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Record

Draft: efta02775419

PALM BEACH COUNTY. FL SHARON R BOCK. CLERK."

U- •

#29I 874/mep

JEFFREY EPSTEIN,

Plaintiff,

vs.

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

Defendant,

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

CASE NO.: 502009CA040800XXXXMBAG

REVISED 4(<1/4 EXHIBIT LIST OF COUNTERPLAINTIFF.

COMES NOW the Counterplaintiff, BRADLEY J. by and through his undersigned attorneys and hereby lists xhil4s for trial as follows:

DEF. PLF. NO. NO.DATE Ek OFFERED --b— Ci ottDMIT TED DESCRIPTION OF EXHIBITS EXHIBITS EXPECTED TO BE USED
1.6All applicable criminal statutes
2.All applicable Florida Statutes
3.All applicable Rules of Evidence
4.Video of Jeffrey Epstein's home and route from victim to Epstein's home
5.Order confirmation from Amazon.com for purchase of books

Case No.: 502009CA040800)OOaMBAG

REVISED EXHIBIT LIST OF COUNTERPLAINTIFF,

Page 2 of II

DEF. PLF. DATE
OFFEREDMARK ADMIT
TEDDESCRIPTION OF EXHIBITS Abernathy:
A Workbook for Erotic Slaves and Their ners"
6.Non-Prosecution Agreement
7.Jane Doe 102 Complaint
8.Messages taken from m and at Epstein's home
Documents related • e pstein produced by Alfredo Rodriguez
10.Jeffrey Epst ' i
Jeffre 'n ne records
12.n's phone records
13.J isitation Logs
14.Jeffrey Epstein's probation file
1 5.YYAll probable cause affidavits related to criminal investigation of Jeffrey Epstein
17.Victims' statements to the FBI related to criminal investigation of Jeffrey Epstein executed
19.Application for Search Warrant of Jeffrey Epstein's home
20Complaint Jane Doe v. Epstein and all subsequent Amended Complaints
21.All records of homes, properties, bank accounts and any and all records related to Jeffrey Epstein's assets
22.Jeffrey Epstein's passport (or copy)
23.Jeffrey Epstein's driver's license (or copy)

Case No.: 502009CA040800,OOOCMBAG

REVISED EXHIBIT LIST OF COUNTERPLAINTIFF,

Page 3 of II

DEF. NO.PLF. NO.DATE OFFEREDMARKADMIT TEDDESCRIPTION OF EXHIBITS
24.List of corporations owned by Jeffrey Epstein
25.All documents evidencing relationship between Jeffrey Epstein and Jean Luc Brunel
26.All documents evidencing relationship between Jeffrey Epstein and MC2 or any modeling agencies
27.Yearbooks of Jane Doe
28.2002 [REDACTED] Palm Beach High School Year Book
29.2001 [REDACTED] Palm Beach High School Year Book
30.2003 Palm Beach Gardens High School Year Book
31.Affidavit and Application for Search Warrant on Jeffