our clients unless they expressly cis to be bound by the terms and conditions of this agreement.

5. No copies will be made of the documents unless one or more of the conditions of paragraph 3 above have been satisfied, or to the extent we provide copies to aclient or clients pursuant to paragraph 4 above;

6, Nothing in this agreement will restrict our disclosing any document(s) for in camera review in connection with any privilege abjection you seek to maintain, or in connection with any request we make to use the documents without restriction and/or to determine that such documents arc not protected from disclosure by any privilege or otherwise;¶

7. Stay of the aforcement of our subpoena may be lilted at any time to seek additional documents t aj,may come into your possession or control or to satisfy the conditions of Paragraph 3c;

8. The terms of this agreement may be disclosed as we may deem appropriate, and we intend to disclose the terms to Judge Ray at Monday's hearing in connection with announcing our resolution of the issues that were to he considered at that hearing;

In the event that any third-party socks to compel production of materials disclosed to us pursuant to this agreement, we will notify you immediately of such efforts and cooperate with you In preserving the confidentiality of documents you designate as privileged or not otherwise discoverable until such time as any one of the conditions set forth in paragraph ³ above have been satisfied;¶

10. You have agreed to deliver tho Epstein Related Documents to us immediately based on our agreement with you to the terms of this agreement; and

¶

Jack Scorola
April 8, 2011
Page 3¶

11. Since this agreement relates to documents requested in a bankruptcy subpoena issued by us in the RRA bankruptcy case, it is agreed and understood that all disputes relating to this agreement as well as its enforcement will be determined exclusively by Judge Ray in the RRA bankruptcy case. Without limiting the foregoing, to the extent we seek to use or disclose any of the Epstein Related Documents (and you do not consent) and/or to obtain a determination of any issues relating to any claimed privilege regarding those documents, such determinations shall be made exclusively by Judge Ray in the RRA bankruptcy case.

If you agree with the terms and conditions set forth above, please sign this letter below and indicate that it is "Agreed" or send me an e-mail indicating your agreement.¶

Very truly yours,¶

JDS/ra¶

¶

James D. Silver¶

From: James D. Silver Sent: Sunday, April 10, 201112:45 PM To: 'Jack Scarola' Cc: brad@pathtojustice.com Subject: RE: Agreement regarding Epstein Related Documents¶

Jack,¶

Confirming our phone conversation of yesterday we now have an agreement and will appear at the hearing tomorrow morning where I will announce our agreement to Judge Ray. As for the issue regarding how the documents are to be provided, you will provide the electronic documents on disc and we can copy for ourselves from that disk as we deem appropriate. As for additional responsive documents that are not on disk, you agree the y can be copied by a copy service of my choosing, at my side's expense.¶

I am glad that we were able to amicably resolve our Issues regarding the documents setforth In our letter agreement. Have a nice rest of your weekend and I will see you at bankrup cou tomorrow morning.¶

Jim Silver¶

From: Jack Scarola [mallto:JSX@SearcyLaw.com] Sent: Saturday, April 09, 2011 12:41 PM To: James D. Silver Cc: brad@pathtojustice.com Subject: Re: Agreement regarding Epstein Related¶

The letter agreement as redrafted by you is acceptable with one clarification regarding paragraph 10. Electronic documents will be provided on a disc. Hard copy documents will biinade available for your inspection and copying at your expense- rather than we being required to "deliver" the documents to¶

Original Message --- From: James D. Silver SiSilver@tco COMP To: Jack Scarola Sent: Fri Apr 08 20:11:36 20 Subject: Agreement regardlog tcIn Related Documents¶

Jack,¶

Sec attached letter eZ1116know if it accurately sets forth the terms of our agreement. As we were finalizing the document we had a computer issu Word version was lost. Due to the lateness of the hour we did not want to retype the entire letter. As a result, I was unable to correct the mistake in your c-mail address listed on my letter but the correct one is on this eqnall. Also, we had to whiteout the "y" In delivery on the second to last page of paragraph 9 since we couldn't correct it on the document. I wanted to let you know so that it does not look like the document had been altered.¶

Please let me know as soon as you can if we are in agreement. My cell number is 305-588-5664.¶

Jim Silver¶

'•• eSafc scanned this email for malicious content ••• ••• IMPORTANT: Do not open attachments from unrecognized senders •.'¶

EXHIBIT F¶

NOT A CERTIFIED COPY¶

¶

Conrad Si. Scherer¶

Attorneys at Law¶

Ft. Lauderdale, Florida • Washington, DC • Quito, Ecuador¶

. I. y ; I ')¶

• June'7,2011 '.¶

Via and U.S. Mall • :s ••¶

Steven Jaffe, Esq.¶

Farmer, Jaffe, Weissing,¶

Fistos & Lehrman, P.L.¶

425 North Andrews Avenue¶

Suite 2¶

Fort Lauderdale, FL 33301¶

William R. Scherer • 954.847.3362 Direct Line wscherer@con emu=¶

Re: In re: Rothstein Rosenfeldt Adler, P.A., •Case No.: 09-3479I-BKC-RBR¶

(Review of Epstein related documents),¶

File No. 09-444B¶

Dear Steve: ?c¶

I ant troubled by our discussfik ay afternoon with respect to the copying of the documents identified for copying within the fourteen boxes of documents related to the Epstein cases, as well as, the dispute concerning the production of the 27,000 plus c-mails or pages of cmails which were to be transferred on to the thumb drive provided by my office.¶

A lawyer and paralegal from my office spent the entirety of last week at your firm reviewing the contents of the fourteen boxes and marked certain documents as important for further investigation. You are now insisting that the copying process, which was initially agreed upon (two boxes in and two boxes out), be suspended until we agree to provide you with a disk of all the documents we tabbed for further investigation. This suspension of copying along with the failure to provide the c-mails to us is in direct violation of the agreement we reached with Jack Scarola by virtue of the correspondence by James Silver, dated April 8, 2011 and finalized by the email exchange, dated April 10, 2011, both of which are attached to this correspondence. It should be considered that compliance with this agreement has required the investment of resources on our side. Additionally, the agreement specifically provides that all disputes will be resolved by Judge Ray.¶

We now demand that you provide li l the boxes we reviewed (to preclude any possibility of investigation by you of our work product) to the copy service by the close of business today¶

Established ¹⁹⁷⁴¶

Rex Conrad 1935-1999 I William Scherer¶

Conrad & Scherer, LLP I 633 South Federal Highway, Fort Lauderdale, Florida 33301¶

Mailing Address I P.O. Box 14723. Fort Lauderdale, FL. 33302¶

Steven Jaffe, Esq.¶

June 7, 2011¶

Page 2 of 2¶

and provide us with the c-mails which are the subject of our initial agreement. In short — we arc requesting you comply with the agreement.¶

In the event the documents are not provided in their entirety to the copy service and the cmails provided to us, we will file the appropriate motion before the Court and seek sanctions for the time invested last week which was intended to ensure compliance with our initial agreement.¶

Furthermore, our review of the documents has indicated that certain documents may be missing from the boxes. For example, we have not located the deposition transcript of Dave Rogers or the entirety of the exhibits to his deposition. We request that all documents which had been contained within the fourteen boxes be provided to us immediately.¶

WRS/pk¶

End.¶

cc: Esq.¶

I look forward to speaking with you in the hopes of resolving this dispute.¶

Respectfully submit cc¶

ake O'd¶

William R. Scherer¶

For the/..S,¶

Jack Scarola, Esq.¶

James D. Silver Esq.¶

Jessica L. MI Esq.¶

¶

EXHIBIT G¶

NOT A CERTIFIED COPY¶

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN MD FOR PALM BEACH COUNTY, FLORIDA CASE NO.50 2009CA0408003000CME AO Comics Lillgadas, Pla.R.Civ.Pro. 1201¶

JEFFREY EPSTEIN, Plaintiff, -vs- VOWME I OF ILL¶

individually, and LM.¶

Defendant.¶

VIDEOTAPED DEPOSITION OP BRINDLEY 1:131)WkIDS; ESQUIRE¶

Tuesday, Minh 23, 20010 10:00 tt 5:07 p.m¶

2139 Palm Beach Lakes, Boulevard West Palm Bach, Florida 33401¶

Reporteda,_ Cynthia, RPR, PPR Notary Public, State ofElcuida Prose Court Reporting Job No.: 1333¶

1 APPEARANCES:¶

2 On behalf °DM Plaintiff: 3 ROBERT D. CIUTION, JR, ESQUIRE BURM.AN, CIUTION, I.UTTIER& COLEMAN. LIP 4 303 Banyan I3oulevard Suite 400 5 West Palm Bash, Florida 33401 Phone: 561.8422820¶

6¶

7 and • 8 JACK ALAN GOLDBERGER, WE ATIERBURY, GO/DBERGER P.A. 9 250 Austullan Avenue South Suite 1400 . • to West Palm Beach, Melds 3)014012. Phone: 5516568300¶

11¶

12 and 13 On behalf ciao PlaiMrn 14 ALAN ht DERSHOWITZ, QUIRE HARVARD LAW SCEOOL¶

15 Hamer 520 Carnbridge,Manttetatsetts 02138 16 Phone 617.496.2020 ' 17 On behalf of the Defadarm¶

18 JACK SCAROLA, ESQUIRE 'SEARCY. DENNEY, SCAROLA, 19 BARNHART & SHIPLEY, P.A. 2139 Palm Beach Lakes Boukrard 20 West Palm Beach, Florida 33409 Phone: 561.6866300¶

ALSO PRESENT: rose sporting Kozak, Videograber Services¶

3¶

W 4¶

5 EXAMINATION DIRECT CROSS REDIRECT¶

6¶

INDEX¶

7¶

a, ESQUIRE¶

BY MR. CR1TTON 5¶

EXHIBITS'¶

EXHIBIT DESCRIPT1 4%,0B¶

PLAINTIFF'S EX. 1 ALFRED. DRIOUP2 211. 16 CRIMINAL COMPLAINT PLAINTIFF'S EX. 2 COMPLAINT • 239 17 PLAINTIFFS EX 3" JULY22, 2009 276 FACSMILE¶

T14/ .1¶

PROCEEDINGS¶

Deposition taken before Cynthia, Registered Professional Reporter and Florida Professional Reporter, and Notary Public in and for, the State of Florida at large, in the above cause.¶

• • • THE VID13OGRAPHER: We are now on video record. This is Media NS. videotaped deposition of in the matter of Scott Rothstein, J. , and L.M.

Today is Tuesday, March 23rd, 2010 at¶

10:00 a.m. Were here in the law offices¶

of Searcy, Denney, Scazola, Barnhart &¶

Shipley, 2139 Palm Beach Lakes Boulevard,¶

West Palm Beach, Florida.¶

My name is Joe Kozak I am the¶

pher. The court reporter is Cindy¶

from Prose, Prose Court Reporting¶

Age-tleY•¶

Will counsel please introduce¶

yourselves, and then the court reporter¶

will swear in the witnesses.¶

MR. CR1TTON: Bob Critton on behalf of the¶

tes.T•tilhlatied-11ama.ci.e.tia..01. •••••••WaspandaralsualSilholiamiala¶

1 A. I don't know that that's a correct statement. 2 Q. You don't know one way or the other? 3 A. The law firm was constantly expanding and 4 constantly under construction. For the most part in the 5 beginning the cases were kept in a, in a filing cabinet 6 in my office and later were kept in a filing cabinet, I 7 believe, in a locked storage location in another area of 8 the office. 9 Q. And did any attorney have access to that 10 storage area or do you know? 11 A. I believe any attorney could have had access. 12 Q. And if the attorney could have access, you 13 wouldn't necessarily know about it, true? 14 A. Correct. 15 Q. In the trustee's filing that they made in 16 response to my motion to preserve evidence, they 17 indicated that 13 boxes relating to Jeffrey Epstein 18 had been removed by the FBI or the government when 19 they came into the RRA. offices. Do you remember 20 seeing that pleading? 21 A. No. 22 Q. Okay. Are you, were there, in fact, 13 23 boxes of material or at least 13 banker's boxes of 24 material that related to matters directed to, 25 whether, whatever the content related to Mr. Epstein¶

1 did they also have swipe cards so that they could 2 access different areas in the firm? 3 A. I believe so. 4 Q. With regard to when you joined RRA, did 5 you ever have any further meetings with 6 Mr. Rothstein; that is, from the day you started at 7 REA, did you ever meet Mr. Rothstein again? 8 A. By meet him again - 9 Q. Did you ever have a meeting with him again 10 regarding your position in the firm? 11 A. No. 12 Q. Okay. Did you ever meet with him and a 13 number of other individuals with regard. to firm 14 business? 15 A. No. 16 Q. Firm cases? 17 A. I don't believe so. 18 Q. Was Mr. Rothstein ever present in any 19 meeting where any of your cases were discussed? Let 20 me strike that. Was Mr. Rothstein ever present 21 wherein at any meeting where any of the cases 22 against Jefficy Epstein were discussed? Don't tell 23 me content; just was he ever present. 24 A. How would I know that? I don't know. Ile 25 could, he could be in a meeting right now where the case¶

1 that you were aware of; that is, hard copies? 2 A. I don't know. 3 Q. Okay. Could have been more, could have 4 been less; you just don't know? 5 A. Correct. 6 Q. If I understood your testimony, 7 Mr. Rothstein, Mr. Rosenfeldt, any other attorney or 8 investigator could have accessed those files 9 depending or where they were within the firm, true? 10 A. I am not sure exactly who could have accessed 11 it. You asked me if the attorneys could and the 12 attorneys had swipe cards for various locked areas. 13 Each attorneyI believe had access to any area where 14 those files were located. I believe so. 15 Q. Okay. Well, during the time you were 16 there did an individual by the name of Ken Jenne 7 work there? 18 A. Yes. 19 Q. Okay. Did an individual by the name of 20 Mike Fisten work for the firm -- 21 A. Yes. 22 Q. — for RRA? Were they employees of the 23 firm or were they independent contractors? 24 A. I don't know. 25 Q. Okay. During the time they were there,¶

1 could be discussed for all I know. 2 Q. I'm sorry. Obviously, where you, where 3 you were present. &There you ever present at al 4 (meetingwhere WILRothsten —r7 vu — also present why 5 (the Epstein cases were discussed?) 6 (A Not 7 Q. Did he ever call you to communicate with 8 you, call you either by phone, video conference, in 9 any fashion to discuss any act aspect of the cases .10 that you had against Jeffrey Epstein? 11 MR. SCAROLA: You can answer that. 12 THE WITNESS: He has communicated about .13 various, about legal issues related to the case 14 as well as commented about the case to me on 15 very few occasions but I would say less than 16 three times. 17 BY MR. CRITTON: 18 Q. During the time that you, from April of 19 '09 through late October of '09, correct? 20 A. In that time period, where, is that when 21 these 22 Q. Correct. 23 • A. things happened? 24 Q. Well, that's the time you were there; 25 that's what I am asking.¶

EXHIBIT H¶

NOT A CERTIFIED COPY¶

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

Case No. 502009CA040800XXXXMB¶

JEFFREY EPSTEIN,¶

Plaintiff,¶

vs.¶

SCOTT ROTHSTEIN, individually; , individually,¶

Defendants/Counter-Plaintiffs.¶

/¶

.9¶

VOLIt,¶

VIDEOTP?t SITION¶

(EDWAIIDS)¶

en on Behalf of Plaintiff¶

Friday, November 10th, 2017 10:02 a.m. - 6:16 p.m. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409¶

Examination of the witness taken before¶

Sonja D. Palm Beach Reporting Service, Inc. 1665 Palm Beach Lakes Boulevard, Suite 1001 West Palm Beach, FL 33401 (561) 471-2995¶

1 2 3 time that you were interviewing that he would make the monthly payments or he would pay whatever that amount was off?¶

4 5 6 7 8 9 10 A My meeting with him was about 10 minutes. And what he said was, do you have a line of credit? c Don't worry about it. It will be paid off at so2 e point in time that you are at this firm. We go ng to treat you fairly. That was it. There specifics about it. Nobody laid out th('credit line. It wasn't that kind of meeting. c¶

11 Q I got it.¶

12 13 off during the time thad4: & /14 L<d:.re employed by him? Did you ever ask to pay it¶

14 N rk7 A NO-1 Q ar -3) ir)(EITE)(gi.:_y_j¶

15 16 Q My que i n asn't whether you talked to him. It was you ever asked him to fulfill --¶

17 18 A n or er to ask somebody you have to talk to them.¶

19 20 MR. SCAROLA: Excuse me. Doesn't Osking involve talking?¶

21 22 MR. LINK: You can do it by email or YYYY letter. Lots of different ways,¶

23 Mr. Scarola.¶

24 BY MR. LINK:¶

25 Q But did you, in any form of communication,¶

EXHIBIT I¶

NOT A CERTIFICATE COPY¶

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

Case No. 502009CA040800XXXXMB¶

JEFFREY EPSTEIN,¶

Plaintiff/Counter-Defendant,¶

vs.¶

SCOTT ROTHSTEIN, individually, , individually,¶

Defendants/Counter-Plaintiff.¶

VOLUO 7¶

TRANSC <t TP PROCEEDINGS ?S H\¶

14 ...,¶

O4¶

DATE TA uesday, December 5th, 2017 TIME: 10:02 a.m. - 4:35 p.m. PLA 205 N. Dixie Highway, Room 10C West Palm Beach, Florida FORS: Donald Hafele, Presiding Judge¶

A46 :) This cause came on to be heard at the time and place aid, when and where the following proceedings were ; rted by:¶

Sonja D. Palm Beach Reporting Service, Inc. 1665 Palm Beach Lakes Boulevard, Suite 1001 West Palm Beach, FL 33401 (561) 471-2995

¶

sense. If you think what just said, if it's not filed it and I con 4c MR. LINK: Your Honor, t nly makes r. Scarola e cause when I th the lawsuit, then there was Aaver robable cause.¶

(FOE) (true.) (cause) (Kg( on tW•(d)(EITel)(W: - no prol5W51-e) (initiate)(this)(proceeding, (there) (prba151-e)(cause)(t-(5) CarrifiTrtfle (fife) was proceediircO (The)(initiation)(arid)(continuation C(ID (the) procee 17114)(caused)(daTh7Eg3(t15) (5AtiTh (because) no @Yo15115re) (cause) (eriegfar) (S5)(it) (15151-15) (initiated) (continued)(n1(ere)(absence p(5T)¶

(MR7)(SCAROEKO @p7,)(Yor)(florcCr7) Et) is¶

But th n *nuation isn't I filed it and it s ave been eliminated that day. The sacond day after the lawsuit it's been continued.¶

THE COURT: I will give you two minutes Oo wrap up. We had planned on 40 minutes. l, We are now going on 55. But again, I want to give both sides the opportunity --¶

o?¶

MR. LINK: I appreciate that.¶

THE COURT: I have read the materials and I have heard the arguments. I don't¶

EXHIBIT J¶

NOT A CERTIFIED COPY¶

IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT OF FLORIDA, IN AND FOR PALM BEACH COUNTY¶

Case No. 502009CA0408003CXXXMBAG¶

JEFFREY EPSTEIN,¶

Plaintiff/Counter-Defendant,¶

v.¶

SCOTT ROTHSTEIN individually, and J. individually,¶

Defendants/Counter-Plaintiff.¶

/¶

JOINT PRETRIAL S¶

Pursuant to this Court's Order Special! ury Trial Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") and Defendant/ aintiff C hereby submit this Joint Pretrial Stipulation.¶

A¶

Goes¶

• A. List of All Pending Mo trial of this matter is special set to commence on March 13, 2018. The parties tici to that additional Motions will be filed before that date. Presently, the following ions/Requests are pending:

  • 1. 9/21

• a. Ed 7/1 ds' four Motions to Compel and the following relatecal: , Epstein's Omnibus Response in Opposition to Four O M ons to Compel. /17, Epstein's Motion for Sanctions Pursuant to Violation of Confidential ettlement Agreement Against and His Counsel and the following related filing:

  • a. 11/8/17, Response in Opposition.
  • 3. 10/26/17, Motion for Protective Order.
  • 4. 11/6/17, Epstein's Supplemental Motion to Compel Discovery, and the following related filings:
    • a. 11/15/17, Response in Opposition to Epstein's Supplemental Motion to Compel Discovery;

• b. 9/25/17, EFS -esMotion to Compel Discovery Responses from and

• c. 9/28/17, Memorandum in Opposition to Epstein's Motio to Compel Discovery Responses.

• 5. 11/8/17, Request for Judicial Notice Pursuant to Flo 90.202 and 90.203, and the following related filings:
  • a. 11/17/17, Epstein's Objection to Request
  • b. 11/28/17, Epstein's Notice of Filing Supplement al Notice; and

• y. tatutes Section

• 6. 11/13/17, Motion in Limine Address' ope of Admissible Evidence and the following firelated lings:
  • a. 11/17/17, Supplement to imine Addressing Scope of Admissible Evidence;
  • b. 11/22/17, Epstein's Oppositio ' Motion in Limine Addressing Scope of Admissible Evide
  • c. 4 12/11/17, Sec Scope of Admissible E
• 7. 11/17/17, following related

• a. 11/13/17, E ment to Motion in Limine Addressing Notice of Production from Non-Parties and the otice of Production from Non-Parties.

• 8. 11/22/17, stein's equest for Judicial Notice.
• 9. 12/1/ , Ed s' Motion for Leave to Propound Limited Requests for Admission. +12/4/17, Notice of Filing Deposition Transcript Excerpts and Discovery Responses by Epstein Implicating the Attorney-Client Privilege.
• 12. 12/4/17, Request for Judicial Notice Pursuant to Florida Statutes Section 90.202 and 90.203.
• 13. 12/8/17, Notice of Filing Preliminary Objections and Counter Designations to Epstein's Deposition Designations.
• 14. 12/15/17, Epstein's Motion for Leave to Disclose Expert Witness
• 10. 1 wards' Notice of Filing Deposition Transcript Excerpts and Discovery nses by Epstein Implicating the Fifth Amendment (as to Sections II — V only).

B. Stipulated Facts:¶

• 1. On June 30, 2008, Epstein entered a guilty plea for one count Amm\ ny licitation of prostitution, a third-degree felony, and one count of pr person under the age of 18 for prostitution, a second-degree felony. 107.)
• 2. was admitted to The Florida Bar in March 07 ( ' 11/10/17 Depo. 43:10-12.)
• 3. After being admitted to the Florida Bar orked as an Assistant State Atte at the Broward State Afton% for approximately three years. 5/15/13 Depo. 6:11-15; /10/17 Depo. 50:3-5.)
• 4. After leaving the Broward S 's Office, went to work for the law firm of Kubicki Dra he worked for approximately three handling insurance defe al 5/15/13 Depo. 7:3-10; 11/10/17 Depo. 56:10 117\W hik an employee of RRA, represented himself to the public, including Epstein, as a partner of RRA. 11/10/17 Depo. 189:22-192:9.)
• 5. formed united liability company on April 16, 2007, by the name of "The Law O Brad & Associates, LLC." (Sunbiz.org.)
• 6. rking at Rothstein, Rosenfeldt and Adler, P.A. ("RRA") in April 2009 Ed s' 3/23/10 Depo. 13:19-22.)
• 7. association with RRA terminated at the end of October or beginning of mber 2009. ( 3/23/10 Depo. 15:5-11.)
• 9. Scott Rothstein ("Rothstein") was the managing partner and CEO of RRA. 11/10/17 Depo. 267:12-13.)
• 10. Rothstein voluntarily relinquished his law license in November 2009 and was disbarred by the Florida Supreme Court on November 25, 2009. (11/25/09 Opinion, The Florida Bar v. Rothstein, Supreme Court of Florida, Case No. SC09- 2146.)
• 11. Rothstein was arrested and arraigned in federal court in Broward Co ty, Florida on December 1, 2009. (12/1/09 Information, United States ofAmeri a Rothstein, United States District Court, Southern District of Florida, Case N 1 (D.E. I).)
• 12. In August and September 2008, while working at The La o Brad & Associates, LLC, filed three separate laws Epstein on behalf of three separate clients: L.M., E.W. and Jane Doe. (8 Complaint, Jane Doe
  • v. Jeffrey Epstein, United States District Court, Southern 'strict of Florida, Case No. 08-CV-80893 (D.E. 1); 9/11/08 Com t, LM. v. Jeffiey Epstein, 15'h Judicial Circuit Court, Palm Beach Coun e po. 50-2008-CA-028051 (D.E. 4); 9/11/08 Complaint, E.W. v. Jeffrey 5''' Judicial Circuit Court, Palm Beach County, Case No. 50-2008-C #1: , E. 4).)
• 13. E stein does not admit or deny when he was a sole and Jane Doe). However filed the lawsuits agai
• 14. While an emplo Jane Doe cases
• 15. While an e stmOd A litik'tic) t erointlibee hal . allegations ofhis in the three ollaiewsotsui(tLbromuttwby es not challenge good faith when he pstein. 11/20/17 Depo. 78:3-6; 120:11-18.) Mists the lead attorney on the L.M., E.W. and of RRA, was the sole employee of RRA who made ions on the L.M., E.W. and Jane Doe cases against Epstein. 1 /20/17 Depo. 85:2-15.) 16.E an employee of RRA, did not represent any individuals other than, E.W. and Jane Doe with regard to claims against Epstein. ( 3/23/10 po. 291:8; 11/10/17 Depo. 77:1-7.)
• 17. On July 24, 2009, while was employed by RRA, a Complaint was filed on behalf of L.M. in the United States District Court for the Southern District of Florida. (7/24/09 Complaint, L.M. v. Jeffrey Epstein, United States District Court, Southern District of Florida, Case No. 09-CV-81092 (D.E. 1).)
• 18. L.M. already had a state court action pending against Epstein at the time the July 24, 2009, federao Complaint was filed which was based on the same facts and circumstances. 11/10/17 Depo. 316:11-20.)
• 19. never formally served Epstein with the federal Complaint t was filed on behalf of L.M. against Epstein. al 5/15/13 Depo. 34:10
• 20. L.M.'s July 24, 2009, federal Complaint against Epstein allege her into "oral sex," yet L.M. testified that she never engage intercourse with Epstein and she never touched his geni Complaint 142(j) (D.E. 19).) Epstein forced I or vaginal Answer to
• 21. While was employed by RRA he mad emston to take the deposition of three pilots who had flown, at different lanes used by Epstein, and am deposition of a fourth pilot Answer to Complaint 1 36 e litigation against Epstein.
• 22. On August 24, 2009, L.M. not sitions of Epstein's pilots Paul Visoski, Jr., and David rs. L.M. requested they produce "[a]ll original flight logs from 4 , 1998 through present for any and all aircraft/airplanes/jets w piloted or co-piloted that were owned or controlled by Jeffre or Ghislaine Maxwell." (8/24/09 Notices of Deposition and Su ces Tecums, L M. v. Jeffrey Epstein, 15th Judicial Circuit, Palm l h nty, Case No. 50-2008-C A-028051-XXXX-MB (D.E. 114, 11
• 23. In August pile was employed by RRA, he noticed the deposition of Id p in the Jane Doe litigation. (8/11/09 and 8/24/09, Re-Notices of T Videotaped Depositions, Jane Doe v. Jeffrey Epstein, United States District
• 24. Cie them District of Florida, Case No. 08-80893.) was employed by RRA, he served Answers to Interro atones on half of L.M. and E.W. indicating that he intended to call Bill who was the governor of New Mexico a, as a trial witness as part of clients' litigation against Epstein. Answer to Complaint 140 (D.E. 19).)
• 25. a three clients (L.M., E.W. and Jane Doe) never testified that they had sex with a celebrity, dignitary or international figure associated with Epstein. a 11/10/17 Depo. 167:21-168:10.)
• 26. In August 2009, a, on behalf of his client E.W., served a Request for Entry Upon Land seeking to inspect Epstein's entire home and property and to take videos

and photograph it. (8/10/09, Request for Entry Upon Land, E.W. v. Jeffrey Epstein, 15^th Judicial Circuit, Palm Beach County, Case No. 50-2008-CA-028058-XXX-MB (D.E. 143).)¶

1. 27. On August 20, 2009, the Court in the E.W. matter noted that E.W.'s request to inspect Epstein's entire home and property was withdrawn. (8/20/09, Order on Plaintiff's Request for Entry Upon Land, E.W. v. Jeffrey Epstein, 15^th Judicial Circuit, Palm Beach County, Case No. 50-2008-CA-028058-XXX-MB (D.E. 151).)
2. 28. In August and September 2009, [REDACTED], on behalf of his client L.M., served Notices of Production from Non-Parties evidencing his intent to obtain Epstein's medical records from Stephen Alexander, Bruce W. Markowitz and Charles J. Galecki. The Subpoenas sought, "[t]he complete medical file including MRIs, scans, X-rays and any other diagnostic test result, Intake Form, notes, reports, opinions, correspondence to or from third parties, correspondence to or from Jeffrey Epstein, referrals, medical bills, in short, your complete file." (8/19/09 and 9/11/09, Notice of Production from Non-Party, L.M. v. Jeffrey Epstein, 15th Judicial Circuit, Palm Beach County, Case No. 50-2008-CA-028051-XXXX-MB (D.E. 105, 127, 129).)
3. 29. On August 14, 2009, Edwards, on behalf of his client L.M., served Notices of Production from Non-Parties evidencing his intent to obtain Epstein's prescription history from Lewis Pharmacy and Greens Pharmacy. The Subpoenas sought, "[a] complete computer printout of any and all prescriptions for medication, name and type of prescription, and all other documentation or information on or regarding Jeffrey Epstein." (8/14/09, Notice of Production from Non-Party, L.M. v. Jeffrey Epstein, 15th Judicial Circuit, Palm Beach County, Case No. 50-2008-CA-028051-XXXX-MB (D.E. 97, 100).)
4. 30. On April 24, 2007, L.M., before she was a client of [REDACTED], provided a statement to the FBI.
5. 31. In September 2009, while [REDACTED] was employed by RRA, his client, L.M., testified at a deposition in her case against Epstein.
6. 32. On June 19, 2009, [REDACTED], on behalf of his Jane Doe client, filed a Motion for Injunction Restraining Fraudulent Transfer of Assets, Appointment of a Receiver to Take Charge of Property of Epstein, and to Post a $15 Million Bond to Secure

Potential Judgment. (6/19/09 Motion, Jane Doe No. 2 v. Jeffrey Epstein, United States District Court, Southern District of Florida, Case No. 08-CV-$0119 (D.E. 165).)¶

• 33. In July Jane Doe). 20101.in settled the claims of three die .W., L.M. and 11/10/17 Depo. 305:2-3.)
• 34. The Ponzi scheme through which Rothstein misrep investors began in 2005 and ended in October 2009. for Forfeiture In Rem 1 13, United States v. R Rothstein, United States District Court, Sout CV-61780 (D.E. 1).)
• 35. On November 20, 2009, certain Rothstein in the Seventeenth Ju Florida. This lawsuit was p (11/20/09 Complaint, Razor Judicial Circuit C 062009CA062943 ms and defrauded Verified Complaint operties Purchased by Scott 'et of Florida, Case No. 09 f Rothstein's Ponzi scheme sued Ire ft Court, in and for Broward County, ublic record as of the date it was filed. ing, LLC, et at v. Scott Rothstein, et at, 17th ward County, Florida, Case No.
• 36. The United S govAfttfient filed an Information against Rothstein on or about December 1, 2 s criminal charge was public record as of the date it was filed. (12/ /09 In ation, United States of America v. Rothstein, United States District Co uthern District of Florida, Case No. 09-60331.) +38. ',ember 21, 2009, just 17 days after Epstein instituted the civil proceeding, filed a Counterclaim for abuse of process against Epstein. (12/21/09 Answer and Counterclaim, Jeffrey Epstein v. Scott Rothstein, et at, 15th Judicial Circuit Court, Palm Beach County, Case No. 502009CA40800XXXMB (D.E. 19).)
• 37. O ember 7 2009, Epstein filed a civil Complaint in this action against and L.M. (12/7/09 Complaint, Jetey Epstein v. Scott tein, et at, 15th Judicial Circuit Court, Palm Beach County, Case No. 09CA40800XXXM13 (D.E. 5).)
• 39. represented L.M. in this litigation. ( 11/10/17 Depo. 255:5-11.) a
• 40. did not charge L.M. for his representation of her in this litigation. 11/10/17 Depo. 255:12-19; 257:23-258:1.)

1. 41. [REDACTED] did not enter into any written representation agreement with L.M. concerning his representation of her in this litigation. ([REDACTED] 11/10/17 Depo. 255:20-256:8; 258:2-4.)
2. 42. On January 21, 2010, a Default was entered against Rothstein in this litigation as to all claims in the December 7, 2009, Complaint against Rothstein. (1/21/10 Default, Jeffrey Epstein v. Scott Rothstein, et al., 15^th Judicial Circuit Court, Palm Beach County, Case No. 502009CA40800XXXMB (D.E. 27).)
3. 43. In early August 2010, L.M. and Epstein entered into a Stipulation for Order of Dismissal With Prejudice as to L.M. Individually, Only. (8/5/10 Stipulation, Jeffrey Epstein v. Scott Rothstein, et al., 15^th Judicial Circuit Court, Palm Beach County, Case No. 502009CA40800XXXMB (D.E. 112).)
4. 44. On August 9, 2010, the Court entered a Final Order of Dismissal With Prejudice as to L.M. Only approving L.M. and Epstein's Stipulation. (8/9/10 Final Order, Jeffrey Epstein v. Scott Rothstein, et al., 15^th Judicial Circuit Court, Palm Beach County, Case No. 502009CA40800XXXMB (D.E. 113).)
5. 45. On January 5, 2011, Epstein moved to amend his Complaint, to eliminate certain paragraphs. (1/5/11 Plaintiff's Motion to Amend Complaint, Jeffrey Epstein v. Scott Rothstein, et al., 15^th Judicial Circuit Court, Palm Beach County, Case No. 502009CA40800XXXMB (D.E. 195).)
6. 46. On April 12, 2011, Epstein filed an Amended Complaint against Rothstein and Edwards for abuse of process. (4/12/11 Amended Complaint, Jeffrey Epstein v. Scott Rothstein, et al., 15^th Judicial Circuit Court, Palm Beach County, Case No. 502009CA40800XXXMB (D.E. 303).)
7. 47. On August 22, 2011, Epstein filed a Second Amended Complaint, which was corrected on August 24, 2011, bringing a claim for abuse of process against [REDACTED] and for conspiracy to commit abuse of process against Rothstein. (8/22/11 Second Amended Complaint and 8/24/11 Notice of Scrivener's Error and Corrected Second Amended Complaint, Jeffrey Epstein v. Scott Rothstein, et al., 15^th Judicial Circuit Court, Palm Beach County, Case No. 502009CA40800XXXMB (D.E. 368, 370).)

• 48. On November 3, 2011, moved for Final Summary Judgment on Epstein's Second Amended Complaint. (11/3/11 Renewed Motion for Find Summary Judgment, Jeffrey Epstein v. Scott Rothstein, et al., 15th Judicial Circ ourt, Palm Beach County, Case No. 502009CA40800XXXMB (D.E. 401).)
• 49. appeared in this action as his own co-counsel on the suit against him was dismissed. ( 11/10/1 Notice of Appearance, Jeffrey Epstein v. Scott Rothste Court, Palm Beach County, Case No. 502009CA408
• 50. On July 26, 2012, the Court set the hearing o Summary Judgment to be held on Augus Motion to Reschedule Hearing, Jeffi• Judicial Circuit Court, Palm Beach (D.E. 512).)
• 51. Epstein dismissed his claim 2012. (8/16/12 Notice o et al., 15th Judie 502009CA40800
• 52. inco the present than January 20 2012, before :7-22; 3/27/12 Judicial Circuit B (D.E. 468).) ' Renewed Motion for Final (7/26/12 Order on
  • v. Scott Rothstein, et at, 15 ase No. 502009CA40800XXXMB our prejudice against on August 16, Dismissal, Jeffrey Epstein v. Scott Rothstein, Court, Palm Beach County, Case No. . 519).) lawyer has been collective) greater from January 2010 to as from 2002 when started practicing law through wards' 11/10/17 Depo. 47:10-14; 49:4-13.)
• 53. s is not claiming a loss of income as a result of his reputation being injured ps n's filing and continuation of this lawsuit. 10/10/13 Depo. 1-22.) +wards has not seen a doctor or taken any medication as a result of the anxiety caused by this lawsuit. ( ' 5/15/13 Depo. 57:23-58:5; 11/10/17 Depo. 112:11-20.)

C. Statement of Issues of Fact for Determination at Trial:¶

1. Case Against Rothstein. What, if any, damages were sustained by Epstein and proximately caused by Rothstein? ([REDACTED] does not agree with this language for the reason that the issue as stated fails to tie causation to Rothstein's operation of the Ponzi scheme. It is [REDACTED] position that failure to limit the issue in this way as to Rothstein has the potential of confusing the jury in determining whether Epstein had any probable cause to claim damages against [REDACTED] arising out of the same circumstances.)

2. Malicious Prosecution Counterclaim. The following are issues of fact for determination at trial on [REDACTED] Counterclaim against Epstein:

A. Epstein's Position: Whether, in December 2009, when Epstein instituted his civil proceeding against [REDACTED], the facts and circumstances known to Epstein were not sufficiently strong to support a reasonable belief that the proceeding against [REDACTED] was supported by existing facts and, thus, Epstein did not have probable cause to institute his civil proceeding. (This issue is based on the Standard Jury Instruction, but [REDACTED] disputes it is appropriate.)¶

Edwards' Alternate Position: Whether, in December 2009, when Epstein instituted his civil proceeding against [REDACTED], the facts and circumstances known to Epstein were insufficient to support a belief on the part of a reasonably cautious person that [REDACTED] had engaged in conduct that supported Epstein's claims against [REDACTED]. (Epstein disputes this issue because it does not follow the Standard Jury Instruction. The parties agree that, in the absence of material disputed facts, the issue of whether probable cause existed to support the institution of the civil proceeding brought by Epstein against [REDACTED] is an issue of law to be determined by the Court.)¶

B. If Epstein had probable cause to initiate the original civil proceeding against [REDACTED] at the time the case was initially filed, whether a reasonably cautious person would have continued to prosecute the civil proceeding¶

against [REDACTED], based on new information acquired by Epstein after the case was filed. (The parties agree that in the absence of material disputed facts, the issue of whether Epstein's claim against [REDACTED] was maintained when probable cause no longer existed is an issue to be determined by the Court.)¶

C. Epstein's Position: Whether Epstein instituted or continued his civil proceeding against [REDACTED] maliciously and without probable cause for the primary purpose of injuring [REDACTED] or recklessly and without regard for whether the proceeding was justified. (This issue is based on the Standard Jury Instruction, but [REDACTED] disputes it is appropriate.)¶

[REDACTED] Alternate Position: Whether Epstein instituted or continued his civil proceeding against Edwards with legal and/or actual malice. (Epstein disputes this issue because it does not follow the Standard Jury Instruction.)¶

D. Epstein's Position: Whether the continuation of the civil proceeding by Epstein against Edwards resulted directly and in natural and continuous sequence from Epstein's actions and, but for Epstein's actions, the proceeding would not have been continued. ([REDACTED] disagrees that this is an issue and is of the position that, having conceded that Epstein is responsible for initiating the claim, and having waived any "advice of counsel" defense, it is impossible for Epstein to contend that responsibility for maintenance of the action up until the time of its voluntary dismissal is attributable to anyone but Epstein himself.)¶

E. Whether Epstein's civil proceeding against [REDACTED] was terminated in favor of [REDACTED]. ([REDACTED] contends this is a legal issue for determination by the Court.)¶

F. Whether the institution or continuation of the civil proceeding by Epstein against [REDACTED] was a substantial contributing cause of damage to [REDACTED] and, but for the malicious institution or continuation of the proceeding, [REDACTED] damage would not have occurred.¶

G. What amount of money, if any, will fairly and adequately compensate [REDACTED] for his compensatory damages that resulted from Epstein's institution or continuation of the civil proceeding against [REDACTED].¶

• D. Exhibit Lists (with OW Exhibit Lists and to ide disclosed and/or provid
• H. Whether Epstein was guilty of intentional misconduc reckless disregard or gross negligence which was a substantial cause of d: ages.
• I. Whether punitive damages are warranted as punislune in for instituting or continuing his civil proceeding against ds d/or as a deterrent to others from filing a civil proceeding wi ble cause.
• J. Whether the claimed damage is a result of state made after the institution of the civil proceeding and are thu ro ted by the litigation privilege, even if any such statements to untrue. (This issue is based on the Standard Jury Ins ut disputes it is appropriate because he believe Amended Complaints are "statements made after the i ut the civil proceeding" and are afforded no protection by th privilege.)
• K. Bifurcated Proceeding: ount, if any, should be assessed against Epstein for punitive damages 7 a punishment for instituting or continuing his civil proceed* againsPEdwards and/or as a deterrent to others. Nile parties do not waive their right to amend their onal objections for those exhibits that have not yet been rrespond with the parties' respective Exhibit Lists.
  • I. 't List and Epstein's Objections are attached as Composite Exc.
  • 2. ein Exhibit List and Objections are attached as Composite it B.
• E. Lists: The parties do not waive their right to amend their Witness Lists. Witness List is attached as Exhibit C.
  • 2. Epstein's Witness List is attached as Exhibit D.
• F. Estimated Trial Time: estimates 10 trial days; Epstein estimates 15-20 trial days.

G. Names, Addresses, and Telephone Numbers of Attorneys to Tn. the Case:¶

For Jeffrey Epstein: Scott J. Link Kara Berard Rockenbach Link & Rockenbach, PA 1555 Palm Beach Lakes Boulevard, Suite 301 West Palm Beach, FL 33401 Telephone: (561) 727-3600¶

For J. Jack Scarola David P. Vitale, Jr. Seamy Denney Scarola Barnhart 2139 Palm Beach Lakes Boulev 41. A Telephone: (561) 686-6300 West Palm Beach, FL 33409¶

H. Number of Peremptory Cha Qs Per Party: Three.¶

1. Each Party's propos .instructions and verdict form, with citations to supporting authorities¶

• sed jury instructions and verdict form are attached as Composite Exhi it E.
• 2. proposed jury instructions and verdict form are attached as Composite bi F.

Epstein v. Rothstein and [REDACTED]
Case No. 502009CA040800XXXXMBAG
Joint Pretrial Stipulation
Page 14¶

DATED: December 22, 2017.¶

SEARCY, DENNY, SCAROLA,
BARNHART & SHIPLEY, P.A.
2139 Palm Beach Lakes Boulevard
West Palm Beach, FL 33409
(561) 686-6300; (561) 383-9451 [fax]¶

LINK & ROCKENBACH, PA
1555 Palm Beach Lakes Boulevard, Suite 301
West Palm Beach, FL 33401
(561) 727-3600; (561) 727-3601 [fax]¶

By: /s/ Scott J. Link, with permission
Scott J. Link (FBN 602991)
Kara Berard Rockenbach (FBN 44903)
Angela M. Many (FBN 26680)
Primary: Scott@linkrocklaw.com
Primary: Kara@linkrocklaw.com
Primary: Angela@linkrocklaw.com
Secondary: Tina@linkrocklaw.com
Secondary: Troy@linkrocklaw.com
Secondary: Tanya@linkrocklaw.com
Secondary: Eservice@linkrocklaw.com
Trial Counsel for Plaintiff/Counter-
Defendant Jeffrey Epstein¶

NOTA CERTIFICATE¶

EXHIBIT K¶

NOT A CERTIFIED COPY¶

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA individually, ORDER SPECIALLY SETTING JURY TFLIAL II. UNIFORM PRETRIAL PROCEDURE¶

CIRCUIT CIVIL DIVISION AG CASE NO. 50-2009-CA-040800-XXXX-MB¶

JEFFREY EPSTEIN, Plaintiff(s)¶

v.¶

SCOTT ROTHSTEIN individually, and L M, individually, Defendant(s).¶

THIS CAUSE came before this court on July 6, 2O17 on Counter-Plaintiff, J. , Motion to Set Cause for Trial and the Court's Motion to Determine Nee or Discovery/Motion Scheduling Order and the court having reviewed the Motion, heard argument and being otherwise fully advised in the premises, it is hereby¶

ORDERED AND ADJUDGED that this case is specially set, number one, for jury trial on Tuesday, December 5, 2O17, at 9:3O a.m., (1O days reserved) in Courtroom 1OC, Palm Beach County Courthouse, 2O5 North Dixie Highway, West Palm Beach, Florida 334O1.,¶

• A. On the last business day no later than 60 DAYS PRIOR TO TRIAL the panics shall exchange lists of all trial exhibits, names and addresses.of all trial witnesses, and names and addresses of all expert witnesses.
• B. On the last business day no later than 50 DAYS PRIOR TO TRIAL the parties shall exeliange lists of names and addresses of all rebuttal witnesses.
• C. In addition to names and addresses of each expert retained to formulate an expert opinion with regard to this cause, both on the initial listing and on rebuttal, the parties shall provide:
  • 1. the subject matter about which the expert is expected to testify;
  • 2. the substance of the facts and opinions to which the expert is expected to testify;
  • 3. a summary of the grounds for each opinion;

Order Specially Setting Jury Trial
Case No: 50-2009-CA-040800-XXXX-MB¶

1. 4. a copy of any written reports issued by the expert regarding this case; and
2. 5. a copy of the expert's curriculum vitae.

D. On the last business day no later than 30 DAYS PRIOR TO TRIAL, the parties shall confer and:¶

1. 1. discuss settlement;
2. 2. simplify the issues and stipulate, in writing, as to as many facts and issues as possible;
3. 3. prepare a Pre-Trial Stipulation in accordance with paragraph E; and
4. 4. list all objections to trial exhibits.

E. PRETRIAL STIPULATIONS MUST BE FILED. It shall be the duty of counsel for the Plaintiff to see that the Pre-Trial Stipulation is drawn, executed by counsel for all parties, and filed with the Clerk no later than 20 DAYS PRIOR TO TRIAL. UNILATERAL PRETRIAL STATEMENTS ARE DISALLOWED, UNLESS APPROVED BY THE COURT, AFTER NOTICE AND HEARING SHOWING GOOD CAUSE. Counsel for all parties are charged with good faith cooperation in this regard. The Pre-Trial Stipulation shall contain in separately numbered paragraphs:¶

1. 1. a list of all pending motions including MOTIONS IN LIMINE and DAUBERT MOTIONS requiring action by the Court and the dates those motions are set for hearing (MOTIONS IN LIMINE shall not be heard the day of trial or thereafter). All Daubert Motions must be heard 20 days before the start of the trial.
2. 2. stipulated facts which require no proof at trial which may be read to the trier of fact;
3. 3. a statement of all issues of fact for determination at trial;
4. 4. each party's numbered list of trial exhibits with specific objections, if any, to schedules attached to the Stipulation;
5. 5. each party's numbered list of trial witnesses with addresses (including all known rebuttal witnesses); the list of witnesses shall be on separate schedules attached to the Stipulation;
6. 6. a statement of estimated trial time;
7. 7. names of attorneys to try case;
8. 8. number of peremptory challenges per party; and
9. 9. each party's proposed jury instructions and verdict form, with citations to supporting authority, as schedules attached to the Stipulation.

F. FILING OF PRE-TRIAL STIPULATION. Failure to file the Pre-Trial Stipulation or a Court Approved Unilateral Stipulation as above provided may result in the case being stricken from the Court's calendar at its sounding or other sanctions.¶

G. ADDITIONAL EXHIBITS, WITNESSES OR OBJECTIONS. At trial, the parties shall be strictly limited to exhibits and witnesses disclosed and objections reserved on the¶

Order Specially Setting Jury Trial
Case No: 50-2009-CA-040800-XXXX-MB¶

schedules attached to the Pre-Trial Stipulation prepared in accordance with paragraphs D and E, absent agreement specifically stated in the Pre-Trial Stipulation or order of the Court upon good cause shown. Failure to reserve objections constitutes a waiver. A party desiring to use an exhibit or witness discovered after counsel have conferred pursuant to paragraph D shall immediately furnish the Court and other counsel with a description of the exhibit or with the witness' name and address and the expected subject matter of the witness' testimony, together with the reason for the late discovery of the exhibit or witness. Use of the exhibit or witness may be allowed by the Court for good cause shown or to prevent manifest injustice.¶

H. DISCOVERY. Unless permitted by court order, all discovery must be completed no later than 10 DAYS BEFORE THE DATE SET FOR TRIAL, ABSENT A TRUE EMERGENCY, FAILURE TO COMPLETE DISCOVERY SHALL NOT CONSTITUTE GROUNDS FOR CONTINUANCE.¶

1. I. PRE-TRIAL CONFERENCE. No pre-trial conference pursuant to Fla. R. Civ. P. 1.200 is set by the Court on its own motion. If a pre-trial conference is set upon motion of a party, counsel shall meet and prepare a stipulation pursuant to paragraphs D and E and file the stipulation no later than 5 DAYS BEFORE THE CONFERENCE. Failure to request a pre-trial conference in a timely fashion constitutes a waiver of the notice of requirement of Rule 1.200. Motions for Summary Judgment will not be heard at any pre-trial conference.
2. J. UNIQUE QUESTIONS OF LAW. Prior to trial, counsel for the parties are directed to exchange and simultaneously submit to the Court appropriate memoranda with citations to legal authority in support of any unique legal questions which may reasonably be anticipated to arise during the trial.
3. K. MODIFICATION TO UNIFORM PRE-TRIAL PROCEDURE. Upon written stipulation of the parties filed with the court, the Pre-Trial Procedure, except for items II D-F, inclusive, may be modified in accordance with the parties' stipulation, except to the extent that the stipulation may interfere with the Court's scheduling of the matter for trial or hinder the orderly progress of the trial.
4. L. PREMARKING EXHIBITS. Prior to trial, each party shall meet with and assist the clerk in marking for identification all exhibits, as directed by the clerk.
5. M. DEPOSITION DESIGNATIONS. No later than 20 DAYS PRIOR TO TRIAL, each party shall serve his, her, or its designation of depositions, or portions of depositions, each intends to offer as testimony in his, her or its case in chief. No later than 10 DAYS PRIOR TO TRIAL, each opposing party shall serve his, her, or its counter (or "fairness") designations to portions of depositions designated, together with objections to

Order Specially Setting Jury Trial
Case No: 50-2009-CA-040800-XXXX-MB¶

the depositions, or portions thereof, originally designated. No later than trial, each party shall serve his, her or its objections to counter designations served by an opposing party.¶

III. MEDIATION¶

A. All parties are required to participate in mediation.¶

1. 1. The appearance of counsel who will try the case and representatives of each party with full authority to enter into a complete compromise and settlement is mandatory. If insurance is involved, an adjuster with authority up to the policy limits or the most recent demand, whichever is lower, shall attend.
2. 2. At least ONE WEEK BEFORE THE CONFERENCE, all parties shall file with the mediator a brief, written summary of the case containing a list of issues as to each party. If an attorney or party filing the summary wishes its content to remain confidential, he/she must advise the mediator in writing when the report is filed.
3. 3. All discussions, representations, and statements made at the mediation conference shall be privileged consistent with Florida Statutes sections 44.102 and 90.408.
4. 4. The mediator has no power to compel or enforce a settlement agreement. If a settlement is reached, it shall be the responsibility of the attorneys or parties to reduce the agreement to writing and to comply with Florida Rule of Civil Procedure 1.730(b), unless waived.

B. The Plaintiff's attorney shall be responsible for scheduling mediation. The parties should agree on a mediator. If they are unable to agree, any party may apply to the Court for appointment of a mediator in conformity with Rule 1.720 (f), Fla. R. Civ. P. The lead attorney or party shall file and serve on all parties and the mediator a Notice of Mediation giving the time, place, and date of the mediation and the mediator's name. The mediator shall be paid $175.00 per hour, unless otherwise agreed by the parties.¶

C. Completion of mediation prior to trial is a prerequisite to trial. If mediation is not conducted, or if a party fails to participate in mediation, the case, at the Court's discretion, may be stricken from the trial calendar, pleadings may be stricken, and other sanctions may be imposed.¶

D. Any party opposing mediation may proceed under Florida Rule of Civil Procedure 1,700(b).¶

IV. NONCOMPLIANCE¶

NONCOMPLIANCE WITH ANY PORTION OF THIS ORDER MAY RESULT IN THE STRIKING OF THE CASE, WITNESSES, OR EXHIBITS, OR IMPOSITION OF SUCH OTHER SANCTIONS AS ARE JUST.¶

Order Specially Setting Jury Trial¶

Case No: 50-2009-CA-040800-XXXX-MB¶

DONE AND ORDERED in West Palm Beach, Palm Beach County, Florida this 20th day of July, 2017.¶

¶

JUDGE DONALD HAFELE Circuit Judge¶

Copies furnished to:¶

• .170 Andrew A. Harris (aah@flappellatelaw.com) 17 James (brad@pathtojustice.com) John Scarola (mep@searcylaw.com) 'S < I)41 ITE.COM) 17 Fred Haddad (haddadfm@aol.com) I ACKERMAN, JR (JACKERMAN@F24 17 Maria Kelljchian (maria@pathtojustice.comV 17 \ Matthew D Weissing (matt@pathtojustice.com) PHILIP M BURLINGTON (PMB@FLAPPELLATELAW.COM)
• service@jurytrial.co S, Adler. (servicegurytrialcom) Tonja Haddad Coleman (tonjä@tonJahaddad.com)
• William Bennette (wbk@searcylaw.com) 17 William Chester Brewer, Jr. (wcblaw@aolcom) William B. King Lkingteam@searcylaw.com) fr; John Scarola (jcarolateam@searcylaw.com)
• Rodney G Rdinanci (alex@matrixmediation.com) 17 John R. Beranek (csullivan@ausley.com) Fred Haddad (Dee@fredhaddadlaw.com) 17 James B Chaplin (efile@mediationfirminc.com) Tonja Haddad Coleman (efiling@tonjahaddad.com) 17 Fred Haddad (fredhaddad@fredhaddadlaw.com)

Order Specially Setting Jury Trial¶

Case No: 50-2009-CA-040800-XXXX-MB¶

F F F F F FF F JaymeMi Day (Jayme@tonjahaddad.com) John R. Beranek (jberanek@ausley.com) Jack A Goldberger (jgoldberger@agwpa.com) Andrew A Harris (jrh@flappellatelaw.com) Philip M Burlington (kbt@flappellatelaw.com) Marc Nurik (marc@nuriklaw.com) Jack A Goldberger (smahoney@agwpa.com) Bradley (staff.efile@pathtojustice.com) W Chester= Jr (wcblawasst@grnail.com)¶

CO 'S iS C) )¶

EXHIBIT L¶

NOT A CERTIFIED COPY¶

JEFFREY EPSTEIN,¶

Plaintiff,¶

vs.¶

SCOTT ROTHSTEIN individually, and individually.¶

Defendants.¶

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

CASE NO.: 502009CA040800X7GOCMBAG¶

JUDGE: HAFELE¶

PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN' SIESTF Ci RIAL EXHIBITS, TRIAL WITNESSES AND EXPERT wrtritSsa¶

Plaintiff/Counter-Defendant Jeffrey Epstein ("EpsteirC) h, /files his list of trial exhibits, trial witnesses, and expert witnesses purs Court's Order Setting Jury Trial and Directing Pretrial and Mediation Pr follows:¶

TRIAL E¶

• 1. Information Charging S Rothstein in United States of America v. Stott W. Rothstein, 09-60331-CR-C December 1, 2009.
• 2. Plea Agreemen w nited States of America and Scott W. Rothstein, 09-60331-CR-COHN; filed 1, 2009.
• 3. Amended •otgplaint in Razorback Funding, LLC, et at v. Scott W. Rothstein, et at, in the Cit6uit Court of the Seventeenth Judicial Circuit, in and for Broward County, Fl pease No. 09-062943 (19).
• 4. All Depositions taken of Scott W. Rothstein in in re: Rothstein Rosenfeld! Adler, Pt,t 4791-RBR and any and all ancillary cases related thereto, including, but not ed\t01, Razorback Funding, LW, a at v. Scott W. Rothstein, et at, Case No. 09- 062.4
• 5. The videotaped deposition and all exhibits as referenced/used in the Deposition of Scott W. Rothstein taken by Epstein on June 14, 2012.
• 6. Privilege Log of, Jaffe, Weissing, Fistos & Lehrman, Dated February 23, 2011 as filed in this matter and in In re: Rothstein Rosenfeldt Adler, P.A.; 09-34791-RBR.
  • 7. Docket from Doe v. United States, 08-80736-CIV-MARRA.

8. Any and all exhibits listed and/or used by J.

9. All Depositions taken of J. in the case and chief and the Counterclaim in this matter, via videotape or transcription, including all exhibits used/referenced therein.

10. All documents and exhibits provided by J. in this matter.

11. Transcripts of all depositions taken in the Plaintiff/Counter-Defenti?nt's case in chief and the Counterclaim filed by J. including alb& ibits marked at said depositions.

12. All of Answers to Interrogatories, Respons uests for Production, and Response to Requests for Admissions.

13. Complaints and Docket from L.M. v. Jeffre Snipht 09-CV-81092- COHN; and 502008 CA 018051 XXXXMB.

14. Subpoena(s)/Notice(s) for Deposition o QbRal rump, Alan Dershowitz, David Copperfield, and Mark Epstein.

15. Subpoena to Leonard Baird.

16. Notices to produce med* cords to Charles J. Galecki, M.D., Bruce W. Markowitz, M.D. and Steven R. Al :D.

17. Any and all extikts/dor ments/pleadings referenced in Epstein's Motion for Summary Judgment as to cl'ar& 's Counterclaim.

18. Deposition fldck (John) Scarola dated July 2, 2013 taken in In re: &Assent Rosenfeld\dkr, PA; 09-34791-RBR.

19.*N. 20 S9 nshots of the Farmer Jaffe Weissing firm website in which Epstein's A nam¶

4 fiRA \rem Directory dated October 23, 2009.¶

M. Screenshots of the Jaffe Weissing firm, including its attorneys' Facgmok pages, and other social media, in which Epstein's name appears.¶

The Defendants reserve the right to produce any newly discovered evidence upon proper notice.¶

U¶

The Defendants reserve the right to produce any exhibits used for impeachment or rebuttal.¶

The Defendants reserve the right to amend and/or supplement this Exhibit List as information becomes available upon proper notice.¶

All exhibits expected to be offered at trial by the Defendants, except tho u ed for impeachment, will be made available for inspection at the offices of th ed at a mutually convenient time and date.¶

TRIAL WITNESSES¶

• I. Scott W. Rothstein do Marc Nurik, Esq. Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Ft. Lauderdale, FL 33301

• 2. Ken Jenne do Broward Co. Sheriff 2601 W. Broward B1 Ft. Lauderdale, FL 433 }3
• 3. William Scher do ConradtCgc r, PB Box 14923,E Ft. udesdale; FL 33302-4723
• 4. Spent p uvin e Law Office of Craig Goldenfarb, P.A. 2990 Palm Beach Lakes Blvd., Suite 402 West Palm Beach, FL 33409-6512 Katherine Ezcll do Podhurst Orseck PA 25 W. Flagler St. Miami, FL 33130-1712
• 6. Ami Ederi Miami-Dade State Attorney's Office 1350 NW12th Avenue Miami, FL 33136-2102
• 7. Kikka Claudio Address unknown at this time
• 8. Paul Cassell Borton Petrini, LLP 1320 Columbia Street, Suite 210 San Diego, California 92101-3436
• 9. Margaret Berk 5925 Kaiser Lane Pensacola, FL 32507-8319
• 10. Mercedes Address unknown at this Lime
• 11. Jacquie Address unknown at this time
• 12. Adam Horowitz do Herman, Mermelstein & 3351 NW Boca Raton B1v Boca Raton, FL 33431-
• 13. Stuart Mermelstein do Herman, M & Horowitz, P.A. 3351 NW Bo lvd. Boca Rato 1-6623
• 14. Lisa ivexa do U Scetomey's Office 40 9 venue, Suite A 961 ashville, Tennessee 37203 Jack Kill Address unknown nt this Lime Carolyn Address unknown at this Lime Robert Josetberg Address unknown at this Lime Richard Willits Richard H. Willits, P.A.

490 Way Pante Vedra, FL 32081-0619¶

19.. William J. Berger Weiss Handler & Cornwell PA 2255 Glades Road, Suite 218A Boca Raton, FL 33431-7391 OR Greenspoon Marder PA 100 W. Oipress Creek Road, Suite 700 Fort Lauderdale, FL 33309-2195¶

U¶

20 Bert Patton. Address unknown at this time¶

21.. Susan K. Stilling Promise Healthcare, Inc. 999 NW 5Ig Street Boca Raton, FL. 33431-4477¶

• 22. Mane Yarzabal Address unknown at this time

23: Barry 6740 Chimere Terra 'Boynton Beach, 91¶

• 24. Allan Garte Atto 1000 SW ue, Suite 600 Portl on 972044936

TechnologyWay, Suite 6.30 Raton, FL 33431-3351¶

Christina Fitch Address unknown 'at this time¶

Jaffe, Weissing, Fistos & Lerhman 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268¶

• 28. Denis Kleinfeld 1001 Brickell Bay Drive, 32"d Floor

Miami, FL 34905¶

29. Steve [REDACTED], Esq.
    533 NE 3rd Avenue, Suite 2
    Fort Lauderdale, Florida 33301

30. Carl Linder
    Linder Law Group
    175 SW 7^th Street, Suite 2410
    Miami, FL 33130-2966

31. Cara [REDACTED]
    15751 Sheridan Street, PMB 129
    Fort Lauderdale, FL 33331-3486

32. Jonathan Birkman
    Quraishi & Birkman, PLLC
    809 SE 8^th Street
    Deerfield Beach, FL 33441-5608

33. Robert C. Buschel
    Buschel Gibbons, P.A.
    100 SE Third Avenue, Suite 1300
    Fort Lauderdale, FL 33394-0002

34. Beth Williamson
    1306 Cormorant Road
    Delray Beach, FL 33444-3328

35. Mike Fisten
    Blue Line Investigations
    13762 West State Road #84
    Suite 421
    Davie, Florida 33325

36. Josh [REDACTED]
    Kirschbaum, Birnbaum, Lippman, & Gregoire
    1301 E. Broward Blvd., Suite 230
    Fort Lauderdale, FL 33301-2111

37. Robin T. Kempner
    Address unknown at this time

38. Pat [REDACTED]
    Address unknown at this time

39. Amy Swan

Address unknown at this time¶

• 40. Pat Drug Enforcement Administration 2100 N. Commence Parkway. Weston, FL 33326-3234
• 41. Jeffrey Sonn Broward Financial Centre 500 E. Broward Blvd., Suite 700 Fort Lauderdale, FL 33394-3055
• 42. Tami Wolfe Morrow, Milberg & Wolfe 499 NW 70i6 Avenue, Suite 108 Plantation, FL 33317-7572
• 43. Steven Jaffee Jaffe, Weissing, Fis an 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-326
• 44. Marc Nurik c/o Marc Nurik, Esq. Law Offices of Marc One E. Broward B Ft. Lauderdale,
• 45. Nom Batia Address u
• 46. Prise' cimento ddre kunknown at this time bel Matiska Address unknown at this time 00 55jek at this time
• 48. Michael Wheeler Department of Juvenile Justice 2737 Centerview Drive, Suite 3220 Tallahassee, FL 32399-0999
• 49. Berger Address unknown at this time
• 50. Shawn Gilbert

0¶

Address unknown at this time¶

• 51. Ronald Wise Address unknown at this time
• 52. Wayne Black Address unknown at this time
• 53. Preve Banyon Funding, LLC 2455 E. Sunrise Blvd., Penthouse Suite
• 54. Kendall Coffey Coffey Burlington PL 2699 S. Bayshore Dr., Penthouse Miami, FL 33133-5408
• 55. Seth Lehrman Jaffe Weissing Fistos 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-326
• 56. Phaedra Xanthos Address unknown at thi
• 57. Scott Address unknoi, time
• 58. Alfredo Ittieuez Address unk ortii at this time
• 59. Earleiirn to ubic raper 1E. Browatd Blvd., Suite 1600 Fsn't Lauderdale, FL 33301-1845

Ted Morse Morse Operations 1240 N Federal Highway Fort Lauderdale, FL 33304¶

• 61. Carolyn, Legal Assistant to Jay Howell, Co-Counsel Jay Howell & Associates, PA 6444 Cesery Blvd., Suite 250 Jacksonville, FL 32211-3108

62. Jay Howell
    Jay Howell & Associates, PA
    6444 Cesery Blvd., Suite 250
    Jacksonville, FL 32211-3108

63. Alan Sakowtiz
    1135 Kane Concourse, Floor 3
    Bay Harbor Islands, FL 33154-2025

64. A. J. Discala
    Canvas Financial, LLC
    303 Park Avenue South, Suite 1401
    New York, NY 10001-0646

65. Thane Ritchie
    Address unknown at this time

66. [REDACTED] Kretschmar
    Address unknown at this time

67. Michael Legamaro
    Address unknown at this time

68. Debra [REDACTED]
    Address unknown at this time

69. [REDACTED] Levin
    Address unknown at this time

70. Linda Von Allmen
    Address unknown at this time

71. Bruce Zimet, Esq.
    Financial Plaza
    Suite 2612
    Fort Lauderdale, FL 33301

72. [REDACTED] J. [REDACTED]
    Farmer Jaffe Weissing [REDACTED] Fistos Lehrman
    425 N. Andrews Avenue, Suite 2
    Fort Lauderdale, FL 33301-3268

73. John Scarola, Esq.
    Searcy Denney Scarola et al.
    2139 Palm Beach Lakes Blvd.

West Palm Beach, FL 33409¶

• 74. Jeffrey Epstein do Tonja Haddad, PA 315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301
• 75. Any and all witnesses listed by J.

Epstein reserves the right to list and/or call any and all ne ljMT tscovered witnesses upon proper notice.¶

Epstein reserves the right to call and/or produce any and a llatit4tesses necessary for impeachment or rebuttal.¶

Epstein reserves the right to amend and/o4 ent this Witness List upon proper notice to the Parties and this Court. es t¶

EXPRFAIT ..SSES¶

Unknown at this time, b pstein will amend upon proper review of all documents and discovery ii er and will properly provide the name and address of same as per the Thal C resbrder.¶

WE HEREB RT1FY that a true and correct copy of the foregoing was served upon all p sted below, via Electronic Service, this August 15, 2016.¶

/s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 TONJA HADDAD, PA 315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 954.337.3716 (facsimile) Tonja@TonjaHaddad.com

¶

Electronic Service List¶

Jack Scarola, Esq.
Searcy Denney Scarola et al.
2139 Palm Beach Lakes Blvd.
West Palm Beach, FL 33409
JSX@SearcyLaw.com; MEP@Searcylaw.com¶

Jack Goldberger, Esq.
Atterbury, Goldberger, & Weiss, PA
250 Australian Ave. South, Suite 1400
West Palm Beach, FL 33401
jgoldberger@agwpa.com¶

Marc Nurik, Esq.
1 East Broward Blvd., Suite 700
Fort Lauderdale, FL 33301
marc@nuriklaw.com¶

J. J. [REDACTED], Esq.
[REDACTED] Jaffe Weissing [REDACTED] Fistos Lehrman
425 N Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
staff.efile@pathtojustice.com¶

Fred Haddad, Esq.
1 Financial Plaza, Suite 2612
Fort Lauderdale, FL 33301
Dee@FredHaddadLaw.com¶

Tonja Haddad Coleman, Esquire
Tonja@tonjahaddad.com; efiling@tonjahaddad.com
Law Offices of Tonja Haddad, P.A.
315 SE 7th Street, Suite 301
Fort Lauderdale, FL 33301¶

W. Chester [REDACTED], Jr.
Wcblaw@aol.com; wcbcg@aol.com
W. Chester [REDACTED], Jr., P.A.
250 S. Australian Avenue, Suite 1400
West Palm Beach, FL 33401¶

• •¶

JEFFREY EPSTEIN,¶

Plaintiff,¶

vs.¶

IN THE CIRCUIT COURT OF THE Fn. ltENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA¶

SCOTT ROTHSTEIN, individually, CASE NO.: 502009CA0408003OOO(MBAG and J. individually.¶

Defendants.¶

PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'SQ OF • SUPPLEMENTING HIS EXHIBIT LIST¶

Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") h4eb ;files the following amendment/addition to his exhibit list:¶

JUDGE: HAFELE¶

1. GOVERNMENT'S MOTION t HDW ITS MOTION FOR REDUCTION OF SENTENCE OF SCOTT 114, dated September 26, 2017. Tc1/44T United States of America v. Scott W. Rothste'd 09 - ..., - r0331 COHN.

4¶

WE HEREBY CERTIFY th la rue and correct copy of the foregoing was served upon all parties listed below, vid% ic Service, this September 28, 2017.¶

1st Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 , TONJA HADDAD, PA 315 SE 7`h Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 954.337.3716 (facsimile) Tonja@TonjaHaddad.com Efiling@TonjaHaddad.com

¶

Electronic Service List¶

Jack Scarola, Esq. Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 JSX@SearcyLaw.com; MEP@Searcylaw.com¶

Jack Goldberger, Esq. Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South, Suite 1400 West Palm Beach, FL 33401 jgoldberger@agwpa.com¶

Marc Nurik, Esq. 1 East Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 marc@nuriklaw.com¶

Jaffe WeissinEgsk. Fistos Lehrman 425 N Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 staftefile@pathtojustice.com¶

Fred Haddad, Esq. 1 Financial Plaza, Suite 261/..". Fort Lauderdale, FL 3330K Dee@FredHaddadLaw.co¶

Tonja Haddad Colenw,,Esquire Tonja@tonjahaddad.epm; efiling@tonjahaddad.com Law Officestronja Haddad, P.A. 315 SE,7tIstr c'Suite 301 Fort iiiderd6, FL 33301¶

W. Gfiester, Jr. Wcblaw@aol.com wcbcg@aol.com W. Chester Jr., P.A. 250 S. Australian Avenue, Suite 1400 West Palm Beach, FL 33401¶

EXHIBIT M¶

NOT A CERTIFIED COPY¶

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

Case No. 50-2009CA040800XXXXMBAG¶

JEFFREY EPSTEIN,¶

Plaintiff/Counter-Defendant,¶

^v .¶

SCOTT ROTHSTEIN individually, and J. , individually,¶

Defendants/Counter-Plaintiff¶

/¶

PLAINTIFF/COUNTER-DEFEND¶

A Cos¶

Plaintiff/Counter-Defendant Jeffrey Eloic, y files this list of the trial exhibits he may introduce at the trial of this matter.¶

• 0. No Objection
• 1. All objections
• 2. All objectio
• 3. Irreleva C ceps thenticity atcrial
• 4. P value substantially outweighed by daIer of unfair prejudice, confusion of issues, misleading the jury, or needless presentation of cumulative evidence
• 5. Privileged
• 6. Opinion
• 7. Hearsay
• 8. Authenticity lacking
• 9. Other (please identify basis of objection)

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
<i>Jeffrey Epstein v. Scott Rothstein, [REDACTED] J. [REDACTED] and L.M.</i> <b>15th Judicial Circuit Case No. 50-2009-CA-040800XXXXMB</b>
1	12/7/09	Complaint with Exhibits
2	12/21/09	Answer and Counterclaim of Defendant [REDACTED] J. [REDACTED]
3	1/21/10	Default against Scott Rothstein
4	8/2/10 8/9/10	Stipulation and Order of Dismissal with Prejudice as to L.M., Individually Only
5	3/27/12	Notice of Appearance of [REDACTED] J. [REDACTED]
6	8/16/12	Notice of Voluntary Dismissal Without Prejudice of [REDACTED] J. [REDACTED]
7	1/9/13	[REDACTED] J. [REDACTED] Fourth Amended Counterclaim
8	9/25/13	Affidavit of Jeffrey Epstein
9	6/30/17	Affidavit of Jeffrey Epstein
10	6/30/17	Jeffrey Epstein's Motion for Summary Judgment, Appendix in Support and all documents cited therein
11	Misc.	All deposition transcripts, exhibits and videotapes including, but not limited to: a. [REDACTED] J. [REDACTED] (3/23/10; 5/15/13; 10/10/13; 11/10/17) b. Jeffrey Epstein (3/17/10; 1/25/12) c. Scott Rothstein (6/14/12) d. [REDACTED] Adler (4/20/11) e. Abrakas Joseph Di [REDACTED] (5/25/11) f. [REDACTED] Russell Kretschmar (2/11/11) g. Michael Legamaro (3/11/11) h. Courtney Wild (10/12/17)
12	Misc.	Defendant/Counter-Plaintiff [REDACTED] J. [REDACTED] Answers, Responses, Objections and Privilege Logs in response to Plaintiff/Counter-Defendant Jeffrey Epstein's Interrogatories, Requests for Admission, Requests for Production, and Subpoenas Duces Tecum
13	Misc.	All documents produced by any party or non-party in this matter
14	Misc.	All documents filed in the court file, including pleadings, motions, responses, affidavits, discovery, and exhibits
15	Misc.	All hearing transcripts
<i>State of Florida v. Jeffrey Epstein</i> <b>15th Judicial Circuit</b>

No.	Date	Description	Objection	Marked
16	4/24/07	Transcript of Taped Statement of
17	Misc.	All other testimony, transcripts and statements

L.M. v. Jeffrey Epstein¶

151° Judicial Circuit Case No. 50-2008-CA-028051XXXXMB¶

18	Misc.	Court docket and all court filings referenced therein
19	9/11/08	Com laint
20	12/23/08	Amended Com laint
21	3/30/09	Notice of Change of Firm and Address
22	4/7/09	Defendant Epstein's Answer & Affirmative
23	8/19/09
24	8/24/09	Notices of Taking Deposition and Subpoe
25	8/11/09	Plaintiff's Request for Productio dant
26	8/19/09	Defendant Epstein's Answer§Il ye
		Defenses to Plaintiff's Seco A ed Complaint
27	5/28/10	Plaintiff's Third Amend mt
28	7/22/10	Sti ulation of Dismi reudice
29	Misc.	All testimony, d nscripts, exhibits and
		videotapes inclu mg, of limited to:
		a. L.M. 9/2 10

L.M. v. Jeffrey Epstein¶

USDC S.D. Fla. Case No. 09-CV-81092¶

30	Misc.	C. et, all court filings referenced therein and
		al ery and discovery responses
31	7/24/0	o • • Taint and Demand for Jury Trial
32	7/2	tipulation of Dismissal With Prejudice D.E. 21)
33	Misc.	All testimony, deposition transcripts, exhibits and
34		Federal Rule of Civil Procedure, Rule 11

E.W. v. Jeffrey Epstein¶

151° Judicial Circuit Case No. 50-2008-CA-028058XXXXMB¶

35	Misc.	Court docket, all court filings referenced therein and all discovery and discovery responses
36	9/10/08	Complaint

No.	Date	Description Objection Marked
37	12/23/08	Amended Complaint
38	3/30/09	Notice of Change of Firm and Address
39	4/6/09	Defendant Epstein's Answer & Affirmative
40	6/2/09	Defendant Epstein's Motion for Order to Terminate
41	7/16/09	Cross Notice of Taking Videotaped Deposition of
42	8/19/09	Defendant Epstein's Answer & Affirmative
43	8/10/09	Plaintiff's Request for Entry Upon Land
44	5/28/10	Plaintiff's Third Amended Complaint
45	7/22/10	Stipulation of Dismissal With Prejudice
46	7/29/10	Order Adopting Stipulation and Dismiss'
47	Misc.	All testimony, deposition transcript x b d
		Ja v. of rey Epstein
		USDC . ase No. 08-CV-80893
48	Misc.	Court docket, all referenced therein and
		all discovery an disco responses
49	8/12/08	Complaint (D.E.
50	3/26/09	Defendant tein's Motion to Stay and/or Continue
		Action for' 4 ertain Based on Parallel Civil and
		Cri n 1 Pro ings with Incorporated
		M ndum of Law (D.E. 24)
51	4/9/09	o e Change of Address and Firm Affiliation
	4/9/09	'. ' amtiffs Motion to Strike References to Non
	4/17/09	Plaintiffs First Amended, ip
54	5/14/09	Order Consolidating Cases for Purposes of

No.	Date	Description	Objection	Marked
55	7/28/09 to
		Trump, Mark E . stein, Jean Luc
		Bruhel, Michael Freidman, Rosalie
56	7/20/10	Stipulation of Dismissal With Prejudice (D.E. 210)
57	7/20/10	Final Order of Dismissal With Prejudice (D.E. 211)
58	Misc.	All testimony, deposition transcripts, exhibits and

Jane Doe 2 v. Jeffrey Epstein (Consolidated A •¶

USDC S.D. Fla. Case No. 08-CV-80I¶

59	Misc.	Court docket, all court filings referenced therein and all discovery and discovery responses
60	6/19/09	Plaintiff Jane Doe's Motion for Injunction Restraining Fraudulent Transfer of Assets Appointment of a Receiver to Take Charge of Property of Epstein and to Post a $15 Million Bond to Secure Potential Judgment (D.E. 165)
61	7/23/09	Plaintiff Jane Doe's Reply Memorandum in Support of Motion for Injunction Restraining Fraudulent Transfer of Assets, Appointment of a Receiver to Take Charge of Property of Epstein and to Post a $15 Million Bond to Secure Potential Judgment (D.E. 217)
62	10/16/09	Plaintiff Jane Doe's Notice that Additional Evidence of Epstein's Fraudulent Asset Transfers Will be Filed Shortly, etc. (D.E. 357)
63	10/30/09	Plaintiff Jane Doe's Motion for Leave to Provide Recently-Obtained Deposition Testimony and Affidavit Demonstrating Fraudulent Transfers by Epstein in Support of Motion for Appointment of a Receiver to Take Charge of Property of Epstein and Incorporated Supporting Memo of Law (D.E. 386)
64	11/5/09	Order (D.E. 400)
65	Misc.	All testimony, deposition transcripts, exhibits and videotapes

Jane Doe v. United States of America (CVRA)¶

USDC S.D. Fla. Case No. 08-80736-C IV¶

66	7/7/08	Emergency Victim's Petition for Enforcement of Crime Victim's Rights Act, 18 U.S.C. Section 3771 (D.E. 1)
----	--------	-----------------------------------------------------------------------------------------------------------	--	--	--

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
67	8/14/08	Transcript of Hearing Before the Honorable Kenneth A. Marra

Rothstein Rosenfeldt Adler and Stuart Rosenfeldt v. Scott W. Rothstein 17th Judicial Circuit Broward Coun Case No. 2009-CA-059301-AXXXCE¶

68	Misc.	Court docket, all court filings referenced therein and
69	11/3/09	Amended Complaint
70	Misc.	All testimony, deposition transcripts, exhibits and

In re Rothstein Rosenfeldt Adler, P.A USBC S.D. Fla. Case No. 09-34791-RB¶

71	11/16/09	Motion of the U.S. Trustee for an Order Directing the Appointment of a Chapter 11 Trustee and Objection to Retention of Chief Restructuring Officer (D.E. 8)
72	12/1/09	Verified Complaint for Damages and Other Relief (D.E. 74)
73	2/23/11	Privilege Log of [REDACTED], Jaffe, Weissing, [REDACTED], Fistos & Lehrman
74	Misc.	All testimony, deposition transcripts, exhibits and videotapes including, but not limited to: <ol type="a"> <li>Scott W. Rothstein (12/12/11);</li> <li>Jack (John) Scarola's (7/2/13); and</li> <li>[REDACTED] Adler (10/28/10).</li> </ol>

United ," f America v. Scott Rothstein — Forfeiture Action DC Fla. Case No. 09-CV-61780-Zloch-Rosenbaum¶

75	11/9/09	V	Complaint for Forfeiture in Rem (D.E. 1)
76	11/23/09		d Verified Complaint for Forfeiture in Rem
77	11/2	mended Verified Complaint for Forfeiture	in Rem

The Florida Bar Matters¶

78	11/9/09	The Florida Bar Inquiry/Complaint Form Jeffrey Epstein filed against [REDACTED] J. [REDACTED], William Berger and Scott Rothstein
79	11/25/09	Approval of Scott Rothstein's disbarment; <i>The Florida Bar v. Scott Walter Rothstein</i> ; Supreme Court Case No. SC09-2146

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
80	6/24/10	The Florida Bar's Notice of No Probable Cause and Letter of Advice to Accused; <i>In re Complaints by Jeffrey Epstein and the Florida Bar against [REDACTED]</i> ; James [REDACTED]; Case No. 2010-50,746(09B)
<b><i>United States of America v. Scott W. Rothstein</i></b> <b>USDC S.D. Fla. Case No. 09-60331</b>
81	12/1/09	Information charging Scott W. Rothstein
82	1/25/10	Plea Agreement between the United States of America and Scott W. Rothstein
83	9/26/17	Government's Motion to Withdraw its Motion for Reduction of Sentence
<b><i>Razorback Funding, LLC, et al. v. Scott W. Rothstein, et al.</i></b> <b>17th Judicial Circuit, Broward County, Florida Case No. 09-062943</b>
84	Misc.	Court docket, all court filings referenced therein and all discovery and discovery responses
85	11/20/09	Complaint
86	11/25/09	Amended Complaint
87	Misc.	All testimony, deposition transcripts, exhibits and videotapes including, but not limited to: a. Scott W. Rothstein's testimony (12/12/11, 12/19/11, 12/20/11, 12/21/11, 12/22/11)
<b>Rothstein Rosenfeldt Adler – Communication</b>
88	4/8/09 2:58 p.m.	E-mail from Russell Adler to [REDACTED] J. [REDACTED], cc Mark S. Nurik (01404)
89	4/22/09 4:51 p.m.	E-mail from Bradley J. [REDACTED] to [REDACTED] Adler (01620)
90	4/24/09 5:07 p.m.	E-mail from [REDACTED] J. [REDACTED] to [REDACTED] Adler (01446)
91	5/1/09 10:33 a.m.	E-mail from William J. Berger to [REDACTED] J. Edwards, [REDACTED] Adler, Steven R. Jaffe, Matthew D. Weissing and Gary M. [REDACTED] (01726)
92	5/19/09 12:00 p.m.	E-mail from Susan K. Stirling to [REDACTED] J. [REDACTED] (05725)
93	5/19/09 12:03 p.m.	E-mail from [REDACTED] J. [REDACTED] to Russel Adler (01574)
94	5/22/09 12:13 p.m.	E-mail from [REDACTED] J. [REDACTED] to Susan Spencer Wendel (01449)
95	5/22/09 12:21 p.m.	E-mail from Susan Spencer Wendell to [REDACTED] J. [REDACTED] (05148)

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
96	5/26/09 4:57 p.m.	E-mail from [REDACTED] J. [REDACTED] to Timothy Malloy (01450)
97	5/26/09 5:33 p.m.	E-mail from Timothy Malloy to [REDACTED] J. [REDACTED] (05151)
98	5/28/09 2:13 p.m.	E-mail from Susan Spencer Wendell to [REDACTED] J. [REDACTED] (05161)
99	5/28/09 2:16 p.m.	E-mail from [REDACTED] J. [REDACTED] to William J. Berger (02241-02242)
100	6/3/09 5:17 p.m.	E-mail from William J Berger to [REDACTED] J. [REDACTED], cc [REDACTED] Adler and [REDACTED] J. [REDACTED] (01735)
101	6/4/09 10:43 a.m.	E-mail from [REDACTED] J. [REDACTED] to Susan K. Stirling, cc [REDACTED] (01410)
102	6/9/09 3:10 p.m.	E-mail from [REDACTED] J. [REDACTED] to Eric Glasser (06655)
103	6/23/09 12:52 p.m.	E-mail from [REDACTED] J. [REDACTED] to Michele Dargan (Palm Beach Daily News) (01632)
104	6/23/09 1:03 p.m.	E-mail from [REDACTED] J. [REDACTED] to Paul Cassell (01634)
105	6/23/09 1:13 p.m.	E-mail from Michele Dargan to Bradley J. Edwards (05239)
106	6/23/09 1:16 p.m.	E-mail from [REDACTED] J. Edwards to Michele Dargan (05203)
107	6/23/09 1:29 p.m.	E-mail from Michele Dargan to Bradley J. [REDACTED] (05277-05278)
108	6/23/09 2:31 p.m.	E-mail from Bradley J. Edwards to Michele Dargan (05207-05208)
109	6/23/09 2:41 p.m.	E-mail from Michele Dargan to [REDACTED] J. [REDACTED] (05324-05325)
110	6/23/09 2:53 p.m.	E-mail from Bradley J. [REDACTED] to Michele Dargan (05212-05213)
111	6/23/09 3:08 p.m.	E-mail from Michele Dargan to [REDACTED] J. [REDACTED] (05344-05346)
112	6/23/09 3:12 p.m.	E-mail from [REDACTED] J. [REDACTED] to Michele Dargan (05215-05217)
113	6/23/09 4:39 p.m.	E-mail from Michele Dargan to [REDACTED] J. [REDACTED] (05368-05369)
114	6/23/09 5:22 p.m.	E-mail from [REDACTED] J. [REDACTED] to Michele Dargan (05220-05221)
115	6/23/09 5:28 p.m.	E-mail from Michele Dargan to [REDACTED] J. [REDACTED] (05387-05388)
116	6/24/09 9:39 a.m.	E-mail from [REDACTED] J. [REDACTED] to Michele Dargan (05224-05225)

EFTA02765642¶

No.	Date	Description Objection Marked
117	7/8/09	E-mail from J. to Adler,
	3:36 p.m.	William J. Berger and Steven R. Jaffee (01462)
118	7/13/09	E-mail from Michele Dar an (Palm Beach Daily
	2:28 p.m.	News) to J. 08404)
119	7/4/09	E-mail from J. to William J.
	4:37 p.m.	Berger (0220D_
120	7/15/09	E-mail from EM J. to Michele Dargan
	1:17 p.m.	(04906)
121	7/15/09	E-mail from Michele Dargan to J.
	1:22 p.m.	(04905
122	7/18/09	E-mail Lfrom M J. Adler
	4:10 p.m.	(01661)
123	7/21/09	E-mail from J. to Michele Leone
	8:21 p.m.	(01352
124	7/22/09	E-mail from J. to Michele n
	11:22 a.m.	01479
125	7/22/09	E-mail from Michele Dargan to Bradle
	11:35 a.m.	05803
126	7/22/09	E-mail from Jacquie to J. dwards
	1:29 p.m.	(01662
127	7/22/09	Letter from J. Edw noticing
128	7/26/09	E-mail from Priscila ju ento to Scott
	5:28 p.m.	Rothstein, cc Amy and Adelita Cabello
129	7/28/09	E-mail from B to Susan Spencer
	8:59 a.m.	Wendel (0 3)
130	7/28/09	E-mail fro n Spencer Wendel to J.
	8:59 a.m.	Edw (03 70
131	7/28/09	E- a m J. to Michele Dargan
132	7/28/09	-m it from Michele Dargan to J.
	10:00,a.m._	48
133	7/29/014/	, E-mail from Cam L. to
	1:13 '	08420
134	7/28/09	E-mail from Michele Dargan to J.
	1:47 ..m.	11075-11076
135	7/29/09	E-mail from Michele Dargan to J.
	1:49 p.m.	(05852-05851)_
136	7/30/09	E-mail from J. to Michele Dargan
	2:36 p.m.	(05535-05530_
137	7/30/09	E-mail from J. to Michele Dargan
	2:36 p.m.	(11320-11322)

No.	Date	Description Objection Marked
138	7/30/09	E-mail from J. to Michele Dargan
	6:06 .m.	05538-05539
139	7/31/09	E-mail from Michele Dargan to J.
	11:20 a.m.	(11080-1108S
140	8/10/09	E-mail from J. to Michael Isikoff
	6:59 .m.	06965
141	8/10/09	E-mail from Michael Isikoff to J.
	7:23 p.m.	(06967
142	8/11/09	E-mail Efron7MJ. to Michael Isikoff
	8:43 a.m.	06968-06969
143	8/11/09	E-mail from Michael Isikoff to J.
	9:29 a.m.	(06963-0696i.
144	8/11/09	E-mail from J. to Michael Isikoff
	10:10 a.m.	06970-06971
145	8/11/09	E-mail from Michael Isikoff to J.
	12:34 .m.	06959-06960
146	8/14/09	E-mail from Michael Isikoff to Bradle
	4:40 p.m.	(06975
147	8/15/09	E-mail fromM J. Fisten, cc
	2:41 p.m.	Ken Jenne (02161
148	8/15/09	E-mail from J. Edw whael Isikoff
	6:00 p.m.	(06972-06973)
149	8/17/09	E-mail from MichaelJ611io o radley J.
	10:32 a.m.	(06976-06977)
150	8/17/09	E-mail from B ey J. art to Jacquie
	10:42 a.m.	(02442)
151	8/19/09	E-mail fro radley J. to Ken Jenne
	2:47 p.m.	(01501)
152	8/24/09	E- m radley J. to
	7:38 p.m.	0
153	8/25/09	.1 om to 3.
	11:03 a.	059 2-0595i.
154	8/2	-mail from J. to
	9:56 p.	(02269
155	8/31/09	E-mail from to J.
	10:58 a.m.	02895
156	9/2/09	E-mail from Elizabeth Villar to J.
		12:54 p.m. and Ken Jenne, cc Jacquie Pat and
157	9/7/09	E-mail from to J.
	1:39 p.m.	(07612-07613
158	9/7/09	E-mail from to J.
	6:42 p.m.	(02595-02596)

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
159	9/7/09 6:49 p.m.	E-mail from [REDACTED] J. [REDACTED] to [REDACTED] (07614-07615)
160	9/7/09 7:00 p.m.	E-mail from [REDACTED] to [REDACTED] J. [REDACTED] (07605-07606)
161	9/7/09 8:12 p.m.	E-mail from [REDACTED] J. [REDACTED] to [REDACTED] (07607-07608)
162	9/7/09 10:55 p.m.	E-mail from [REDACTED] to [REDACTED] J. [REDACTED] (07609-07611)
163	9/8/09 11:43 a.m.	E-mail from [REDACTED] J. [REDACTED] to [REDACTED] (04015)
164	9/8/09 11:50 a.m.	E-mail from [REDACTED] to [REDACTED] J. [REDACTED] (07646)
165	9/8/09 11:53 a.m.	E-mail from [REDACTED] J. [REDACTED] to [REDACTED] (07647)
166	9/8/09 12:04 p.m.	E-mail from [REDACTED] to [REDACTED] J. Edwards (07676-07677)
167	9/8/09 1:59 p.m.	E-mail from [REDACTED] to Bradley J. Edwards (07674-07675)
168	9/8/09 2:04 p.m.	E-mail from [REDACTED] J. [REDACTED] to Conchita [REDACTED] (07678-07679)
169	9/8/09 2:36 p.m.	E-mail from Conchita Sarnoff to Bradley J. [REDACTED] (07684-07685)
170	9/8/09 2:42 p.m.	E-mail from [REDACTED] J. Edwards to [REDACTED] (07682-07683)
171	9/8/09 2:49 p.m.	E-mail from Conchita Sarnoff to [REDACTED] J. [REDACTED] (07695-07697)
172	9/8/09 3:25 p.m.	E-mail from Conchita [REDACTED] to [REDACTED] J. [REDACTED] (07680-07681)
173	9/8/09 7:51 p.m.	E-mail from Bradley J. [REDACTED] to [REDACTED] (07686-07688)
174	9/8/09 7:53 p.m.	E-mail from [REDACTED] to [REDACTED] J. [REDACTED] (07689-07691)
175	9/8/09 7:53 p.m.	E-mail from [REDACTED] to [REDACTED] J. [REDACTED] (07692-07694)
176	9/15/09 1:08 p.m.	E-mail from [REDACTED] J. [REDACTED] to Elizabeth Villar, cc Ken Jenne and Pat [REDACTED] (01361)
177	9/18/09 12:35 p.m.	E-mail from [REDACTED] J. [REDACTED] to [REDACTED] Adler (01318)
178	9/18/09 12:35 p.m.	E-mail from Jacquie [REDACTED] to Ann [REDACTED] Villafana, cc [REDACTED] J. [REDACTED] (01583)
179	9/18/09 1:01 p.m.	E-mail from [REDACTED] J. [REDACTED] to Susan Spencer Wendel (05619-05620)

No.	Date		Description	Objection Marked
180	9/18/09	E-mail from	J.	to Beth S.
	2:37 p.m.	Williamson (Wil4
181	9/18/09	E-mail from	J.	to Michele Dargan
	2:55 p.m.	(01280-01288
182	9/21/09	E-mail from	to	J.
	1:37 p.m.	(03081
183	9/23/09	E-mail from	to	J.
	8:42 .m.	(04320
184	9/24/09	E-mail from	J. to	404A"
	6:31 a.m.	(04321
185	9/24/09	E-mail from	to	J.
	6:53 a.m.	(04318-04319		O '
186	9/24/09	E-mail from	to	J.
	8:45 p.m.	(10586-10589
187	9/28/09	E-mail from	to	J.
	8:09 a.m.		cc Renee/Carlos	029
188	9/28/09	E-mail from	J. to
	10:06 a.m.	(06789)
189	9/28/09	E-mail from	to	J.
	10:20 a.m.	(06788)
190	9/28/09	E-mail from Mike Fisten to	n	arnoff
191	9/29/09	E-mail from		to Ken Jenn and
	10:06 a.m.	Elizabeth Villar (0
192	10/2/09	E-mail from B	ey J.	ards to Nigel Rosser
	10:41 a.m.	(06191
193	10/2/09	E-mail fro	igel Rosser to	J.
	11:08 a.m.	06189-061
194	10/2/09	E- m	ichael Isikoff to	J.
	4:28 p.m.	(0 9 980
195	10/2/09	11- il om		to Mike Fisten
	4:52 p.m.	02 0-02441
196	10449	-mail from	J.	to Michael Isikoff,
	4:53 pli.	cc Jacquie	(06974
197	10/2/09		E-mail from Michael Isikoke.1.
	6:14 p.m.	cc Jacquie	06955-06956)
198	10/8/09	E-mail from	J.	to Richard
	4:11 .m.	06961
199	10/13/09	E-mail from Grant J.		to Scott Rothstein,
	2:17 p.m.	J.	Ken Jenne Kip Hunter and
			Adler, cc Grant J.	2650
200	10/13/09	E-mail from Mike Fisten to		J.
	2:27 p.m.	(01727)

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
201	10/13/09 7:00 p.m.	E-mail from [REDACTED] J. [REDACTED] to Jacquie [REDACTED], cc Mike Fisten (01744)
202	10/14/09 7:39 a.m.	E-mail from [REDACTED] J. [REDACTED] to [REDACTED] (03190)
203	10/14/09 9:02 a.m.	E-mail from [REDACTED] to [REDACTED] J. [REDACTED] (03189)
204	10/14/09 10:42 a.m.	E-mail from [REDACTED] Adler to [REDACTED] J. [REDACTED], cc Jacquie [REDACTED] (01099)
205	10/14/09 12:20 p.m.	E-mail from [REDACTED] J. [REDACTED] to Mike Fisten, cc Jacquie [REDACTED] (01741)
206	10/16/09 5:29 a.m.	E-mail from ABA Journal Weekly Newsletter to Scott Rothstein (25864-25865)
207	10/19/09 10:46 a.m.	E-mail from [REDACTED] J. [REDACTED] to Ken Jenne (01704)
208	10/20/09 1:01 p.m.	E-mail from [REDACTED] Rush to [REDACTED] J. Edwards (01433)
209	10/20/09 3:07 p.m.	E-mail from Ken Jenne to Scott Rothstein (26506)
210	10/22/09 11:52 a.m.	E-mail from [REDACTED] J. [REDACTED] to Jacquie Johnson (01391)
211	10/22/09 2:52 p.m.	E-mail from Jacquie [REDACTED] to Russell Adler, Cara L. [REDACTED], Mike Fisten, Michael J. Wheeler, Marc S. Nurik, William J. Berger, Bradley J. [REDACTED], Barry J. [REDACTED] and Ken Jenne, cc Robert C. Buschel (01392)
212	10/22/09 4:10 p.m.	E-mail from Jacquie Johnson to [REDACTED] J. [REDACTED], Marc S. Nurik, Michael J. Wheeler, Cara L. [REDACTED], William J. Berger, [REDACTED] Adler and Robert C. Buschel (01307)
213	10/26/09 7:46 a.m.	E-mail from William J. Berger to Pat Carter and Bradley J. [REDACTED], cc [REDACTED] and Jacquie J. [REDACTED] Johnson (01380)
214	10/29/09 2:16 p.m.	E-mail from Pat [REDACTED] to [REDACTED] J. [REDACTED] (01623)
215	10/30/09 10:01 a.m.	E-mail from Debra [REDACTED] to Scott Rothstein (26304-26305)
216	10/30/09 10:03 a.m.	E-mail from [REDACTED] Adler to Jacquie [REDACTED] and [REDACTED] J. [REDACTED] (01625)
<b>Billing</b>
217	12/21/09	Contract for Services between Searcy Denny Scarola Barnhart & Shipley and [REDACTED] J. [REDACTED]

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
218	N/D	Spreadsheet of Brad [REDACTED] Time in [REDACTED] <i>adv. Epstein</i> (BJE00000104 – BJE00000156)
219	7/14/10 - 1/16/13	Searcy Denney Scarola Barnhart and Shipley's Invoices for Disbursements to [REDACTED] J. [REDACTED] (BJE000000039 – BJE000000103)
220	1/1/80 – 2/15/13	Search Denney Scarola Barnhart and Shipley's Matter Ledger Report (BJE000000006 – BJE000000038)
<b>Miscellaneous</b>
221	10/23/09	Rothstein Rosenfeldt Adler's Firm Directory
222	11/9/17	[REDACTED], Jaffe, Weissing, [REDACTED], Fistos & Lehrman, P.L.'s "Our Attorneys" website printout ( <a href="https://www.pathtojustice.com/about-us/attorneys/">https://www.pathtojustice.com/about-us/attorneys/</a> )
223	12/1/09	Criminal Complaint; <i>United States of America v. Alfredo Rodriguez</i> ; USDC S.D. Fla. Case No. 09-8308
224	4/23/10	Affidavit of [REDACTED] James [REDACTED]
225	9/21/10	Affidavit of [REDACTED] James Edwards
226	Misc.	Subpoenas and Notices of Deposition for Alan Dershowitz, David Copperfield and Leonard Baird
227	11/16/17	Critton Luttier Coleman, LLP's website printout for Robert D. Critton Jr. ( <a href="https://www.lawclc.com/team_members/Robert-d-critton-jr/">https://www.lawclc.com/team_members/Robert-d-critton-jr/</a> )
228	11/16/17	[REDACTED] Burnett, P.A.'s website printout for L. Ackerman, Jr. ([REDACTED] - [REDACTED] Attorneys/id/3/read)
<b>J. [REDACTED]</b>
229	N/D	The National Crime Victim Bar Association presentation excerpt of article by [REDACTED] J. Edwards: <i>Who is Responsible for Child Sexual Abuse</i>
230	N/D	The Florida Bar's website member profile printout for [REDACTED] James [REDACTED]
231	N/D	National Association of Distinguished Counsel biographical information for [REDACTED] J. [REDACTED]
232	5/14/13	The National Trial Lawyers Top 40 Under 40 Directory ( <a href="http://www.thenationaltriallawyers.org/top-40-under-40-directory?last_name+[REDACTED]=&amp;state=FL&amp;x=18&amp;y=17">http://www.thenationaltriallawyers.org/top-40-under-40-directory?last_name+[REDACTED]=&state=FL&x=18&y=17</a> )

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
233	5/14/13	The National Trial Lawyers Profile View of Brad [REDACTED] ( <a href="http://www.thenationaltriallawyers.org/profile-view/Brad/[REDACTED]/4409/">http://www.thenationaltriallawyers.org/profile-view/Brad/[REDACTED]/4409/</a> )
234	5/14/13	Lawyers.com website information for [REDACTED] J. [REDACTED] ( <a href="http://www.lawyers.com/florida/fort-lauderdale/[REDACTED]-J-[REDACTED]-3489098-a/">http://www.lawyers.com/florida/fort-lauderdale/[REDACTED]-J-[REDACTED]-3489098-a/</a> )
235	10/30/04	Kubicki Draper's website attorney information for Brad J. [REDACTED]
236	10/30/05	Kubicki Draper's website attorney information for Brad J. [REDACTED]
237		The American Registry Website printouts of recognitions received by [REDACTED] J. [REDACTED]
238	5/7/12	[REDACTED], Jaffe, Weissing, [REDACTED], Fistos & Lehrman, P.L.'s website printout ( <a href="http://www.abuseandassault.com/Abuse_Under_Investigation">http://www.abuseandassault.com/Abuse_Under_Investigation</a> )
239	1/16/13	[REDACTED], Jaffe, Weissing, [REDACTED], Fistos & Lehrman, P.L.'s website printout ( <a href="http://www.abuseandassault.com/Abuse_Under_Investigation">http://www.abuseandassault.com/Abuse_Under_Investigation</a> )
240	1/16/13	[REDACTED], Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L.'s website printout ( <a href="http://www.pathtojustice.com/media-center/press-releases/">http://www.pathtojustice.com/media-center/press-releases/</a> )
241	5/14/13	[REDACTED], Jaffe, Weissing, [REDACTED], Fistos & Lehrman, P.L. website printout ( <a href="http://www.abuseandassault.com/Abuse_Home">http://www.abuseandassault.com/Abuse_Home</a> )
242	5/14/13	Farmer, Jaffe, Weissing, [REDACTED], Fistos & Lehrman, P.L.'s website printout ( <a href="http://www.abuseandassault.com/Abuse_Under_Notable_Cases">http://www.abuseandassault.com/Abuse_Under_Notable_Cases</a> )
243	5/14/13	Farmer, Jaffe, Weissing, [REDACTED], Fistos & Lehrman, P.L.'s website attorney information for Brad [REDACTED] ( <a href="http://www.pathtojustice.com/attorneys/brad-#.UZJOPpWTOX0">www.pathtojustice.com/attorneys/brad-#.UZJOPpWTOX0</a> )
244	5/14/13	[REDACTED], Jaffe, Weissing, [REDACTED], Fistos & Lehrman, P.L.'s website printout ( <a href="http://www.pathtojustice.com/media-center/achived-press-releases/#.UZJTy5WTOX0">http://www.pathtojustice.com/media-center/achived-press-releases/#.UZJTy5WTOX0</a> )
245		[REDACTED], Jaffe, Weissing, [REDACTED], Fistos & Lehrman, P.L.'s website attorney information for Brad [REDACTED] with referenced articles

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
A.	Winter 2014	Journal of Criminal Law and Criminology. Volume 104; Issue 1. <i>Crime Victims' Rights During Criminal Investigations? Applying the Crime Victims' Rights Act Before Criminal Charges are Filed;</i>
B.	12/26/15	<u>Politico.</u> <i>Victims in Underage Sex Case Want Prosecutors to Testify</i>
C.	12/21/15	<u>Palm Beach Daily News.</u> <i>Jeffrey Epstein Sex Scandal: Alan Dershowitz Suffers Setback in Defamation Case</i>
D.	12/18/15	<u>Palm Beach Daily News.</u> <i>Epstein Victims' Attorneys Seek Partial Victory in Defamation Suit</i>
E.	12/21/15	<u>Palm Beach Post.</u> <i>Boca-Resident Model Nabs $13.4 Million Following Six-Year Divorce Battle</i>
F.	12/17/15	<u>Daily Mail.Com.</u> <i>Florida Model Gets Whopping $13.4 Million Payout from Real Estate Tycoon Ex-Husband After Nasty Six-Year Divorce Battle</i>
G.	11/25/15	<u>Palm Beach Daily News.</u> <i>Appellate Court Reverses Palm Beach Sex Offender Jeffrey Epstein's Victory</i>
H.	11/12/15	<u>Daily Business Review.</u> <i>Attorney's Suit Against Billionaire Allowed as Long as Justices Say It's OK</i>
I.	7/8/15	<u>Palm Beach Daily News.</u> <i>Judge Keeps Thousands of Epstein Documents Sealed</i>
J.	6/25/15	<u>WCVB5.</u> <i>Jury Awards $24 Million to Mass. Widower in Fatal Cabana Crash</i>
K.	6/24/15	<u>NBC6.</u> <i>Jury Awards 24 Million in Fatal Cabana Crash</i>
L.	6/24/15	<u>CBS Miami.</u> <i>Jury Awards Millions to Husband of Pregnant Woman Killed by Drunk Driver</i>
M.	6/25/15	<u>Sun Sentinel.</u> <i>Jury Awards $24 Million to Widower in Fatal Cabana Crash</i>
N.	1/8/15	<u>Daily Business Review.</u> <i>The Lawyer Suing Legal Legend Alan Dershowitz Over Sex Offender</i>
O.	4/21/14	<u>The Washington Post.</u> <i>Eleventh Circuit Rules that Discovery Can Move Forward on My Crime Victims' Rights Act Case</i>
P.	4/21/14	<u>Palm Beach Daily News.</u> <i>Appeals Court Rules Against Sex Offender. Attorneys for Underage Victims Seek to Overturn "Sweetheart Plea"</i>
Q.	4/21/14	<u>Sun-Sentinel.</u> <i>Victims Win Right to See Negotiation that Led to 'Lenient' Plea Deal Agreement for Billionaire Sex Offender</i>

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
R.	4/21/14	<u>Palm Beach Post. Appellate Ruling Could Force Feds to Reconsider Sex Changes Against Palm Beacher Epstein</u>
S.	10/20/13	<u>Palm Beach Daily News. Newest Lawsuit Against Epstein Expected to Include Victim Testimony</u>
T.	9/10/12	<u>CBS Miami, Exclusive: Sexual Assault Victim Alleges Abuse by Former Youth Pastor</u>
U.	9/7/12	<u>Sun-Sentinel. Elevator Fall Nets Woman $13 Million Jury Award</u>
V.	July 2012	<u>Daily Business Review. Top Florida Verdicts & Settlements of 2011</u>
W.	6/13/12	<u>Daily Business Review. Suit Accuses Goldrush Strip Club of Scheme to Bilk Professionals</u>
X.	4/22/11	<u>Palm Beach Daily Business Review. Jeffrey Epstein Amends Lawsuit; Claims Victims' Attorney Threatened to Depose His Friends</u>
246	8/10/16	[REDACTED] Jaffe Weissing's Facebook page with referenced articles
A.	5/22/16	<u>Lawnewz.com. The Shameful Way Feds Protected Convicted Pedophile Billionaire Jeffrey Epstein</u>
B.	5/13/16	<u>Fox News. Flight Logs Show Bill Clinton Flew on Sex Offender's Jet Much More than Previously Known</u>
C.	2/11/16	<u>Sun-Sentinel. Feds Deceived Us About Billionaire Sex Offender's 'Sweetheart Deal' Teen Victims Say</u>
D.	2/12/16	<u>NBC News. Lawyers: Victims Not Told of 'Sweetheart Deal' for Jeffrey Epstein</u>
E.	2/11/16	<u>NY Daily News. Jeffrey Epstein Accusers Sue Feds Over Hidden Non-Prosecution 'Conspiracy'</u>
F.	4/23/14	<u>Farmer, Jaffe. Appeals Court Rules in Favor of Crime Victims' Rights in Registered Pedophile Jeffrey E. Epstein Case</u>
G.	4/23/14	<u>Daily Business Review. Prosecutors Must Turn Over Docs in Billionaire Sex Offender Jeffrey Epstein Case</u>
247	Misc.	Court and arrest information; [REDACTED] James [REDACTED]; Duval County Court, Case No. 16-1995-MM-000074-AXXA-[REDACTED]
248	Misc.	Court and arrest information; [REDACTED] James [REDACTED]; Duval County Case No. 16-1998-CF-004394-AXXX-[REDACTED]

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
249	8/14/07	Exemption and/or Limitation Exclusion – Tax Assessment of $3,507.72
250	1/7/08	Notice of Satisfaction of Lien Relative to Tax Exemption
251	Misc.	Docket and all court filings referenced therein; <i>U.S. Bank National Association v. [REDACTED] J. [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2010CA002613AXXXCE
252	1/21/10	Petition/Complaint; <i>U.S. Bank National Association v. [REDACTED] J. [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2010CA002613AXXXCE
253	2/18/10	[REDACTED] J. [REDACTED] Answer and Affirmative Defenses; <i>U.S. Bank National Association v. [REDACTED] J. [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2010CA002613AXXXCE
254	8/11/10	Notice of Sale; <i>U.S. Bank National Association v. [REDACTED] J. [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2010CA002613AXXXCE
255	8/11/10	Final Summary Judgment of Mortgage Foreclosure; <i>U.S. Bank National Association v. Bradley J. [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2010CA002613AXXXCE
256	10/22/10	Certificate of Sale; <i>U.S. Bank National Association v. [REDACTED] J. Edwards</i> ; 17 th Judicial Circuit, Broward County Case No. 2010CA002613AXXXCE
257	11/2/10	Certificate of Title; <i>U.S. Bank National Association v. [REDACTED] J. Edwards</i> ; 17 th Judicial Circuit, Broward County Case No. 2010CA002613AXXXCE
258	Misc.	Docket and all court filings referenced therein; <i>Wells Fargo Bank, N.A. v. [REDACTED] J. [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2010CA012467AXXXCE
259	3/17/10	Petition/Complaint; <i>Wells Fargo Bank, N.A. v. Bradley J. [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2010CA012467AXXXCE
260	10/4/11	Final Summary Judgment of Mortgage Foreclosure; <i>Wells Fargo Bank, N.A. v. [REDACTED] J. [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2010CA012467AXXXCE
261	10/10/11	Notice of Sale; <i>Wells Fargo Bank, N.A. v. [REDACTED] J. [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2010CA012467AXXXCE

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
262	1/5/12	Certificate of Sale; <i>Wells Fargo Bank, N.A. v. J. [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2010CA012467AXXXCE
263	1/18/12	Certificate of Title; <i>Wells Fargo Bank, N.A. v. J. [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2010CA012467AXXXCE
264	Misc.	Docket and all court filings referenced therein; <i>Ist United Bank v. [REDACTED] J. [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 11-030427
265	12/8/11	Complaint; <i>Ist United Bank v. [REDACTED] J. [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 11-030427
266	1/25/12	Stipulation for Settlement; <i>Ist United Bank v. [REDACTED] J. [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 11-030427
267	Misc.	Docket and all court filings referenced therein; <i>Wells Fargo Bank, N.A. v. [REDACTED] Edwards</i> ; 17 th Judicial Circuit, Broward County Case No. 2012CC003827AXXXWE
268	3/22/12	Complaint; <i>Wells Fargo Bank, N.A. v. Bradley [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2012CC003827AXXXWE
269	5/18/12	[REDACTED] J. [REDACTED] Motion to Dismiss; <i>Wells Fargo Bank, N.A. v. Bradley Edwards</i> ; 17 th Judicial Circuit, Broward County Case No. 2012CC003827AXXXWE
270	10/3/12	Order Denying Motion to Dismiss; <i>Wells Fargo Bank, N.A. v. Bradley [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2012CC003827AXXXWE
271	10/26/12	Answer to Complaint; <i>Wells Fargo Bank, N.A. v. Bradley [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2012CC003827AXXXWE
272	11/20/12	Mediation Report; <i>Wells Fargo Bank, N.A. v. [REDACTED] [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2012CC003827AXXXWE
273	3/15/13	Mediation Report; <i>Wells Fargo Bank, N.A. v. [REDACTED] [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2012CC003827AXXXWE
274		Corporate Detail Printout from Sunbiz.org for The Law Office of Brad [REDACTED] & Associates, LLC

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
275	4/16/07	Articles of Organization for Florida Limited Liability Company for The Law Office of Brad [REDACTED] & Associates, LLC
276	1/25/08	2008 Limited Liability Company Annual Report for The Law Office of Brad [REDACTED] and Associates
277	3/11/09	2009 Limited Liability Company Annual Report for The Law Office of Brad [REDACTED] and Associates
278		Florida Bar Rules including, but not limited to, Florida Bar Rule 4-7.21
279	3/3/08	Complaint; <i>Donald D. Baker v. The City of Hollywood, et al.</i> ; Case No. 08-60294-CIV-HUCK (D.E. 1)
280	6/17/08	Omnibus Order on Defendants' Motion to Dismiss; <i>Donald D. Baker v. The City of Hollywood, et al.</i> ; Case No. 08-60294-CIV-HUCK (D.E. 79)
281	8/10/10	U.S. Court of Appeals Opinion; <i>Donald D. Baker v. City of Hollywood, et al.</i> ; Case No. 08-14924 & 08-15602
282	12/9/04	New Times Broward Palm-Beach: <i>Tale of the Tape</i>

.e s¶

283	10/20/17	Dr. Bernard J. Jansen's	c, R • en with
284	Misc.	All documents pro	o i lied upon or
		referenced by D Be	Jansen in preparing his
285	9/9/16	Expert Wi	Report of Dr. Bernard J. Jansen in
		Virginia Gt	. Ghislaine Maxwell (USDC NY)
286	11/30/16	Sup	enta Expert Witness Report of Dr. Bernard
		J.	in v. Ghislaine Maxwell
287	Misc.
		it t io
		o r r. Bernard J. Jansen

Other Articles¶

288	11/1/09	Kendall Coffey: Law Firm Victimized by Scott
289	11/2/09	Legal Junkies. WSJ Law Blog — Rothstein
290	11/2/09	New Times Broward-Palm Beach. ChiefJudge:

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
291	11/3/09	<u>The New York Times: Fraud Accusations Against Florida Lawyer Set Off a Race to Return His Donations</u>
292	11/3/09	<u>Rothstein Returns After Contemplating Suicide, Partner Says</u>
293	11/3/09	<u>Florida Law Firm Asks to be Dissolved</u>
294	11/3/09	<u>Sun Sentinel. Scott Rothstein's Investment Deals Seemed Too Good to be True</u>
295	11/5/09	<u>Funds News. FBI Agents Search Law Firm in Missing Funds Probe</u>
296	11/6/09	<u>New Times Broward-Palm Beach. Scott Rothstein: The Jeffrey Epstein and Bill Clinton Ploy</u>
297	11/6/09	<u>Rothstein Accomplice Still on Lam</u>
298	11/7/09	<u>Tour of Scott Rothstein's Office Reveals Gallery of Who's Who</u>
299	11/12/09	<u>Sun Sentinel: FBI Doubts Rothstein Ran a Ponzi Scheme Alone</u>
300	11/13/09	<u>Palm Beach Post: FBI Doubts Rothstein's Scheme a 'One-Man Show'</u>
301	11/13/09	<u>Sun Sentinel. High-Ranking Police Officers Guarded Over Rothstein</u>
302	11/17/09	<u>Inside the Rothstein Swindle, Part I</u>
303	11/17/09	<u>Sun Sentinel. Rothstein Asks to Voluntarily Give Up Law License</u>
304	11/17/09	<u>Rothstein and Dreier: How Much Alike?</u>
305	11/18/09	<u>Inside the Rothstein Swindle, Part II</u>
306	11/18/09	<u>Former RAA Attorneys Take New Jobs</u>
307	11/20/09	<u>Scherer Files Suit Against Rothstein, et al.</u>
308	11/20/09	<u>Article by Paul Brinkman</u>
309	11/21/09	<u>Rothstein Feeder [REDACTED] Levin's Ugly Past</u>
310	11/22/09	<u>George Levin was Rothstein's Whale</u>
311	11/23/09	<u>Rothstein Associate Levy Got Protection from Plantation Cops</u>
312	11/23/09	<u>Main Line Firm's Clients Invested $30 Million with 'Ponzi' Lawyer</u>
313	11/23/09	<u>Sun-Sentinel. Scott Rothstein: "You're in Town Full of Thieves</u>
314	11/24/09	<u>Miami Herald. Feds: Scott Rothstein Ponzi Scheme Paid Salaries at Law Firm</u>
315	11/26/09	<u>The Rothstein Wires</u>
316	1/13/10	<u>Sun Sentinel. Florida Bar Looking at 35 Former Attorneys from Rothstein's Firm</u>

No.	Date	Description Objection Marked
317	July 2010	Sun Sentinel. 22 Former Scott Rothstein Attorneys
318	10/22/10	South Florida Business Journal. A Year After
319	10/31/10	The Florida Bar. Scott Rothstein Scandal: One Year
320	1/21/13	Forbes. Rothstein Expose Details Sex, Murder, and
321	10/13/14	Five Years on, Rothstein's Ponzi Still Resonates
322	10/3/17	Palm Beach Daily News. Epstein Paid Three
323		All public records and news articles relating to
324		All court dockets and filings in all mat
		Jeffrey Epstein relating to any victi al
325		All prior testimony, statements, d
326		All charts/analyses prepared documents
327		All foundation exhili
328		All rebuttal and i exhibits
329		Demonstrative a an ibits including, but not
		limited to, charts, nes, diagrams, models,
		surveys, p phs and blow-ups
330		All newly IP - red documents/exhibits
		An d all ibits listed by J.
		wa ng is right to object to any of

PlaintifVC unter-Defendant reserves his right to supplement this Exhibit List.¶

nkrocklaw.com Scott J. Link (FBN 60299 Kara Berard Rockenbac 44903) Angela M. Many (Fr Primary: Scott®lin ock9tw.com Primary: Ka inkrocklaw.com Primary: Second Seco Eservice(alinkrocklaw.com¶

CERTIFICATE OF SERVICE¶

I certify that the foregoing document has been finished to the attorneys listed on the Service List below on November 16, 2017, through the Court's e-filing portal pursuant to Florida Rule of Judicial Administration 2.516(bX1).¶

LINK & ROCKENBACH, PA 1555 Palm Beach Lakes Boulevard, Suite 301 West Palm Beach, Florida 33401 (561) 727-3600; (561) 727-3601 [fax]

¶

By. Is/ Scott J. Link¶

(SS E Counsel for Plaintiff7Counter-Defendant law ffrey Epstein¶

s¶

Gs'¶

SERVICE LIST¶

<p>Jack Scarola Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 <a href="mailto:mep@searcylaw.com">mep@searcylaw.com</a> <a href="mailto:jsx@searcylaw.com">jsx@searcylaw.com</a> <a href="mailto:scarolateam@searcylaw.com">scarolateam@searcylaw.com</a> <i>Co-Counsel for Defendant/Counter-Plaintiff</i></p> <p style="text-align: center;"><b>J. [REDACTED]</b></p>	<p>Nichole J. Segal Burlington & Rockenbach, P.A. Courthouse Commons, Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 <a href="mailto:njs@FLAppellateLaw.com">njs@FLAppellateLaw.com</a> <a href="mailto:kbt@FLAppellateLaw.com">kbt@FLAppellateLaw.com</a> <i>Co-Counsel for Defendant/Counter-Plaintiff</i></p> <p style="text-align: center;"><b>J. [REDACTED]</b></p>
<p><b>J. [REDACTED]</b> Pottinger LLC 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 <a href="mailto:brad@epllc.com">brad@epllc.com</a> <a href="mailto:staff.efile@pathtojustice.com">staff.efile@pathtojustice.com</a> <i>Co-Counsel for Defendant/Counter-Plaintiff</i></p> <p style="text-align: center;"><b>J. [REDACTED]</b></p>	<p>Marc S. Nurik Law Offices of Marc S. Nurik One E. Broward Boulevard, Suite 700 Ft. Lauderdale, FL 33301 <a href="mailto:marc@nuriklaw.com">marc@nuriklaw.com</a> <i>Counsel for Defendant Scott Rothstein</i></p>
<p>Tonja Haddad Coleman 315 S.E. Seventh Street, Suite 301 Ft. Lauderdale, FL 33301 <a href="mailto:tonja@tonjahaddad.com">tonja@tonjahaddad.com</a> <a href="mailto:efiling@tonjahaddad.com">efiling@tonjahaddad.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i></p> <p style="text-align: center;"><i>Jeffrey Epstein</i></p>	<p>Fred Haddad Haddad & Navarro, PLLC 1 Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 <a href="mailto:dee@haddadandnavarrolaw.com">dee@haddadandnavarrolaw.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i></p> <p style="text-align: center;"><i>Jeffrey Epstein</i></p>
<p>Jack A. Goldberger Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 <a href="mailto:jgoldberger@agwpa.com">jgoldberger@agwpa.com</a> <a href="mailto:smahoney@agwpa.com">smahoney@agwpa.com</a> <i>Co-Counsel for Plaintiff/Counter-Defendant</i></p> <p style="text-align: center;"><i>Jeffrey Epstein</i></p>

EXHIBIT N¶

NOT A CERTIFIED COPY¶

VIA HAND DELIVERY¶

Jack Scarola¶

Searcy, Denney, Scarola, Barnhart & Shipley, P.A.¶

2139 Palm Beach Lakes Blvd.¶

West Palm Beach, FL 33409¶

RE: Jeffrey Epstein v. Scott Rothstein and Bradley J. Edwards 158i Judicial Circuit Case No. 50-2009CA040800XXXXMBAG¶

Dear Jack:¶

December 19, 2017¶

Pursuant to the Court's Order on Mr. Edwards' Motion to Compel Payment of Deposition Expenses, I am enclosing our firm's check in the amount of $400 payable to Searcy, Denny.¶

In addition, with regard to our exhibits, ram enclosing a flash drive of those documents identified on our November 16, 2017, Amended Exhibit List. In light of the Court's recent rulings, we anticipate amending our Exhibit List after we have had an opportunity to review Mr. Epstein's former counsels' files.¶

Should you have any questions, please do not hesitate to contact me.¶

Si¶

Scott¶

SJUtic¶

Enclosure¶

EXHIBIT O¶

NOT A CERTIFIED COPY¶

¶

VIA HAND DELIVERY¶

Jack Scarola Searcy, Denney, Scarola, Bamhart & Shipley, P.A. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 isxfasearcvlaw.com¶

RE: Jeffrey Epstein v. Scott Rothstein and 411e J. Edwards . . 15th Judicial Circuit Case No. 50- 009.dA040800XXXXMBAG

¶

Dear Jack:¶

February 2, 2018¶

1555 Palm Beach Lakes Blvd., Suite 301 West Palm Beach, FL 33401 TEL (561) 727-3600 I FAX (561) 727-3601¶

oes¶

I am enclosing a flash drive coutainin additional documents for our trial Exhibit Nos. 18, 35, 48, 323, and 324. We are still obtaining additional public records and will provide those to you upon our receipt.¶

ricS"¶

Enclosure SJL/tIc¶

•¶

Scott J. Link¶

From: To: lark °tarok; David P. Wale 3z • lyadeleoliccom• otajilawalataayagra Cc 'Mary McCann"- tgraberlv MAKI).Kra Berard Rnrkenharn• scgtuajok; flirts R. Ibvierert sawn Bcc: Subject: Epstein v. Date: Friday, February 16, 2018 1:55:00 PM Attachments: 323 A-10 Supo.pdf 321,945_5uppodf 323 A-26 Sup)Odf 323_8:31_5uPOOdf 323 A-34 Suno.pdf 323_&35_5upp.pdf 323 6-36 SuCOOdf 3233-31_5u011,COf 323 323_CAl_Supp,pdf C-35 Sup0.Pdf¶

sistir¶

I am attaching supplemental public record Trial Exhibits for Ex. 323.¶

Thank you.¶

Tina CP/FRP Certified Paralegal¶

LINK 8 ROCKENBACH, PA 1555 Palm Beach Lakes Blvd., Suite 301 West Palm Beach, FL 33401 office (561) 727-3600 I fax (561) 727-3601 1 Email:¶

This e-mail may contain privileged or confidential in immediately. Please confirm receipt of time sensitiv unsuccessful. We do not provide tax advice. Our imposed by the Internal Revenue Service. it is not meant for you, please delete it and notify us ns because email deliveries may be delayed or ons may not be relied upon to avoid penalties that may be From: rata To: ;ark Scarola; David P. Vitale 1. atafiteppellatelait=0; Dradeeortc corn Cc: lark finldher0er Stott 1. / Kaalitiadlicsientath; MAN Ma00; Kimberly Marsh Bcc: Subject: Epstein v. - Trial Exhibits Date: Friday, March 2, 2018 7:13:00 PM¶

I am attaching additional trial exhibits from our general categories at the following link:¶

We will be supplying our Clerk's Exhibit List shortly.¶

Thank you¶

Tina CP/FRP Certified Paralegal¶

LINK & ROCKENBACH, PA 1555 Palm Beach Lakes Blvd., Suite 301 West Palm Beach. FL 33401 office (561) 727-3600 I fax (561) 727-36011 Email: tna@Jin¶

This e-mail may contain privileged or confidential information. I 14/ iii meant for you, please delete it and notify us immediately. Please confirm receipt of time sensitive comm " ns use email deliveries may be delayed or unsuccessful. We do not provide tax advice. Our commu lions not be relied upon to avoid penalties that may be imposed by the Internal Revenue Service.¶

EXHIBIT P¶

NOT A CERTIFIED COPY¶

From: To: ace: Subject: Epstein v. - Fre-marking Exhibits Date: Thursday, February 22, 2018 5:36:00 FM¶

Hi Chris,¶

We are in the process of pre-marking our exhibits in accordance with the Court's pre-marking guidelines. We wanted to let you know that we are marking our exhibits with "Plaintiff" stickers. In addition, we will be sending an updated and specific list identifying the items individually s required by the guidelines. We ask that your office do the same. O4¶

Thank you.¶

Tina Certified Paralegal CP/FRP¶

LINK 8 ROCKENBACH, PA 1555 Palm Beach Lakes Blvd., Suite 301 West Palm Beach. FL 33401 office (561) 727-3600 I fax (561) 727-3601 I Email: Gcc¶

This e-mail may contain privileged or confidential i immediately. Please confirm receipt of time se unsuccessful. We do not provide tax advice. imposed by the Internal Revenue Servicu.s on.. If it is not meant for you, please delete it and notify us munications because email deliveries may be delayed or cations may not be relied upon to avoid penalties that may be¶

6 S 17ilit¶

EXHIBIT Q¶

NOT A CERTIFIED COPY¶

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

Case No. 50-2009CA040800XXXXMBAG¶

JEFFREY EPSTEIN,¶

Plaintiff/Counter-Defendant,¶

v.¶

SCOTT ROTHSTEIN individually, and J. individually,¶

Defendants/Counter-Plaintiff.¶

PLAINTIFF/COUNTER-DEFEND CLERK'S TRIAL Y EPSTEIN'S 1ST¶

Plaintiff'Counter-Defendant Jeffrey E July 20, 2017, Order Specially Setting T Lists, (2) the parties' December 22, 2 not waive their right to amend th exhibits which require each e uant to (1) paragraph G of the Court's ng the parties to agree to amend their Exhibit retrial Stipulation which provided the parties did Lists, and (3) the Clerk's guidelines on pre-marking identified individually, hereby files this Clerk's Trial Exhibit List to set forth i *vidual y those items previously contained in general categories.¶

Cos¶

INDEX TO OBJECTIONS¶

• O. No ObjecCSS
• 1. All o
• 2. All ob tions, except authenticity
• 3. Irrelevant or immaterial
• 4. Probative value substantially outweighed by danger of unfair prejudice, confusion of issues, misleading the jury, or needless presentation of cumulative evidence
• 5. Privileged
• 6. Opinion
• 7. Hearsay
• 8. Authenticity lacking
• 9. Other (please identify basis of objection)

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
<b><i>Jeffrey Epstein v. Scott Rothstein, [REDACTED] J. [REDACTED] and L.M.</i> 15th Judicial Circuit Case No. 50-2009-CA-040800XXXXMB</b>
1	12/7/09	Complaint with Exhibits
2	12/21/09	Answer and Counterclaim of Defendant [REDACTED] J. [REDACTED]
3	1/21/10	Default against Scott Rothstein
4	8/2/10 8/9/10	Stipulation and Order of Dismissal with Prejudice as to L.M., Individually Only
5	3/27/12	Notice of Appearance of [REDACTED] J. [REDACTED]
6	8/16/12	Notice of Voluntary Dismissal Without Prejudice of [REDACTED] J. [REDACTED]
7	1/9/13	[REDACTED] J. [REDACTED] Fourth Amended Counterclaim
8	9/25/13	Affidavit of Jeffrey Epstein
9	6/30/17	Affidavit of Jeffrey Epstein
10	6/30/17	Jeffrey Epstein's Motion for Summary Judgment
10-1	N/D	Index of Appendix Items to Jeffrey Epstein's Motion for Summary Judgment
10A	1/9/13	Fourth Amended Counterclaim - <i>Jeffrey Epstein v. Scott Rothstein, et al.</i> , 15 th Judicial Circuit Case No. 50-2009-CA-040800XXXXMB
10B	7/31/12	Epstein's Answer and Affirmative Defenses to [REDACTED] Counterclaim - <i>Jeffrey Epstein v. Scott Rothstein, et al.</i> , 15 th Judicial Circuit Case No. 50-2009-CA-040800XXXXMB
10C	3/23/10	Transcript of Deposition of [REDACTED] J. [REDACTED] - <i>Jeffrey Epstein v. Scott Rothstein, et al.</i> , 15 th Judicial Circuit Case No. 50-2009-CA-040800XXXXMB
10D	12/12/11	Excerpts of Transcript of Rule 2004 Examination of Scott W. Rothstein - <i>In re Rothstein Rosenfeldt Adler, P.A.</i> , USDC S.D. Florida Case No. 09-34791
10F	12/1/09	Information - <i>United States of America v. Scott W. Rothstein</i>
10G	N/D	Court Docket - <i>L.M. v. Jeffrey Epstein</i> , 15 th Judicial Circuit Case No. 50-2008-CA-028051-XXXX-MB
10H	N/D	Court Docket - <i>E.W. v. Jeffrey Epstein</i> , 15 th Judicial Circuit Case No. 50-2008-CA-028058-XXXX-MB

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
101-1	6/19/09	Jane Doe's Motion for Injunction Restraining Fraudulent Transfer of Assets, Appointment of Receiver to Take Charge of Property of Epstein and to Post a $15 Million Bond to Secure Potential Judgment – <i>Jane Doe No. 2 v. Jeffrey Epstein (consolidated action)</i> , USDC S.D. Florida Case No. 08-CV-80119-Marra/
101-2	7/22/09	Letter from [REDACTED] J. [REDACTED] to Adam D. Horowitz, Stuart S. Mermelstein, Isidro Manuel [REDACTED], Jeffrey Marc Herman, Katherine Ezell, Robert C. Josefsberg and Jack [REDACTED]
101-3	7/23/09	Jane Doe's Reply Memorandum in Support of Motion for Injunction Restraining Fraudulent Transfer of Assets, Appointment of a Receiver to Take Charge of Property of Epstein and to Post a $15 Million Bond to Secure Potential Judgment – <i>Jane Doe No. 2 v. Jeffrey Epstein (consolidated action)</i> , USDC S.D. Florida Case No. 08-CV-80119-Marra/
101-4	10/16/09	Jane Doe's Notice That Additional Evidence of Epstein's Fraudulent Asset Transfers Will be Filed Shortly and Motion for Consideration by the Court of Materials in Docket Numbers 282 and 283 in Determining Motion for Appointment of a Receiver Restraining Fraudulent Assets Transfers and Incorporated Memorandum of Law – <i>Jane Doe v. Jeffrey Epstein</i> , USDC S.D. Florida Case No. 08-CV-80893
101-5	N/D	Court Docket – <i>Jane Doe v. Jeffrey Epstein</i> , USDC S.D. Florida Case No. 08-CV-80893
10J	3/17/10	Transcript of Deposition of Jeffrey Epstein - <i>Jeffrey Epstein v. Scott Rothstein, et al.</i> , 15 th Judicial Circuit Case No. 50-2009-CA-040800XXXXMB
10K	11/09	Amended Complaint (without exhibits) – <i>Razorback Funding, LLC, et al. v. Scott W. Rothstein, et al.</i> , 17 th Judicial Circuit Case No. 09-062943
10L-1	11/1/10	<u>The Florida Bar Daily News Summary</u>
10L-2	10/22/10	<u>South Florida Business Journal – A Year After Rothstein, Many Questions Unanswered</u>
10L-3	1/13/10	<u>Sun-Sentinel – Florida Bar Looking at 35 Former Lawyers from Rothstein's Firm</u>

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
10L-4	7/10	<u>Sun-Sentinel</u> – <i>Latest Rothstein Updates</i> – 22 <i>Former Scott Rothstein Attorneys Cleared by The Florida Bar</i>
10M-1	7/22/09	Letter from [REDACTED] J. [REDACTED] to Adam D. Horowitz, Stuart S. Mermelstein, Isidro Manuel [REDACTED], Jeffrey Marc Herman, Katherine Ezell, Robert C. Josefsberg and Jack [REDACTED]
10M-2	10/22/09	Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action – <i>Jane Doe v. Jeffrey Epstein</i> , USDC S.D. Florida Case No. 08-CV-80893
10N-1	7/28/09	Notice of Taking Video Deposition of Leslie Wexler and Subpoena – <i>Jane Doe v. Jeffrey Epstein</i> , USDC S.D. Florida Case No. 08-CV-80893
10N-2	7/28/09	Notice of Taking Videotaped Deposition of Glenn [REDACTED] [REDACTED] and Subpoena – <i>Jane Doe v. Jeffrey Epstein</i> , USDC S.D. Florida Case No. 08-CV-80893
10N-3	7/28/09	Notice of Taking Videotaped Deposition of Ghislane Noelle Maxwell and Subpoena – <i>Jane Doe v. Jeffrey Epstein</i> , USDC S.D. Florida Case No. 08-CV-80893
10N-4	8/11/09	Notice of Taking Videotaped Deposition of Jean Luc Bruhel and Subpoena – <i>Jane Doe v. Jeffrey Epstein</i> , USDC S.D. Florida Case No. 08-CV-80893
10N-5	8/11/09	Notice of Taking Videotaped Deposition of Nadia Marcinkova and Subpoena – <i>Jane Doe v. Jeffrey Epstein</i> , USDC S.D. Florida Case No. 08-CV-80893
10N-6	8/11/09	Notice of Taking Videotaped Deposition of Mark Ep [REDACTED] and Subpoena – <i>Jane Doe v. Jeffrey Epstein</i> , USDC S.D. Florida Case No. 08-CV-80893
10N-7	8/11/09	Re-Notice of Taking Videotaped Deposition of Ghislane Noelle Maxwell – <i>Jane Doe v. Jeffrey Epstein</i> , USDC S.D. Florida Case No. 08-CV-80893
10N-8	8/10/09	Re-Notice of Taking Videotaped Deposition of Donald Trump – <i>Jane Doe v. Jeffrey Epstein</i> , USDC S.D. Florida Case No. 08-CV-80893

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
10N-9	8/24/09	Re-Notice of Taking Videotaped Deposition of Donald Trump – <i>Jane Doe v. Jeffrey Epstein</i> , USDC S.D. Florida Case No. 08-CV-80893
10N-10	9/2/09	Re-Notice of Taking Videotaped Deposition of [REDACTED] – <i>Jane Doe v. Jeffrey Epstein</i> , USDC S.D. Florida Case No. 08-CV-80893
10N-11	9/2/09	Re-Notice of Taking Videotaped Deposition of [REDACTED] – <i>Jane Doe v. Jeffrey Epstein</i> , USDC S.D. Florida Case No. 08-CV-80893
10N-12	10/16/09	Re-Notice of Taking Videotaped Deposition of Ghislane Noelle Maxwell – <i>Jane Doe v. Jeffrey Epstein</i> , USDC S.D. Florida Case No. 08-CV-80893
10N-13	10/22/09	Subpoena to Testify at Deposition to Michael [REDACTED] – <i>Jane Doe v. Jeffrey Epstein</i> , USDC S.D. Florida Case No. 08-CV-80893
10N-14	10/22/09	Subpoena to Testify at Deposition to Michael Sanka – <i>Jane Doe v. Jeffrey Epstein</i> , USDC S.D. Florida Case No. 08-CV-80893
10O	12/7/09	Complaint (without exhibits) - <i>Jeffrey Epstein v. Scott Rothstein, et al.</i> , 15 th Judicial Circuit Case No. 50-2009-CA-040800XXXXMB
10P	1/25/10	Plea Agreement – <i>United States of America v. Scott W. Rothstein</i> , USDC S.D. Fla. Case No. 09-60331-CR-COHN
10Q	2/23/11	Privilege Log of Farmer, Jaffe, Weissing, [REDACTED], Fistos & Lehrman
10R	N/D	Brad Edwards Privilege Log of Emails Dated November 2009 to August 2010
10S	Misc.	Documents Produced Responsive to Order (individual items identified separately below)
10T	7/24/09	Complaint – <i>L.M. v. Jeffrey Epstein</i> , USDC S.D. Fla. Case No. 09-CV-81092-Cohn-Seltzer
10U	11/5/09	Order - <i>Jane Doe No. 2 v. Jeffrey Epstein (consolidated action)</i> , USDC S.D. Florida Case No. 08-CV-80119-Marra/[REDACTED]
10V	7/29/09	Email from Cara L. [REDACTED] to [REDACTED] J. [REDACTED] (08420)
10W	12/12/11	Excerpt of Transcript of Deposition of Scott Rothstein – <i>Razorback Funding, LLC, et al. v. Scott W. Rothstein, et al.</i> , 17 th Judicial Circuit Case No. 09-062943
10X	9/25/13	Affidavit of Jeffrey Epstein

No.	Date		Description Objection Marked
11A-1	3/23/10	Deposition Transcript of	J.
11A-2	5/15/13	Deposition Transcript of	J. with
		15ih	Judicial Circuit Case No. 50-2009-CA
11A-3	10/10/13	Deposition Transcript of	J. (Ex. 1
		a at, 15th	Judicial Circuit Case No. 50-2009-CA
11A-3a	10/9/08	Letter from Brad	to Dexter Lee
11A-3b	10/15/08	Letter from Brad	to Dexter Le
11A-3c	7/17/08	Letter from Brad	to Ann Ma aAna
11A-3d	7/3/08	Letter from Brad	to Ann
11A-3e	6/7/07	Letter from A.	Villa
11A-3f	8/11/06	Letter from A.	Villa L.M.
11A-3g	1/10/08	Letter from T.	t
11A-3h	1/10/08	Letter from T. Smi	Eisenberg
11A-3i	5/30/08	Letter from T. S t	o e Doe
11A-3j	7/9/08	Letter from A	an lafana to Brad
IIA-3k	7/9/08	Letter from A.	' Villafana to Brad
11A-31	3/20/11	Letter f	R. Alexander Acosta to "To Whom it
11A-3m	12/10/10	r fro	J. and Paul Cassell to
		t o A. Ferrer
11A-3n	3/22/11	i tte from	J. and Paul Cassell to
11A-3o		tter from	J. and Paul Cassell to
11A-3p	3/15/ 1		Letter from Wifredo A. Ferrer to Paul Caccell
11A-3q	10/9/08	Letter from Brad	to Dexter Lee
11A-3r	9/29/11		Letter from Paul Cassell to Wifredo Ferrer
11A-3s	7/17/08	Letter from Brad	to Ann C.
11A-3t	7/3/08	Letter from Brad	to Ann C.
11A-3u	10/15/08	Letter from Brad	to Dexter Lee

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
11A-4	11/10/17	Deposition Transcript of [REDACTED] J. [REDACTED] - <i>Jeffrey Epstein v. Scott Rothstein, et al.</i> , 15 th Judicial Circuit Case No. 50-2009-CA-040800XXXXMB (individual exhibits identified below)
11B-1	3/17/10	Deposition Transcript of Jeffrey Epstein - <i>Jeffrey Epstein v. Scott Rothstein, et al.</i> , 15 th Judicial Circuit Case No. 50-2009-CA-040800XXXXMB
11B-2	1/25/12	Deposition Transcript of Jeffrey Epstein - <i>Jeffrey Epstein v. Scott Rothstein, et al.</i> , 15 th Judicial Circuit Case No. 50-2009-CA-040800XXXXMB (individual exhibit identified below)
11C	6/14/12	Deposition Transcript of Scott Rothstein - <i>Jeffrey Epstein v. Scott Rothstein, et al.</i> , 15 th Judicial Circuit Case No. 50-2009-CA-040800XXXXMB (individual exhibits identified below)
11D	4/20/11	Deposition Transcript of [REDACTED] S. Adler - <i>Jeffrey Epstein v. Scott Rothstein, et al.</i> , 15 th Judicial Circuit Case No. 50-2009-CA-040800XXXXMB
11E	5/25/11	Deposition Transcript of Abraxas [REDACTED] Discala with exhibits - <i>Jeffrey Epstein v. Scott Rothstein, et al.</i> , 15 th Judicial Circuit Case No. 50-2009-CA-040800XXXXMB
11F	2/11/11	Deposition Transcript of Dean [REDACTED] Kretschmar - <i>Jeffrey Epstein v. Scott Rothstein, et al.</i> , 15 th Judicial Circuit Case No. 50-2009-CA-040800XXXXMB
11G	3/11/11	Deposition Transcript of Michael Legamaro - <i>Jeffrey Epstein v. Scott Rothstein, et al.</i> , 15 th Judicial Circuit Case No. 50-2009-CA-040800XXXXMB
11H	10/12/17	Deposition Transcript of E.W. - <i>Jeffrey Epstein v. Scott Rothstein, et al.</i> , 15 th Judicial Circuit Case No. 50-2009-CA-040800XXXXMB (exhibits listed as follows)
11H-1	8/7/07 8/14/07	FBI Report – E.W.
11I	12/1/17	Deposition Transcript of Bernard Jansen - <i>Jeffrey Epstein v. Scott Rothstein, et al.</i> , 15 th Judicial Circuit Case No. 50-2009-CA-040800XXXXMB
11J	2/23/18	Deposition Transcript of William Berger - - <i>Jeffrey Epstein v. Scott Rothstein, et al.</i> , 15 th Judicial Circuit Case No. 50-2009-CA-040800XXXXMB

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
12A	12/4/10	Epstein's Request to Produce to [REDACTED]
12B	5/11/10	[REDACTED] Answers to Plaintiff's First Set of Interrogatories
12C	5/11/10	[REDACTED] Response to Plaintiff's Request for Production
12D	6/21/10	Epstein's Request for Admissions to [REDACTED]
12E	7/7/10	[REDACTED] Response to First Request for Admissions
12F	4/7/11	Epstein's Request for Production to [REDACTED]
12G	5/5/11	[REDACTED] Response to Epstein's Request to Produce dated April 7, 2011
12H	5/16/11	Epstein's Interrogatories to [REDACTED]
12I	6/10/11	[REDACTED] Answers to Interrogatories
12J	12/9/11	Epstein's Second Request for Production to [REDACTED]
12K	6/1/12	[REDACTED] Answers to Epstein's Third Set of Interrogatories
12L	6/1/12	[REDACTED] Response to Request for Production
12M	2/21/13	[REDACTED] Supplemental Response to Epstein's Request for Production dated December 9, 2011
12N	7/25/13	[REDACTED] Response to Epstein's Request for Production dated June 25, 2013
12O	8/11/17	[REDACTED] Answers to Interrogatories
12P	9/5/17	Epstein's Request for Production to [REDACTED]
12Q	10/5/17	[REDACTED] Answers to Epstein's September 5, 2017, Interrogatories
12R	10/5/17	[REDACTED] Response to Epstein's September 5, 2017, Request for Production
12S	10/13/17	Epstein's Request to Produce to [REDACTED]
12T	10/13/17	Epstein's Expert Interrogatories to [REDACTED]
12U	11/13/17	[REDACTED] Answers to Epstein's Expert Interrogatories
12V	11/13/17	[REDACTED] Response to Epstein's Request to Produce re Experts
12W	N/D	[REDACTED] Privilege Log – Emails November 2009 to August 2010
13	Misc.	All documents produced by any party or non-party in this matter
13-1	4/9/09 3:50 p.m.	E-mail chain – from [REDACTED] J. [REDACTED] to [REDACTED] Adler (02645)
13-2	4/22/09 9:14 a.m.	E-mail chain - from [REDACTED] Adler to [REDACTED] J. [REDACTED] (03037)

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
13-3	4/24/09 11:39 a.m.	E-mail chain - from █ Adler to Steven Jaffe, █, William Berger, Barry █, Scott Rothstein, Marc Nurik, Carl Linder and Robert Buschel (03036)
13-4	4/26/09 7:35 p.m.	E-mail chain - from Radler to █ (00149)
13-5	4/27/09 2:16 p.m.	E-mail chain - from █ to Marc Nurik (01527)
13-6	4/28/09 6:17 p.m.	E-mail chain - from █ to Katherine Ezell (4493-4495)
13-7	5/1/09 5:23 p.m.	E-mail chain - from Rob to █ (00014)
13-8	5/13/09 1:20 p.m.	E-mail chain - from █ to William Berger (03988-04000)
13-9	5/20/09 9:58 a.m.	E-mail chain - from █ to William Berger (02231)
13-10	5/21/09 3:13 p.m.	E-mail chain - from William Berger to Bradley █ and Susan Stirling (01300)
13-11	5/28/09 5:45 p.m.	E-mail chain - from William Berger to █ (00090)
13-12	5/29/09 5:15 p.m.	E-mail chain - from Eric Glasser to Bradley █ (2906-2908)
13-13	6/3/09 11:47 a.m.	E-mail chain - from Paul Cassell to █ (00133)
13-14	6/3/09 5:04 p.m.	E-mail chain - from █ to Wayne Black (11237)
13-15	6/3/09 6:24 p.m.	E-mail chain - from Wayne Black to █ (08006)
13-16	7/8/09 12:33 p.m.	E-mail chain - from █ to Paul Cassell (07304)
13-17	7/13/09 2:13 p.m.	E-mail chain - from Paul Cassell to █ (00026)
13-18	7/13/09 3:20 p.m.	E-mail chain - from █ to Paul Cassell (01464)
13-19	7/14/09 2:06 p.m.	E-mail chain - from █ to William Berger (01004)
13-20	7/20/09 8:32 a.m.	E-mail chain - from █ to William Berger (01403)
13-21	7/20/09 10:45 a.m.	E-mail chain - from █ to █ (02684-02685)
13-22	7/20/09 1:27 p.m.	E-mail chain - from █ to William Berger (01475)

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
13-23	7/31/09 3:40 p.m.	E-mail chain - from Jacquie [REDACTED] to [REDACTED] [REDACTED] (05087)
13-24	8/2/09 1:15 p.m.	E-mail chain - from [REDACTED] [REDACTED] to William Berger (03694)
13-25	8/3/09 11:17 a.m.	E-mail chain – from Beth to Carl Linder (12289)
13-26	8/3/09 7:37 p.m.	E-mail chain - from [REDACTED] [REDACTED] to [REDACTED] [REDACTED] (01166)
13-27	8/6/09 2:21 p.m.	E-mail chain – from [REDACTED] [REDACTED] to William Berger (01258)
13-28	8/10/09 5:44 p.m.	E-mail chain - from [REDACTED] [REDACTED] to Jacquie [REDACTED] (15113-15114)
13-29	8/10/09 5:56 p.m.	E-mail chain - from [REDACTED] [REDACTED] to Jacquie [REDACTED] (00158)
13-30	8/11/09 9:26 p.m.	E-mail chain - from Marc Nurik to Scott Rothstein (26481)
13-31	8/12/09 9:43 a.m.	E-mail chain - from Priscilla Nascimento to Scott Rothstein (26394)
13-32	8/13/09 9:48 a.m.	E-mail chain - from [REDACTED] Edwards to Priscila Nascimento (08412)
13-33	8/13/09 9:51 a.m.	E-mail chain - from Priscilla Nascimento to Scott Rothstein (25922)
13-34	8/13/09 4:51 p.m.	E-mail chain - from Marc Nurik to Scott Rothstein (26480)
13-35	8/13/09 5:31 p.m.	E-mail chain - from Russell Adler to Scott Rothstein (26356)
13-36	8/13/09 6:02 p.m.	E-mail chain - from Marc Nurik to Scott Rothstein (26570)
13-37	8/21/09 4:33 p.m.	E-mail chain - from [REDACTED] [REDACTED] to Jacquie Johnson (00992)
13-38	8/24/09 7:46 p.m.	E-mail chain - from Mike Fisten to [REDACTED] Edwards, Ken Jenne, Cara [REDACTED] and Pat [REDACTED] (05113)
13-39	8/24/09 9:50 p.m.	E-mail chain - from Ken Jenne to [REDACTED] [REDACTED], Mike Fisten, Cara [REDACTED] and Pat [REDACTED] (05112)
13-40	8/24/09 10:44 p.m.	E-mail chain - from [REDACTED] [REDACTED] to William Berger (01423)
13-41	8/25/09 8:58 a.m.	E-mail chain – from William Berger to [REDACTED] [REDACTED] (05071)
13-42	8/26/09 5:23 p.m.	E-mail chain - from Jacquie [REDACTED] to [REDACTED] [REDACTED] (01406)

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
13-43	9/4/09 11:18 a.m.	E-mail chain - from █ █ █ █ █ to Paul Cassell and William Berger (02043)
13-44	9/4/09 6:59 p.m.	E-mail chain - from █ █ █ █ █ to Spencer Kuvin (03731-03732)
13-45	9/10/09 9:48 a.m.	E-mail chain - from █ █ █ █ █ to redrum (06406-06408)
13-46	9/11/09 6:06 p.m.	E-mail chain - from █ █ █ █ █ to Mike Fisten (01686)
13-47	9/17/09 8:35 a.m.	E-mail chain - from █ █ █ █ █ to █ █ █ █ █
13-48	9/17/09 12:11 p.m.	E-mail chain - from █ █ █ █ █ J. █ █ █ █ █ to William Berger (02088)
13-49	9/19/09 7:54 a.m.	E-mail chain - from █ █ █ █ █ █ █ to █ █ █ █ █
13-50	9/19/09 10:01 p.m.	E-mail chain - from █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █
13-51	9/23/09 12:12 p.m.	E-mail chain - from █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █
13-52	9/30/09 3:35 p.m.	E-mail chain - from Robin T. Kempner to All Staff (25925)
13-53	9/30/09 3:51 p.m.	E-mail chain - from Robin T. Kempner to All Staff (25874)
13-54	10/1/09 1:24 p.m.	E-mail chain - from Jacquie Johnson to █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █
13-55	10/1/09 1:30 p.m.	E-mail chain - from Jacquie █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █
13-56	10/5/09 7:16 a.m.	E-mail chain - from █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █
13-57	10/6/09 11:14 a.m.	E-mail chain - from Scott Rothstein to A.J. Discala
13-58	10/13/09 4:02 p.m.	E-mail chain - from Scott Rothstein to A.J. Discala (26094-26096)
13-59	10/13/09 5:38 p.m.	E-mail chain - from Scott Rothstein to A.J. Discala (26826-26827)
13-60	10/14/09 7:36 a.m.	E-mail chain - from █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █
13-61	10/14/09 9:13 a.m.	E-mail chain - from A.J. Discala to Scott Rothstein (27284)
13-62	10/15/09 6:35 p.m.	E-mail chain - from Scott Rothstein to A.J. Discala and █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █ █
13-63	10/15/09 8:59 p.m.	E-mail chain - from A.J. Discala to Scott Rothstein, D. Von Allmen (26882)

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
13-64	10/16/09 11:00 a.m.	E-mail chain - from Michael Wheeler to Mike Fisten, [REDACTED] and Pat [REDACTED] (01255)
13-65	10/16/09 3:03 p.m.	E-mail chain - from Scott Rothstein to A.J. Discala, [REDACTED] Preve and [REDACTED] Kretschmar (26836-26837)
13-66	10/17/09 1:00 p.m.	E-mail chain - from [REDACTED] [REDACTED] to Paul Cassell (04398-04402)
13-67	10/17/09 1:58 p.m.	E-mail chain - from [REDACTED] [REDACTED] to Paul Cassel (04408-04412)
13-68	10/17/09 4:30 p.m.	E-mail chain - from Scott Rothstein to A.J. Discala (26807)
13-69	10/17/09 4:36 p.m.	E-mail chain - from Scott Rothstein to A.J. Discala (26808-26809)
13-70	10/18/09 2:41 p.m.	E-mail chain - from Scott Rothstein to A.J. Discala (27379)
13-71	10/19/09 10:53 a.m.	E-mail chain - A.J. Discala to Scott Rothstein and [REDACTED] Kretschmar (27293)
13-72	10/19/09 2:27 p.m.	E-mail chain - from Ken Jenne to Scott Rothstein (26021 with attachment)
13-73	10/19/09 4:32 p.m.	E-mail chain - from A.J. Discala to Scott Rothstein, [REDACTED] Preve, D. Von Allmen and [REDACTED] Kretschmar (27270)
13-74	10/20/09 8:33 a.m.	E-mail chain - from A.J. Discala to Scott Rothstein (27355)
13-75	10/20/09 12:52 p.m.	E-mail chain - from Scott Rothstein to [REDACTED] Preve (27325)
13-76	10/20/09 12:41 p.m.	E-mail chain - from Scott Rothstein to [REDACTED] Preve (27303)
13-77	10/20/09 12:53 p.m.	E-mail chain - from Scott Rothstein to Chris Podaras (27322)
13-78	10/20/09 5:02 p.m.	E-mail chain - from [REDACTED] Podaras to Scott Rothstein, [REDACTED] Kretschmar, A.J. Discala and Frank Prieve (26777-26781)
13-79	10/20/09 5:04 p.m.	E-mail chain - from Scott Rothstein to [REDACTED] Podaras, [REDACTED] Kretschmar, A.J. Discala and Prieve (26782-26786)
13-80	10/21/09 11:35 a.m.	E-mail chain - from Scott Rothstein to A.J. Discala and [REDACTED] Podaras (26088-26089)
13-81	10/21/09 2:59 p.m.	E-mail chain - from Ken Jenne to Scott Rothstein (25998)
13-82	10/22/09 11:17 a.m.	E-mail chain - from Scott Rothstein to A.J. Discala, [REDACTED] Podaras and [REDACTED] Kretschmar (26817-26818)

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
13-83	10/22/09 1:24 p.m.	E-mail chain – from A.J. Discala to Scott Rothstein, [REDACTED] Podaras and [REDACTED] Kretschmar (27072)
13-84	10/22/09 1:48 p.m.	E-mail chain - from [REDACTED] [REDACTED] to Jacquie [REDACTED] (04996)
13-85	10/22/09 2:47 p.m.	E-mail chain – from [REDACTED] Podaras to Thane Ritchie, Scott Rothstein, A.J. Discala and [REDACTED] Kretschmar (Legamaro Depo. Ex. 6)
13-86	10/23/09 11:37 a.m.	E-mail chain – from Matthew Weissing to Mark Fistos, [REDACTED] Adler, [REDACTED] [REDACTED], Scott Rothstein and Steven Jaffee (26747)
13-87	10/23/09 11:40 a.m.	E-mail chain - from Ken Jenne to Scott Rothstein (26477)
13-88	10/23/09 12:11 p.m.	E-mail chain – from Matthew Weissing to Mark Fistos and [REDACTED] [REDACTED] (08042-08044)
13-89	10/23/09 12:12 p.m.	E-mail chain – from [REDACTED] J. Edwards to Scott Rothstein, Steven Jaffe and Mark Fistos (26741-26742)
13-90	10/23/09 12:16 p.m.	E-mail chain – from [REDACTED] Edwards to Matthew Weissing (08059-08061)
13-91	10/23/09 12:17 p.m.	E-mail chain - from Jacquie Johnson to [REDACTED] [REDACTED], William Berger and Robert Buschel (02992)
13-92	10/23/09 12:18 p.m.	E-mail chain - from Scott J. Rothstein to A.J. Discala and Dean Kretschmar (27522)
13-93	10/23/09 12:27 p.m.	E-mail chain – from Bradley [REDACTED] to Scott Rothstein, Steven Jaffe and Mark Fistos (26756-26758)
13-94	10/23/09 12:36 p.m.	E-mail chain – from [REDACTED] [REDACTED] to Mark Fistos (08036-08038)
13-95	10/23/09 12:53 p.m.	E-[REDACTED] chain - from Scott Rothstein to A.J. Discala and [REDACTED] Kretschmar (026335)
13-96	10/23/09 1:05 p.m.	E-mail chain – from Scott Rothstein to Michael Legamaro (Legamaro production)
13-97	10/23/09 1:26 p.m.	E-mail chain – [REDACTED] J. [REDACTED] to [REDACTED] Adler, Scott Rothstein and Mark Fistos (26762)
13-98	10/23/09 1:31 p.m.	E-mail chain – from Matthew Weissing to [REDACTED] [REDACTED], [REDACTED] Adler, Mark Fistos and Steven Jaffe (01117)
13-99	10/23/09 1:54 p.m.	E-mail chain – from [REDACTED] Kretschmar to Scott Rothstein (27051-27052)
13-100	10/23/09 1:59 p.m.	E-mail chain – from Mark Fistos to [REDACTED] [REDACTED] and [REDACTED] Adler (08121-08123)

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
13-101	10/23/09 2:02 p.m.	E-mail chain – from Scott Rothstein to [REDACTED], Steven Jaffe and Mark Fistos (26749-26752)
13-102	10/23/09 2:05 p.m.	E-mail chain – from Mark Fistos to [REDACTED] and [REDACTED] Adler (08128-08130)
13-103	10/23/09 2:06 p.m.	E-mail chain – from [REDACTED] Adler to [REDACTED] and Mark Fistos (08118-08120)
13-104	10/23/09 2:09 p.m.	E-mail chain – from Mark Fistos to [REDACTED] and [REDACTED] Adler (08131-08133)
13-105	10/23/09 2:09 p.m.	E-mail chain – from Steven Jaffe to [REDACTED], Mark Fistos and [REDACTED] Adler (08124-08126)
13-106	10/23/09 2:10 p.m.	E-mail chain – from Matthew Weissing to [REDACTED], Mark Fistos and [REDACTED] Adler (08135-08138)
13-107	10/23/09 2:24 p.m.	E-mail chain – from Mark Fistos to Steve Jaffe, Scott Rothstein, [REDACTED] Adler, Bradley Edwards and Matthew Weissing (27494)
13-108	10/23/09 2:45 p.m.	E-mail chain – from Mark Fistos to Steven Jaffe, Scott Rothstein, [REDACTED] Adler, Bradley [REDACTED] and Matthew Weissing (26760)
13-109	10/23/09 3:02 p.m.	E-mail chain – from Scott Rothstein to Michael Legamaro (27025)
13-110	10/23/09 3:43 p.m.	E-mail chain – from Russell Adler to Scott Rothstein (25997)
13-111	10/25/09 3:21 p.m.	E-mail chain – from Ken Jenne to Scott Rothstein (25937)
13-112	10/27/09 2:59 p.m.	E-mail chain – from [REDACTED] Preve to A.J. Discala (26973)
13-113	10/27/09 5:23 p.m.	E-mail chain – from Ken Jenne to Phaedra Xanthos (26604-26605)
13-114	10/28/09 9:22 a.m.	E-mail chain – from Ken Jenne to Lea Kaplan (26737)
13-115	10/28/09 9:34 a.m.	E-mail chain – from Ken Jenne to Mike Fisten and Pat [REDACTED] (26485)
13-116	10/29/09 7:44 p.m.	E-mail chain – from Paul Cassell to [REDACTED] (07019-07021)
13-117	10/30/09 10:04 a.m.	E-mail chain – from Scott Rothstein to Debra [REDACTED] (27013)
13-118	3/17/10	Wackenhut Incident Report
13-119	3/18/10 1:20 a.m.	E-mail chain - from C.J. [REDACTED] to Tom Hartog and Donnie
13-120	3/23/10	Wackenhut Incident Report

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
13-121	3/24/10 2:34 p.m.	E-mail chain - from Story Cowles to Tom Hartog
13-122	4/1/10 3:50 a.m.	E-mail chain - from C.J. [REDACTED] to Story Cowles
13-123	10/14/10	Affidavit of Ken Jenne
14	Misc.	All documents filed in the court file, including pleadings, motions, responses, affidavits, discovery, and exhibits
15	Misc.	All hearing transcripts
<i>State of Florida v. Jeffrey Epstein</i> <b>15th Judicial Circuit</b>
16	4/24/07	Transcript of Taped Statement of L.M.
17	Misc.	All other testimony, transcripts and statements provided in the matter
17A	10/4/07	FBI report for October 2, 2007, interview of Jane Doe
17B	2/8/08	FBI report for January 31, 2008, interview of E.W.
17C	5/30/08	FBI report for May 28, 2008, interview of Jane Doe
<i>L.M. v. Jeffrey Epstein</i> <b>15th Judicial Circuit Case No. 50-2008-CA-028051XXXXMB</b>
18-1	Misc.	Court docket [and all court filings referenced therein]
18-2	10/13/09	Epstein's Motion for Protective Order Regarding Depositions of Lawrence Visoski and Davit Hart Rogers
18-3	8/12/09	Notice of Production from Non-Party – Greens Pharmacy
18-4	8/14/09	Notice of Production from Non-Party – [REDACTED] Pharmacy
18-5	8/20/09	Ep [REDACTED] Objections to Notices of Production From Non-Parties and Incorporated Motion for Protective Order
18-6	1/23/09	L.M.'s Answers to Interrogatories
18-7	8/4/09	Notice of Service of Plaintiff's Unverified Better Answers to Defendant's Interrogatories
18-8	8/29/09	Notice of Serving Plaintiff's Supplemental Better Answers to Defendant's Interrogatory Number 19
18-9	3/1/10	Notice of Service of Plaintiff's Answers to Defendant's Third Interrogatories
18-10	4/1/10	Notice of Service of Plaintiff's Unverified Answers to Defendant's Fourth Interrogatories

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
18-11	4/15/10	Notice of Service of Plaintiff's Unverified Answers to Defendant's Fifth Interrogatories
18-12	6/25/10	Notice of Service of Plaintiff's Update Answers to #2 #4 and #5 of Defendant's Fourth Interrogatories
18-13	5/14/10	Printout of L.M.'s Myspace page
19	9/11/08	Complaint
20	12/23/08	Amended Complaint
21	3/30/09	Notice of Change of Firm and Address
22	4/7/09	Defendant Epstein's Answer & Affirmative Defenses to Plaintiff's Amended Complaint
23	8/19/09 9/11/09	Notices of Production from Non Parties: (1) Stephen Alexander, M.D.; (2) Bruce W. Markowitz, M.D.; and (3) Charles J. Galecki, M.D.
24	8/24/09	Notices of Taking Deposition and Subpoenas to (1) Paul Visoski, Jr. and (2) David Hart Rogers
25	8/11/09	Plaintiff's Request for Production to Defendant
26	8/19/09	Defendant Epstein's Answer & Affirmative Defenses to Plaintiff's Second Amended Complaint
27	5/28/10	Plaintiff's Third Amended Complaint
28	7/22/10	Stipulation of Dismissal With Prejudice
29	Misc.	All testimony, deposition transcripts, exhibits and videotapes including, but not limited to:
29A-1	9/24/09	Deposition Testimony of L.M.
29A-2	2/9/10	Deposition Testimony of L.M.

L.M. v. Jeffrey Epstein Ir 0 . P C S.D. Fla. Case No. 09-CV-81092¶

30	Misc.	doe! • t [all court filings referenced therein
31	7/24/09	m aint and Demand for Jury Trial (D.E. I)
32	7/20	S pulation of Dismissal With Prejudice (D.E. 21)
33		All testimony, deposition transcripts, exhibits and
34	N/D	Federal Rule of Civil Procedure, Rule 11

E. W. v. Jeffrey Epstein 15th Judicial Circuit Case No. 50-2008-CA-028058XXXXMB¶

35	Misc.	Court docket [all court filings referenced therein and all discovery and discovery responses]
35-1	8/20/09	Order on Plaintiff's Request for Entry Upon Land

No.	Date	Description Objection Marked
35-2	Misc.	Notice of Taking Deposition Duces Tecum to
36	9/10/08	Complaint
37	12/23/08	Amended Complaint
38	3/30/09	Notice of Change of Firm and Address
39	4/6/09	Defendant Epstein's Answer & Affirmative
40	6/2/09	Defendant Epstein's Motion for Order to Terminate
41	7/16/09	Cross Notice of Taking Videotaped Deposition of
42	8/19/09	Defendant Epstein's Answer & Affirmative
		Defenses to Plaintiff's Second Amended at
43	8/10/09	Plaintiff's Request for Entry Upon Lan
44	5/28/10	Plaintiff's Third Amended Complai
45	7/22/10	Stipulation of Dismissal With Pre' di e
46	7/29/10	Order Adopting Stipulation an is ing Case
47	Misc.	All testimony, depositio ts, exhibits and
		videotapes including, t t 1* ited to:
47A	5/6/10	Deposition Transc • o ir .

Jar oe v. Jeffrey Epstein US .D. Fla. Case No. 08-CV-80893¶

48	Misc.	Court d t [all court filings referenced therein
		and all di and discove res onses
48-1	4/9/09	P mtiff's otion to Strike References to Non
		ro ution Agreement or, in the Alternative, to
48-2	/2	Plaintiff's Answers to Defendant's First
49	8/12/08	Complaint (D.E. 1)
50	3/26/09	Defendant Epstein's Motion to Stay and/or
51	4/9/09	Notice of Change of Address and Finn Affiliation

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
52	4/9/09	Plaintiff's Motion to Strike References to Non-Prosecution Agreement or, in the Alternative, to Lift Protective Order Barring Jane Doe's Attorney's from Revealing Provisions in the Agreement (D.E. 32)
53	4/17/09	Plaintiff's First Amended Complaint (D.E. 38)
54	5/14/09	Order Consolidating Cases for Purposes of Discovery and Procedural Motions that Relate to Multiple Cases (D.E. 56)
55	7/28/09 to 10/22/09	Notices of Taking Deposition and Subpoenas to: Ghislane Noelle Maxwell, Leslie Wexler, Donald Trump, Mark Epstein, [REDACTED], Jean Luc Bruhel, [REDACTED], Michael Freidman, Rosalie Freidman, and Michael Sanka
56	7/20/10	Stipulation of Dismissal With Prejudice (D.E. 210)
57	7/20/10	Final Order of Dismissal With Prejudice (D.E. 211)
58	Misc.	All testimony, deposition transcripts, exhibits and videotapes
58A	9/30/09	Deposition Transcript of Jane Doe
<i><b>Jane Doe 2 v. Jeffrey Epstein (Consolidated Action)</b></i> <b>USDC S.D. Fla. Case No. 08-CV-80119</b>
59	Misc.	Court docket [and all court filings referenced therein and all discovery and discovery responses]
60	6/19/09	Plaintiff Jane Doe's Motion for Injunction Restraining Fraudulent Transfer of Assets Appointment of a Receiver to Take Charge of Property of Epstein and to Post a $15 Million Bond to Secure Potential Judgment (D.E. 165)
61	7/23/09	Plaintiff Jane Doe's Reply Memorandum in Support of Motion for Injunction Restraining Fraudulent Transfer of Assets, Appointment of a Receiver to Take Charge of Property of Epstein and to Post a $15 Million Bond to Secure Potential Judgment (D.E. 217)
62	10/16/09	Plaintiff Jane Doe's Notice that Additional Evidence of Epstein's Fraudulent Asset Transfers Will be Filed Shortly, etc. (D.E. 357)

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
63	10/30/09	Plaintiff Jane Doe's Motion for Leave to Provide Recently-Obtained Deposition Testimony and Affidavit Demonstrating Fraudulent Transfers by Epstein in Support of Motion for Appointment of a Receiver to Take Charge of Property of Epstein and Incorporated Supporting Memo of Law (D.E. 386)
64	11/5/09	Order (D.E. 400)
65	Misc.	All testimony, deposition transcripts, exhibits and videotapes
<b><i>Jane Doe v. United States of America (CVRA)</i></b> <b>USDC S.D. Fla. Case No. 08-80736-CIV</b>
66	7/7/08	Emergency Victim's Petition for Enforcement of Crime Victim's Rights Act, 18 U.S.C. Section 3771 (D.E. 1)
67	8/14/08	Transcript of Hearing Before the Honorable Kenneth A. Marra
<b><i>Rothstein Rosenfeldt Adler and Stuart Rosenfeldt v. Scott W. Rothstein</i></b> <b>17th Judicial Circuit Broward County Case No. 2009-CA-059301-AXXXCE</b>
68	Misc.	Court docket [all court filings referenced therein and all discovery and discovery responses]
69	11/3/09	Amended Complaint
70	Misc.	All testimony, deposition transcripts, exhibits and videotapes
<b><i>In re Rothstein Rosenfeldt Adler, P.A.</i></b> <b>USBC S.D. Fla. Case No. 09-34791-RBR</b>
71	11/16/09	Motion of the U.S. Trustee for an Order Directing the Appointment of a Chapter 11 Trustee and Objection to Retention of Chief Restructuring Officer (D.E. 8)
72	12/1/09	Verified Complaint for Damages and Other Relief (D.E. 74)
73	2/23/11	Privilege Log of [REDACTED], Jaffe, Weissing, [REDACTED], Fistos & Lehrman
74	Misc.	All testimony, deposition transcripts, exhibits and videotapes
74A-1	12/12/11	Transcript of Rule 2004 Examination of Scott W. Rothstein
74A-2	12/23/11	Deposition Transcript of Scott W. Rothstein – Volume I

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
74A-3	12/23/11	Deposition Transcript of Scott W. Rothstein – Volume II
74B	7/2/13	Deposition Transcript of Jack (John) Scarola
74C	10/28/10	Deposition Transcript of [REDACTED] Adler
<b><i>United States of America v. Scott Rothstein – Forfeiture Action</i></b> <b>USDC S.D. Fla. Case No. 09-CV-61780-Zloch-Rosenbaum</b>
75	11/9/09	Verified Complaint for Forfeiture <i>in Rem</i> (D.E. 1)
76	11/23/09	Amended Verified Complaint for Forfeiture <i>in Rem</i> (D.E. 14)
77	11/27/09	Amended Verified Complaint for Forfeiture <i>in Rem</i> (D.E. 19)
<b><i>The Florida Bar Matters</i></b>
78	11/9/09	The Florida Bar Inquiry/Complaint Form Jeffrey Epstein filed against [REDACTED] J. Edwards, William Berger and Scott Rothstein
79	11/25/09	Approval of Scott Rothstein's disbarment; <i>The Florida Bar v. Scott Walter Rothstein</i> ; Supreme Court Case No. SC09-2146
80	6/24/10	The Florida Bar's Notice of No Probable Cause and Letter of Advice to Accused; <i>In re Complaints by Jeffrey Epstein and the Florida Bar against [REDACTED] James Edwards</i> ; Case No. 2010-50,746(09B)
<b><i>United States of America v. Scott W. Rothstein</i></b> <b>USDC S.D. Fla. Case No. 09-60331</b>
81	12/1/09	Information charging Scott W. Rothstein
82	1/25/10	Plea Agreement between the United States of America and Scott W. Rothstein
83	9/26/17	Government's Motion to Withdraw its Motion for Reduction of Sentence (D.E. 938)
<b><i>Razorback Funding, LLC, et al. v. Scott W. Rothstein, et al.</i></b> <b>17th Judicial Circuit, Broward County, Florida Case No. 09-062943</b>
84	Misc.	Court docket [all court filings referenced therein and all discovery and discovery responses]
85	11/20/09	Complaint
86	11/25/09	Amended Complaint
87	Misc.	All testimony, deposition transcripts, exhibits and videotapes including, but not limited to:

No.	Date	Description Objection Marked
87A-I	12/12/11	Deposition Transcript of Scott W. Rothstein —
87A-2	12/13/11	Deposition Transcript of Scott W. Rothstein —
87A-3	12/13/11	Deposition Transcript of Scott W. Rothstein —
87A-4	12/14/11 12114/I 1	Deposition Transcript Tran of Scott W. Rothstein —
87A-5	12/15/11	Deposition Transcript of Scott W. Rothstein —
87A-6	12/15/11	Deposition Transcript of Scott W. Rothstein —
		Afternoon Session OP"
87A-7	12/16/11	Deposition Transcript of Scott W. Rothstein —
87A-8	12/16/11	Deposition Transcript of Scott W. Rothste'
87A-9	12/19/11	Deposition Transcript of Scott W. It
87A-10	12/19/11	Deposition Transcript of Scott 1 , — P.M.
87A-11	12/20/11	Deposition Transcript of S . othstein —
87A-I2	12/20/11	Deposition Transc ' o W. Rothstein —
87A-13	12/21/11	Deposition T nscri Scott W. Rothstein —
87A-14	12/21/11	Depositi Transcript of Scott W. Rothstein —
		Afternoo ion
87A-15	12/22/11	sitio Transcript of Scott W. Rothstein —
87A-16	12/22/1	o Won Transcript of Scott W. Rothstein

Rothstein Rosenfeldt Adler — Communication¶

88	4/8/09 2:58 p.m.	E-mail chain - from [REDACTED] Adler to [REDACTED] J. [REDACTED], cc Mark S. Nurik (01404)
89	4/22/09 4:51 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to [REDACTED] Adler (01620)
90	4/24/09 5:07 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to [REDACTED] Adler (01446)
91	5/19/09 10:33 a.m.	E-mail chain - from William J. Berger to [REDACTED] J. [REDACTED], [REDACTED] Adler, Steven R. Jaffe, Matthew D. Weissing and Gary M. [REDACTED] (01726)

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
92	5/19/09 12:00 p.m.	E-mail chain - from Susan K. Stirling to [REDACTED] J. [REDACTED] (05725)
93	5/19/09 12:03 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Russel Adler (01574)
94	5/22/09 12:13 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Susan Spencer Wendel (01449)
95	5/22/09 12:21 p.m.	E-mail chain - from Susan Spencer Wendell to [REDACTED] J. [REDACTED] (05148)
96	5/26/09 4:57 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Timothy Malloy (01450)
97	5/26/09 5:33 p.m.	E-mail chain - from Timothy Malloy to [REDACTED] J. [REDACTED] (05151)
98	5/28/09 2:13 p.m.	E-mail chain - from Susan Spencer Wendell to [REDACTED] J. [REDACTED] (05161)
99	5/28/09 2:16 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to William J. Berger (02241-02242)
100	6/3/09 5:17 p.m.	E-mail chain - from William J Berger to Grace [REDACTED], cc [REDACTED] Adler and Bradley J. Edwards (01735)
101	6/4/09 10:43 a.m.	E-mail chain - from Bradley J. Edwards to Susan K. Stirling, cc [REDACTED] Martinez (01410)
102	6/9/09 3:10 p.m.	E-mail chain - from Bradley J. [REDACTED] to Eric Glasser (06655)
103	6/23/09 12:52 p.m.	E-mail chain - from Bradley J. [REDACTED] to Michele Dargan (Palm Beach Daily News) (01632)
104	6/23/09 1:03 p.m.	E-mail chain - from Bradley J. [REDACTED] to Paul Cassell (01634)
105	6/23/09 1:13 p.m.	E-mail chain - from Michele Dargan to [REDACTED] J. Edwards (05239)
106	6/23/09 1:16 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Michele Dargan (05203)
107	6/23/09 1:29 p.m.	E-mail chain - from Michele Dargan to [REDACTED] J. Edwards (05277-05278)
108	6/23/09 2:31 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Michele Dargan (05207-05208)
109	6/23/09 2:41 p.m.	E-mail chain - from Michele Dargan to [REDACTED] J. [REDACTED] (05324-05325)
110	6/23/09 2:53 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Michele Dargan (05212-05213)
111	6/23/09 3:08 p.m.	E-mail chain - from Michele Dargan to [REDACTED] J. [REDACTED] (05344-05346)
112	6/23/09 3:12 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Michele Dargan (05215-05217)

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
113	6/23/09 4:39 p.m.	E-mail chain - from Michele Dargan to [REDACTED] J. [REDACTED] (05368-05369)
114	6/23/09 5:22 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Michele Dargan (05220-05221)
115	6/23/09 5:28 p.m.	E-mail chain - from Michele Dargan to [REDACTED] J. [REDACTED] (05387-05388)
116	6/24/09 9:39 a.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Michele Dargan (05224-05225)
117	7/8/09 3:36 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to [REDACTED] Adler, William J. Berger and Steven R. Jaffee (01462)
118	7/13/09 2:28 p.m.	E-mail chain - from Michele Dargan (Palm Beach Daily News) to [REDACTED] J. [REDACTED] (08404)
119	7/14/09 4:37 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to William J. Berger (02204)
120	7/15/09 1:17 p.m.	E-mail chain - from [REDACTED] J. Edwards to Michele Dargan (04906)
121	7/15/09 1:22 p.m.	E-mail chain - from Michele Dargan to Bradley J. [REDACTED] (04905)
122	7/18/09 4:10 p.m.	E-mail chain - from Bradley J. Edwards to [REDACTED] Adler (01661)
123	7/21/09 8:21 p.m.	E-mail chain - from Bradley J. [REDACTED] to Michele Leone (01352)
124	7/22/09 11:22 a.m.	E-mail chain - from Bradley J. [REDACTED] to Michele Dargan (01479)
125	7/22/09 11:35 a.m.	E-mail chain - from Michele Dargan to [REDACTED] J. Edwards (05803)
126	7/22/09 1:29 p.m.	E-mail chain - from Jacquie [REDACTED] to [REDACTED] J. Edwards (01662)
127	7/22/09	Letter from [REDACTED] J. [REDACTED] re cross noticing depositions
128	7/26/09 5:28 p.m.	E-mail chain - from Priscila A. Nascimento to Scott Rothstein, cc Amy N. Howard and Adelita Cabello (25860-25863)
129	7/28/09 8:59 a.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Susan Spencer Wendel (01483)
130	7/28/09 8:59 a.m.	E-mail chain - from Susan Spencer Wendel to [REDACTED] J. [REDACTED] (03070)
131	7/28/09 9:28 a.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Michele Dargan (01486)
132	7/28/09 10:00 a.m.	E-mail chain - from Michele Dargan to [REDACTED] J. [REDACTED] (05848)

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
133	7/29/09 1:13 p.m.	E-mail chain - from Cara L. [REDACTED] to [REDACTED] J. [REDACTED] (08420)
134	7/28/09 1:47 p.m.	E-mail chain - from Michele Dargan to [REDACTED] J. [REDACTED] (11075-11076)
135	7/29/09 1:49 p.m.	E-mail chain - from Michele Dargan to [REDACTED] J. [REDACTED] (05852-05853)
136	7/30/09 2:36 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Michele Dargan (05535-05536)
137	7/30/09 2:36 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Michele Dargan (11320-11322)
138	7/30/09 6:06 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Michele Dargan (05538-05539)
139	7/31/09 11:20 a.m.	E-mail chain - from Michele Dargan to [REDACTED] J. [REDACTED] (11080-11082)
140	8/10/09 6:59 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Michael Isikoff (06965)
141	8/10/09 7:23 p.m.	E-mail chain - from [REDACTED] Isikoff to Bradley J. [REDACTED] (06967)
142	8/11/09 8:43 a.m.	E-mail chain - from [REDACTED] J. Edwards to Michael Isikoff (06968-0696)
143	8/11/09 9:29 a.m.	E-mail chain - from Michael Isikoff to [REDACTED] J. [REDACTED] (06963-06964)
144	8/11/09 10:10 a.m.	E-mail chain - from Bradley J. [REDACTED] to Michael Isikoff (06970-06971)
145	8/11/09 12:34 p.m.	E-mail chain - from Michael Isikoff to [REDACTED] J. [REDACTED] (06959-06960)
146	8/14/09 4:40 p.m.	E-mail chain - from Michael Isikoff to [REDACTED] J. [REDACTED] (06975)
147	8/15/09 2:41 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Mike Fisten, cc Ken Jenne (01685)
148	8/15/09 6:00 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Michael Isikoff (06972-06973)
149	8/17/09 10:32 a.m.	E-mail chain - from Michael Isikoff to [REDACTED] J. [REDACTED] (06976-06977)
150	8/17/09 10:42 a.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Jacquie [REDACTED] (02442)
151	8/19/09 2:47 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Ken Jenne (01501)
152	8/24/09 7:38 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to [REDACTED] (01506)
153	8/25/09 11:03 a.m.	E-mail chain - from [REDACTED] to [REDACTED] J. [REDACTED] (05952-05953)

No.	Date	Description		Objection Marked
154	8/26/09	E-mail chain - from J.	to
	9:56 p.m.	02269
155	8/31/09	E-mail chain - from	to	J.
	10:58 a.m.	02895
156	9/2/09	E-mail chain - from Elizabeth Villar to		J.
	12:54 p.m.	and Ken Jenne, cc Jacquie
157	9/7/09	E-mail chain - from	to	J. AS
	1:39 p.m.	07612-07613
158	9/7/09	E-mail chain - from	to	J.
	6:42 p.m.	02595-02596
				O 'S
159	9/7/09	E-mail chain - from J.	to
	6:49 p.m.	07614-07615
160	9/7/09	E-mail chain - from	to Bra
	7:00 p.m.	(07605-076
161	9/7/09	E-mail chain - from J. Edward
	8:12 p.m.	(07607-07608)
162	9/7/09	E-mail chain - from Conchita S		dley J.
	10:55 p.m.	(07609-07611)
163	9/8/09	E-mail chain - from Bradle	s to
	11:43 a.m.	04015
164	9/8/09	E-mail chain - from C c taS	off to	J.
	11:50 a.m.	07646
165	9/8/09	E-mail chain - Y J.	to
	11:53 a.m.	Conchita Sa ff(0 )
166	9/8/09	E-mail chain - onchita	to	J.
	12:04 ..m.	Edwar. 7676 7677
167	9/8/09	E-mail c m	to	J.
	1:59 p.m.	ds 674-07675
168	9/8/09	• chain - from J.	to
	2:04	c ita 07678-07679
169	9/8/	E ail chain - from	to	J.
	2-	wards (07684-07685
170	9/	E-mail chain - from J.	to
	2:42 p. .	07682-07683
171	9/8/09	E-mail chain - from	to	J.
	2:49 p.m.	07695-07697
172	9/8/09	E-mail chain - from	to	J.
	3:25 p.m.	07680-07681
173	9/8/09	E-mail chain - from J.	to
	7:51 p.m.	07686-07688
174	9/8/09	E-mail chain - from	to	3.
	7:53 •.m.	(07689-07691)

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
175	9/8/09 7:53 p.m.	E-mail chain - from [REDACTED] to [REDACTED] J. [REDACTED] (07692-07694)
176	9/15/09 1:08 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Elizabeth Villar, cc Ken Jenne and Pat [REDACTED] (01361)
177	9/18/09 12:35 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to [REDACTED] Adler (01318)
178	9/18/09 12:35 p.m.	E-mail chain - from Jacquie [REDACTED] to Ann [REDACTED] Villafana, cc [REDACTED] J. [REDACTED] (01583)
179	9/18/09 1:01 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Susan Spencer Wendel (05619-05620)
180	9/18/09 2:37 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Beth S. Williamson (01144)
181	9/18/09 2:55 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Michele Dargan (01280-01288)
182	9/21/09 1:37 p.m.	E-mail chain - from [REDACTED] to Bradley J. [REDACTED] (03081)
183	9/23/09 8:42 p.m.	E-mail chain - from Conchita Sarnoff to Bradley J. [REDACTED] (04320)
184	9/24/09 6:31 a.m.	E-mail chain - from Bradley J. Edwards to [REDACTED] (04321)
185	9/24/09 6:53 a.m.	E-mail chain - from Conchita Sarnoff to [REDACTED] J. [REDACTED] (04318-04319)
186	9/24/09 8:45 p.m.	E-mail chain - from Conchita [REDACTED] to [REDACTED] J. [REDACTED] (10586-10589)
187	9/28/09 8:09 a.m.	E-mail chain - from Conchita [REDACTED] to [REDACTED] J. Edwards, cc Renee/Carlos [REDACTED] (02913)
188	9/28/09 10:06 a.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Conchita Sarnoff (06789)
189	9/28/09 10:20 a.m.	E-mail chain - from [REDACTED] to [REDACTED] J. Edwards (06788)
190	9/28/09 11:45 p.m.	E-mail chain - from Mike Fisten to Conchita Sarnoff (19986-19987)
191	9/29/09 10:06 a.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Ken Jenn and Elizabeth Villar (01754)
192	10/2/09 10:41 a.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Nigel Rosser (06191)
193	10/2/09 11:08 a.m.	E-mail chain - from Nigel Rosser to [REDACTED] J. [REDACTED] (06189-06190)
194	10/2/09 4:28 p.m.	E-mail chain - from Michael Isikoff to [REDACTED] J. [REDACTED] (06979-06980)
195	10/2/09 4:52 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Mike Fisten (02440-02441)

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
196	10/2/09 4:53 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Michael Isikoff, cc Jacquie [REDACTED] (06974)
197	10/2/09 6:14 p.m.	E-mail chain - from Michael Isikoff to [REDACTED] J. [REDACTED], cc Jacquie [REDACTED] (06955-06956)
198	10/8/09 4:11 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Richard [REDACTED] (06961)
199	10/13/09 2:17 p.m.	E-mail chain - from Grant J. [REDACTED] to Scott Rothstein, [REDACTED] J. [REDACTED], Ken Jenne, Kip Hunter and [REDACTED] Adler, cc Grant J. [REDACTED] (26507)
200	10/13/09 2:27 p.m.	E-mail chain - from Mike Fisten to [REDACTED] J. [REDACTED] (01727)
201	10/13/09 7:00 p.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Jacquie [REDACTED], cc Mike Fisten (01744)
202	10/14/09 7:39 a.m.	E-mail chain - from [REDACTED] J. [REDACTED] to [REDACTED] (03190)
203	10/14/09 9:02 a.m.	E-mail chain - from [REDACTED] to Bradley J. [REDACTED] (03189)
204	10/14/09 10:42 a.m.	E-mail chain - from [REDACTED] Adler to Bradley J. [REDACTED], cc Jacquie Johnson (01099)
205	10/14/09 12:20 p.m.	E-mail chain - from Bradley J. Edwards to Mike Fisten, cc Jacquie Johnson (01741)
206	10/16/09 5:29 a.m.	E-mail chain - from ABA Journal Weekly Newsletter to Scott Rothstein (25864-25865)
207	10/19/09 10:46 a.m.	E-mail chain - from Bradley J. [REDACTED] to Ken Jenne (01704)
208	10/20/09 1:01 p.m.	E-mail chain - from [REDACTED] Rush to [REDACTED] J. [REDACTED] (01433)
209	10/20/09 3:07 p.m.	E-mail chain - from Ken Jenne to Scott Rothstein (26506)
210	10/22/09 11:52 a.m.	E-mail chain - from [REDACTED] J. [REDACTED] to Jacquie Johnson (01391)
211	10/22/09 2:52 p.m.	E-mail chain - from Jacquie [REDACTED] to [REDACTED] Adler, Cara L. [REDACTED], Mike Fisten, Michael J. Wheeler, Marc S. Nurik, William J. Berger, [REDACTED] J. [REDACTED], Barry J. [REDACTED] and Ken Jenne, cc Robert C. Buschel (01392)
212	10/22/09 4:10 p.m.	E-mail chain - from Jacquie [REDACTED] to [REDACTED] J. [REDACTED], Marc S. Nurik, Michael J. Wheeler, Cara L. [REDACTED], William J. Berger, [REDACTED] Adler and Robert C. Buschel

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
213	10/26/09 7:46 a.m.	E-mail chain - from William J. Berger to Pat Carter and [REDACTED] J. [REDACTED], cc [REDACTED] [REDACTED] and Jacquie [REDACTED] (01380)
214	10/29/09 2:16 p.m.	E-mail chain - from Pat [REDACTED] to [REDACTED] J. [REDACTED] (01623)
215	10/30/09 10:01 a.m.	E-mail chain - from Debra [REDACTED] to Scott Rothstein (26304-26305)
216	10/30/09 10:03 a.m.	E-mail chain - from [REDACTED] Adler to Jacquie [REDACTED] and [REDACTED] J. [REDACTED] (01625)
<b>Billing</b>
217	12/21/09	Contract for Services between Searcy Denny Scarola Barnhart & Shipley and [REDACTED] J. [REDACTED]
218	N/D	Spreadsheet of Brad [REDACTED] Time in <i>Edwards adv. Epstein</i> (BJE00000104 – BJE00000156)
219	7/14/10 - 1/16/13	Searcy Denney Scarola Barnhart and Shipley's Invoices for Disbursements to Bradley J. Edwards (BJE000000039 – BJE000000103)
220	1/1/80 – 2/15/13	Searcy Denney Scarola Barnhart and Shipley's Matter Ledger Report (BJE000000006 – BJE000000038)
<b>Miscellaneous</b>
221	10/23/09	Rothstein Rosenfeldt Adler's Firm Directory
222	11/9/17	[REDACTED], Jaffe, Weissing, [REDACTED], Fistos & Lehrman, P.L.'s "Our Attorneys" website printout ( <a href="https://www.pathtojustice.com/about-us/attorneys/">https://www.pathtojustice.com/about-us/attorneys/</a> )
223	12/1/09	Criminal Complaint; <i>United States of America v. Alfredo Rodriguez</i> ; USDC S.D. Fla. Case No. 09-8308
224	4/23/10	Affidavit of [REDACTED] James [REDACTED]
225	9/21/10	Affidavit of [REDACTED] James [REDACTED]
226	Misc.	Subpoenas and Notices of Deposition for Alan Dershowitz, David Copperfield and Leonard Baird
227	11/16/17	Critton Luttier Coleman, LLP's website printout for Robert D. Critton Jr. ( <a href="https://www.lawclc.com/team_members/Robert-d-critton-jr/">https://www.lawclc.com/team_members/Robert-d-critton-jr/</a> )
228	11/16/17	[REDACTED] Burnett, P.A.'s website printout for L. Ackerman, Jr. ([REDACTED] - [REDACTED])

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
<b>J. [REDACTED]</b>
229	N/D	The National Crime Victim Bar Association presentation excerpt of article by [REDACTED] J. [REDACTED]: <i>Who is Responsible for Child Sexual Abuse</i>
230	N/D	The Florida Bar's website member profile printout for [REDACTED] James [REDACTED]
231	N/D	National Association of Distinguished Counsel biographical information for [REDACTED] J. [REDACTED]
232	5/14/13	The National Trial Lawyers Top 40 Under 40 Directory ( <a href="http://www.thenationaltriallawyers.org/top-40-under-40-directory/?last_name+[REDACTED]=&amp;state=FL&amp;x=18&amp;y=17">http://www.thenationaltriallawyers.org/top-40-under-40-directory/?last_name+[REDACTED]=&state=FL&x=18&y=17</a> )
233	5/14/13	The National Trial Lawyers Profile View of Brad [REDACTED] ( <a href="http://www.thenationaltriallawyers.org/profile-view/Brad/[REDACTED]/4409/">http://www.thenationaltriallawyers.org/profile-view/Brad/[REDACTED]/4409/</a> )
234	5/14/13	Lawyers.com website information for Bradley J. [REDACTED] ( <a href="http://www.lawyers.com/florida/fort-lauderdale/[REDACTED]-J-[REDACTED]-3489098-a/">http://www.lawyers.com/florida/fort-lauderdale/[REDACTED]-J-[REDACTED]-3489098-a/</a> )
235	10/30/04	Kubicki Draper's website attorney information for Brad J. Edwards
236	10/30/05	Kubicki Draper's website attorney information for Brad J. Edwards
237		The American Registry Website printouts of recognitions received by [REDACTED] J. [REDACTED]
238	5/7/12	Farmer, Jaffe, Weissing, [REDACTED], Fistos & Lehrman, P.L.'s website printout ( <a href="http://www.abuseandassault.com/Abuse_Under_Investigation">http://www.abuseandassault.com/Abuse_Under_Investigation</a> )
239	1/16/13	[REDACTED], Jaffe, Weissing, [REDACTED], Fistos & Lehrman, P.L.'s website printout ( <a href="http://www.abuseandassault.com/Abuse_Under_Investigation">http://www.abuseandassault.com/Abuse_Under_Investigation</a> )
240	1/16/13	[REDACTED], Jaffe, Weissing, [REDACTED], Fistos & Lehrman, P.L.'s website printout ( <a href="http://www.pathtojustice.com/media-center/press-releases/">http://www.pathtojustice.com/media-center/press-releases/</a> )
241	5/14/13	[REDACTED], Jaffe, Weissing, [REDACTED], Fistos & Lehrman, P.L. website printout ( <a href="http://www.abuseandassault.com/Abuse_Home">http://www.abuseandassault.com/Abuse_Home</a> )

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
242	5/14/13	[REDACTED], Jaffe, Weissing, [REDACTED], Fistos & Lehrman, P.L.'s website printout ( <a href="http://www.abuseandassault.com/Abuse_Under_Notable_Cases">http://www.abuseandassault.com/Abuse_Under_Notable_Cases</a> )
243	5/14/13	[REDACTED], Jaffe, Weissing, [REDACTED], Fistos & Lehrman, P.L.'s website attorney information for Brad [REDACTED] ( <a href="http://www.pathtojustice.com/attorneys/brad-edwards/#.UZJOPpWTOX0">www.pathtojustice.com/attorneys/brad-edwards/#.UZJOPpWTOX0</a> )
244	5/14/13	[REDACTED], Jaffe, Weissing, [REDACTED], Fistos & Lehrman, P.L.'s website printout ( <a href="http://www.pathtojustice.com/media-center/achived-press-releases/#.UZJTy5WTOX0">http://www.pathtojustice.com/media-center/achived-press-releases/#.UZJTy5WTOX0</a> )
245		[REDACTED], Jaffe, Weissing, [REDACTED], Fistos & Lehrman, P.L.'s website attorney information for Brad [REDACTED] with referenced articles
245A	Winter 2014	Journal of Criminal Law and Criminology, Volume 104; Issue 1. <i>Crime Victims' Rights During Criminal Investigations? Applying the Crime Victims' Rights Act Before Criminal Charges are Filed</i> ;
245B	12/26/15	<u>Politico. Victims in Underage Sex Case Want Prosecutors to Testify</u>
245C	12/21/15	<u>Palm Beach Daily News. Jeffrey Epstein Sex Scandal: Alan Dershowitz Suffers Setback in Defamation Case</u>
245D	12/18/15	<u>Palm Beach Daily News. Epstein Victims' Attorneys Seek Partial Victory in Defamation Suit</u>
245E	12/21/15	<u>Palm Beach Post. Boca-Resident Model Nabs $13.4 Million Following Six-Year Divorce Battle</u>
245F	12/17/15	<u>Daily Mail.Com. Florida Model Gets Whopping $13.4 Million Payout from Real Estate Tycoon Ex-Husband After Nasty Six-Year Divorce Battle</u>
245G	11/25/15	<u>Palm Beach Daily News. Appellate Court Reverses Palm Beach Sex Offender Jeffrey Epstein's Victory</u>
245H	11/12/15	<u>Daily Business Review. Attorney's Suit Against Billionaire Allowed as Long as Justices Say It's OK</u>
245I	7/8/15	<u>Palm Beach Daily News. Judge Keeps Thousands of Epstein Documents Sealed</u>
245J	6/25/15	<u>WCVB5. Jury Awards $24 Million to Mass. Widower in Fatal Cabana Crash</u>

No.	Date	Description Objection Marked
245K	6/24/15	NBC6. Jury Awards 24 Million in Fatal Cabana
245L	6/24/15	CBS Miami. Jury Awards Millions to Husband of
245M	6/25/15	Sun Sentinel. Jury Awards $24 Million to Widower
245N	1/8/15	Daily Business Review. The Lawyer Suing Legal
245O	4/21/14	The Washington Post. Eleventh Circuit Rules that
245P	4/21/14	Palm Beach Daily News. Appeals Court Rules
245Q	4/21/14	Sun-Sentinel. Victims Win Right to See
245R	4/21/14	Palm Beach Post. Appellate Rut ul orce
		Feds to Reconsider Sex Chan t Palm
245S	10/20/13	calm Beach Daily Ne ewe Lawsuit Against
		Epstein Expected to tim Testimony
245T	9/10/12	CBS Miami, Excl iv • al Assault Victim
		Alleges Abuse Youth Pastor
245U	9/7/12	Sun-Sentinel. leva Fall Nets Woman $13
245V	July 2012	Dail B ' Revi w. Top Florida Verdicts &
		Set emen o 2011
245W	6/13/12	Bus ess Review. Suit Accuses Goldrush
		ri ub of Scheme to Bilk Professionals
245X	4/22/ 1	m Beach Daily Business Review. Jeffrey
246	8/10	Jaffe Weissing's Facebook page with
246A	5/22/16	Lawnewz.com. The Shameful Way Feds Protected
246B	5/13/16	Fox News. Flight Logs Show Bill Clinton Flew on
246C	2/11/16	Sun-Sentinel. Feds Deceived Us About Billionaire
		Sex Offender's 'Sweetheart Deal' Teen Victims Say

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
246D	2/12/16	<u>NBC News. Lawyers: Victims Not Told of 'Sweetheart Deal' for Jeffrey Epstein</u>
246E	2/11/16	<u>NY Daily News. Jeffrey Epstein Accusers Sue Feds Over Hidden Non-Prosecution 'Conspiracy'</u>
246F	4/23/14	<u>[REDACTED], Jaffe. Appeals Court Rules in Favor of Crime Victims' Rights in Registered Pedophile Jeffrey E. Epstein Case</u>
246G	4/23/14	<u>Daily Business Review. Prosecutors Must Turn Over Docs in Billionaire Sex Offender Jeffrey Epstein Case</u>
247	Misc.	Court and arrest information; [REDACTED] <i>James</i> [REDACTED]; Duval County Court, Case No. 16-1995-MM-000074-AXXA-[REDACTED]
248	Misc.	Court and arrest information; [REDACTED] <i>James</i> [REDACTED]; Duval County Case No. 16-1998-CF-004394-AXXX-[REDACTED]
249	8/14/07	Exemption and/or Limitation Exclusion - Tax Assessment of $3,507.72
250	1/7/08	Notice of Satisfaction of Lien Relative to Tax Exemption
251	Misc.	Docket and all court filings referenced therein; <i>U.S. Bank National Association v. Bradley J.</i> [REDACTED]; 17 th Judicial Circuit, Broward County Case No. 2010CA002613AXXXCE
252	1/21/10	Petition/Complaint; <i>U.S. Bank National Association v. Bradley J.</i> [REDACTED]; 17 th Judicial Circuit, Broward County Case No. 2010CA002613AXXXCE
253	2/18/10	[REDACTED] <i>J.</i> [REDACTED] Answer and Affirmative Defenses; [REDACTED] <i>J.</i> [REDACTED] <i>J.</i> [REDACTED] <i>J.</i> [REDACTED]; 17 th Judicial Circuit, Broward County Case No. 2010CA002613AXXXCE
254	8/11/10	Notice of Sale; <i>U.S. Bank National Association v.</i> [REDACTED] <i>J.</i> [REDACTED]; 17 th Judicial Circuit, Broward County Case No. 2010CA002613AXXXCE
255	8/11/10	Final Summary Judgment of Mortgage Foreclosure; <i>U.S. Bank National Association v.</i> [REDACTED] <i>J.</i> [REDACTED]; 17 th Judicial Circuit, Broward County Case No. 2010CA002613AXXXCE
256	10/22/10	Certificate of Sale; <i>U.S. Bank National Association v.</i> [REDACTED] <i>J.</i> [REDACTED]; 17 th Judicial Circuit, Broward County Case No. 2010CA002613AXXXCE

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
257	11/2/10	Certificate of Title; <i>U.S. Bank National Association v. [REDACTED] J. [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2010CA002613AXXXCE
258	Misc.	Docket and all court filings referenced therein; <i>Wells Fargo Bank, N.A. v. [REDACTED] J. [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2010CA012467AXXXCE
259	3/17/10	Petition/Complaint; <i>Wells Fargo Bank, N.A. v. [REDACTED] J. [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2010CA012467AXXXCE
260	10/4/11	Final Summary Judgment of Mortgage Foreclosure; <i>Wells Fargo Bank, N.A. v. [REDACTED] J. [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2010CA012467AXXXCE
261	10/10/11	Notice of Sale; <i>Wells Fargo Bank, N.A. v. Bradley J. [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2010CA012467AXXXCE
262	1/5/12	Certificate of Sale; <i>Wells Fargo Bank, N.A. v. [REDACTED] J. [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2010CA012467AXXXCE
263	1/18/12	Certificate of Title; <i>Wells Fargo Bank, N.A. v. [REDACTED] J. [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2010CA012467AXXXCE
264	Misc.	Docket and all court filings referenced therein; <i>1st United Bank v. Bradley J. [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 11-030427
265	12/8/11	Complaint; <i>1st United Bank v. [REDACTED] J. [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 11-030427
266	1/25/12	Stipulation for Settlement; <i>1st United Bank v. Bradley J. [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 11-030427
267	Misc.	Docket and all court filings referenced therein; <i>Wells Fargo Bank, N.A. v. [REDACTED] [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2012CC003827AXXXWE
268	3/22/12	Complaint; <i>Wells Fargo Bank, N.A. v. [REDACTED] [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2012CC003827AXXXWE
269	5/18/12	[REDACTED] J. [REDACTED] Motion to Dismiss; <i>Wells Fargo Bank, N.A. v. [REDACTED] [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2012CC003827AXXXWE

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
270	10/3/12	Order Denying Motion to Dismiss; <i>Wells Fargo Bank, N.A. v. [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2012CC003827AXXXWE
271	10/26/12	Answer to Complaint; <i>Wells Fargo Bank, N.A. v. [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2012CC003827AXXXWE
272	11/20/12	Mediation Report; <i>Wells Fargo Bank, N.A. v. [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2012CC003827AXXXWE
273	3/15/13	Mediation Report; <i>Wells Fargo Bank, N.A. v. [REDACTED]</i> ; 17 th Judicial Circuit, Broward County Case No. 2012CC003827AXXXWE
274		Corporate Detail Printout from Sunbiz.org for The Law Office of Brad [REDACTED] & Associates, LLC
275	4/16/07	Articles of Organization for Florida Limited Liability Company for The Law Office of Brad [REDACTED] & Associates, LLC
276	1/25/08	2008 Limited Liability Company Annual Report for The Law Office of Brad Edwards and Associates
277	3/11/09	2009 Limited Liability Company Annual Report for The Law Office of Brad Edwards and Associates
278		Florida Bar Rules including, but not limited to, Florida Bar Rule 4-7.21
279	3/3/08	Complaint; <i>Donald D. Baker v. The City of Hollywood, et al.</i> ; Case No. 08-60294-CIV-HUCK (D.E. 1)
280	6/17/08	Omnibus Order on Defendants' Motion to Dismiss; <i>Donald D. Baker v. The City of Hollywood, et al.</i> ; Case No. 08-60294-CIV-HUCK (D.E. 79)
281	8/10/10	U.S. Court of Appeals Opinion; <i>Donald D. Baker v. City of Hollywood, et al.</i> ; Case No. 08-14924 & 08-15602
282	12/9/04	<u>New Times Broward Palm-Beach: <i>Tale of the Tape</i></u>
<b>Experts</b>
283	10/20/17	Dr. Bernard J. Jansen's Expert Report with attachments

No. 284 285 286 287 288 289 290 291 292 293 294 295 296	Date Misc. 9/9/16 11/30/16 Misc. 11/1/09 11/2/09 11/2/09 11/3/09 11/3/09 11/3/09 11/3/09 11/5/09	Description Objection Marked Marked for Id. In Evidence his 10/20/17 Report Bernard J. Jansen in v. Ghislaine Maxwell (USDC NY) 4OAA All public recur Ci Other Articles Rothstein yy Dissolution, Ponzi Scheme i ge: " and is Going into Receivership The New York Times: Fr c ations Against Florida Lawyer Set 0 ace t Return His Donations Rothstein Retur r ntemplating Suicide, Partner Says Florida Law : ks to be Dissolved Seemed od to be True F N r ' ig Funds Probe 11/6/09 dkk. w MU
297	1	othstein Accomplice Still on Lam
298	11	Tour of Scott Rothstein's Office Reveals Gallery of Who's Who
299	11/12/09	Sun Sentinel: FBI Doubts Rothstein Ran a Ponzi Scheme Alone
300	11/13/09	Palm Beach Post: FBI Doubts Rothstein's Scheme a 'One-Man Show'
301	11/13/09	Sun Sentinel. High-Ranking Police Officers Guarded Over Rothstein
302	11/17/09	Inside the Rothstein Swindle, Part I

No.	Date	Description Objection Marked
303	11/17/09	Sun Sentinel. Rothstein Asks to Voluntarily Give
304	11/17/09	Rothstein and Dreier: How Much Alike?
305	11/18/09	Inside the Rothstein Swindle, Part II
306	11/18/09	Former RAA Attorneys Take New Jobs
307	11/20/09	Scherer Files Suit Against Rothstein, et at
308	11/20/09	Article b Paul Brinkman
309	11/21/09	Rothstein Feeder Levin's Ugly Past
310	11/22/09	Levin was Rothstein's Whale
311	11/23/09	Rothstein Associate Levy Got Protection from
312	11/23/09	Main Line Firm's Clients Invested $30 Million with
313	11/23/09	Sun-Sentinel. Scott Rothstein: "You're in To20~
314	11/24/09	Miami Herald. Feds: Scott Rothstein P
315	11/26/09	The Rothstein Wires
316	1/13/10	Sun Sentinel. Florida Bar Lo Former
317	July 2010	Sun Sentinel. 22 Former of t Attorneys
318	10/22/10	South Florida Bus al. A Year After
		Rothstein. Man do s Unanswered
319	10/31/10	The Florida B . Sc othstein Scandal: One
320	1/21/13	Forbes. tern Expose Details Sex. Murder, and
		Corrupti ind Florida's Largest Ponzi Scheme
321	10/13/14	F* e Year on, Rothstein's Ponzi Still Resonates
322	10/3/17	al each Daily News. Epstein Paid Three
323		All public records and news articles relating to
		J. and any witnesses listed by
323A-1	1/15/18	Florida Department of Law Enforcement Criminal
323A-2	Misc.	E.W.'s mugshot arrest information
323A-3	3/17/11	E.W.'s marriage license

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
323A-4	Misc.	Brent Moody's mugshot arrest information
323A-5	Misc.	Gregory [REDACTED] mugshot arrest information
323A-6	Misc.	Property Records for 4140 N.W. 7 th Lane, Delray Beach, Florida
323A-7	N/D	Florida Corporation Division's Records for Moody, Inc.
323A-8	N/D	Florida Corporations Division's Records for C. Moody Enterprises, Inc.
323A-9	N/D	Florida Corporation Division's Records for Courtney Elizabeth, Inc.
323A-10a	Misc.	<i>State of Florida v. E.W.</i> , 11 th Judicial Circuit, Miami Dade County Case No. F12-29832; Court Docket and court documents
323A-10b	12/31/12	<i>State of Florida v. E.W.</i> , 11 th Judicial Circuit, Miami Dade County Case No. F12-29832 - Information
323A-10c		<i>State of Florida v. E.W.</i> , 11 th Judicial Circuit, Miami Dade County Case No. F12-29832 - Case File Sheet
323A-10d	2/19/13	<i>State of Florida v. E.W.</i> , 11 th Judicial Circuit, Miami Dade County Case No. F12-29832 - Notice of Appearance, Waiver of Arraignment, Plea of Not Guilty, Demand for Discovery and Demand for Trial
323A-10e	1/8/14	<i>State of Florida v. E.W.</i> , 11 th Judicial Circuit, Miami Dade County Case No. F12-29832 - Judgment and Sentencing
323A-10f	1/10/14	<i>State of Florida v. E.W.</i> , 11 th Judicial Circuit, Miami Dade County Case No. F12-29832 - Complaint/Arrest Affidavit
323A-11	1/14/18	15 th Judicial Circuit, Palm Beach County Search Results for Eva [REDACTED]
323A-12	1/16/18	15 th Judicial Circuit, Palm Beach County Search Results for E.W.
323A-13	1/16/18	15 th Judicial Circuit, Palm Beach County Search Results for E.W.
323A-14a		<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-1996-GA-00487 - Docket and court documents
323A-14b	8/4/96	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-1996-GA-00487 - Order Approving Settlement of Minor's Tort Claim

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
323A-15a		<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2002-CG-026985-AXXX-MB - Docket
323A-15b	11/12/02	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2002-CG-026985-AXXX-MB - Citations
323A-15c	10/21/03	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2002-CG-026985-AXXX-MB - Judgment
323A-15d	10/21/03	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2002-CG-026985-AXXX-MB - Order Placing Defendant on Probation
323A-15e	1/22/04	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2002-CG-026985-AXXX-MB - Affidavit – Violation of Probation
323A-15f	4/7/04	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2002-CG-026985-AXXX-MB - Amended Affidavit – Violation of Probation
323A-15g	5/22/04	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2002-CG-026985-AXXX-MB - Booking Card
323A-15h	6/17/08	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2002-CG-026985-AXXX-MB - Order for Restitution
323A-15i	6/17/08	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2002-CG-026985-AXXX-MB - Plea
323A-15j	6/17/08	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2002-CG-026985-AXXX-MB - Final Judgment for Fines, Costs and Additional Charges
323A-15k		<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2002-CG-026985-AXXX-MB - Sheriff Information Sheet
323A-15l	6/17/08	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2002-CG-026985-AXXX-MB - Final Judgment for Cost of Supervision Fee
323A-16a		<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2006-CF-16146-AXXX-MB - Docket

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
323A-16b	12/7/06	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2006-CF-16146-AXXX-MB - Booking Card
323A-16c	12/6/06	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2006-CF-16146-AXXX-MB - Arrest/Notice to Appear Report - Aggravated Battery
323A-16d	12/6/06	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2006-CF-16146-AXXX-MB - Boynton Beach Police Department Incident Report
323A-16e	12/7/06	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2006-CF-16146-AXXX-MB - Cross Reference List of Criminal Activity
323A-16f	12/7/06	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2006-CF-16146-AXXX-MB - Order
323A-16g	12/7/06	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2006-CF-16146-AXXX-MB - Application for Criminal Indigent Status
323A-16h	1/4/07	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2006-CF-16146-AXXX-MB - No File for Aggravated Battery
323A-17a		<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2007-CF-008710-AXXX-MB - Docket
323A-17b	7/6/07	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2007-CF-008710-AXXX-MB - No File for Possession of Scheduled IV Substance
323A-18a		<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 2007-MM-013914-AXXX-MB - Docket
323A-18b	6/15/07	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 2007-MM-013914-AXXX-MB - Arrest / Notice to Appear - Possession of a Controlled Substance
323A-18c	6/15/07	Palm Beach County Sheriff's Office Offense Report No. 07-603178

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
323A-18d	6/15/07	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 2007-MM-013914-AXXX-MB - Booking Card
323A-18e	7/9/07	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 2007-MM-013914-AXXX-MB - Information
323A-18f	7/11/07	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 2007-MM-013914-AXXX-MB - Cross Reference List – Criminal Defendant Activity Report
323A-18g	8/6/07	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 2007-MM-013914-AXXX-MB - Plea
323A-18h	8/6/07	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 2007-MM-013914-AXXX-MB - Judgment and Fingerprints
323A-18i	8/6/07	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 2007-MM-013914-AXXX-MB - Collection Agreement
323A-18j	8/6/07	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 2007-MM-013914-AXXX-MB - Order Assessing Additional Charges, Costs and Fines and Entering Judgment
323A-18k	8/6/07	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 2007-MM-013914-AXXX-MB - Plea in the County Court
323A-18l	8/6/07	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 2007-MM-013914-AXXX-MB - Application for Criminal Indigent Status
323A-18m	5/25/08	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 2007-MM-013914-AXXX-MB - Notice to Suspend Driving Privileges
323A-19a		<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2007-MM-021940-AXXX-SB – Docket and Court Filings
323A-19b	9/4/07	Arrest / Notice to Appear – Boynton Beach Police Department - Battery
323A-19c	10/18/07	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2007-MM-021940-AXXX-SB - Information - Battery

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
323A-19d	10/29/07	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2007-MM-021940-AXXX-SB - Cross Reference List – Criminal Defendant Activity
323A-20a		<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2007-TR-163488-AXXX-MB - Docket
323A-20b	6/15/07	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2007-TR-163488-AXXX-MB - Citation
323A-21a		<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2007-TR-166340-AXXX-MB - Docket
323A-21b		<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Case No. 50-2007-TR-166340-AXXX-MB - Citation
323A-22a		<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2007-TR-204547-AXXX-MB - Docket
323A-22b	8/8/07	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2007-TR-204547-AXXX-MB - Citation
323A-23a		<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2009-MM-010876-AXXX-MB - Docket
323A-23b	5/30/09	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2009-MM-010876-AXXX-MB - Arrest / Notice to Appear – Palm Beach County Sheriff's Office Report No. 09-085397
323A-23c	6/23/09	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2009-MM-010876-AXXX-MB - Collection Agreement and Judgment
323A-24a		<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2009-CF-011288-AXXX-MB - Docket
323A-24b	9/5/09	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2009-CF-011288-AXXX-MB - Arrest / Notice to Appear – North Palm Beach Public Safety Report No. 70-09009903
323A-24c	9/5/09	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2009-CF-011288-AXXX-MB - Notice of Arraignment

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
323A-25a		<i>Andrew Pastor, Esq. v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2009-CC-014838 - Docket
323A-25b	9/17/09	<i>Andrew Pastor, Esq. v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2009-CC-014838 - Complaint for Tenant Eviction
323A-25c	10/30/09	<i>Andrew Pastor, Esq. v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2009-CC-014838 - Final Judgment for Possession
323A-26a		<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2009-MM-018257 – Docket and Court Documents
323A-26b	10/9/09	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2009-MM-018257 – First Appearance Disposition Record – Possession of Marijuana
323A-26c	10/9/09	Palm Beach Sheriff's Office Booking Card
323A-27a		<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2009-TR-144682-AXXX-MB - Docket
323A-27b	6/9/09	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2009-TR-144682-AXXX-MB - Citation
323A-28a		<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2009-TR-233639-AXXX-NB - Docket
323A-28b	9/5/09	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2009-TR-233639-AXXX-NB - Citation
323A-29a		<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2010-CF-003921-AXXX-MB – Docket and Court Documents
323A-29b	4/4/10	Arrest / Notice to Appear – Palm Beach Gardens Police Department Report No. 78-10001780 and Probable Cause Affidavit – Possession of Marijuana
323A-29c	9/16/10	<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2010-CF-003921-AXXX-MB Judgment, Sentence and Plea
323A-30a		<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2010-CT-010505-AXXX-NB – Docket and Court Documents

No.	Date Description Objection Marked
323A-	4/4/10 State of Florida v. E.W., 15th Judicial Circuit, Palm
30b	Beach County Case No. 50-2010-CT-010505-
323A-	State of Florida v. E.W., 15th Judicial Circuit, Palm
31a	Beach County Case No. 50-2010-CT-029906-
323A-	7/17/11 Palm Beach County Sheriff's Office Booking Card
323A-	8/19/11 State of Florida v. E.W, 15th Judicial Circuit, Palm 4OAA
31c	Beach County Case No. 50-2010-CT-029906-
323A-	State of Florida v. E.W, 15th Judicial Circuit, Palm 0
32a	Beach County Case No. 50-2010-TR-227746-
323A-	9/15/10 State of Florida v. E.W., 15th Judicial C • ,
32b	Beach County Case No. 50-2010-TR-2 4
323A-33	State of Florida v. E. W, 15th Judi ' ' , Palm
	Beach County Case No. 50-20 27 47-
	AXXX-MB — Docket and C. a ents
323A-	State of Florida v. E.W, 1 i ici 1 Circuit, Palm
34a	Beach County Case N' to 201 -CT-014746-
	AXXX-SB — Dock n. II Documents
323A-	5/20/11 Arrest / Notice t, Palm Beach County
34b	Sheriff's Offi Repo o. 06-11-076192
323A-	5/20/11 Citation
323A-	8/19/11 State of v. E.W., 15th Judicial Circuit, Palm
34d	B h Co ty Case No. 50-201I-CT-014746-
323A-	to f Florida v. E.W., 15th Judicial Circuit, Palm
35a	<ch County Case No. 50-2012-CT-000557-
323A-	1/ 2 Citation
323A-	4/20/12 State of Florida v. E.W., 15th Judicial Circuit, Palm
35c	Beach County Case No. 50-2012-CT-000557-
323A-	7/30/12 Palm Beach County Sheriff's Office Booking Card
35d	Book #2012031810
323A-	8/1/12 State of Florida v. E. W, 15th Judicial Circuit, Palm
35e	Beach County Case No. 50-2012-CT-000557-

No.	Date	Description	Objection	Marked in Evidence	Marked for Id.
323A-36a		<i>State of Florida v. E.W.</i> , 15 th Judicial Circuit, Palm Beach County Case No. 50-2012-CF-005135-AXXX-MB – Docket and Court Documents

Display truncated; use Text to download the complete prepared source.¶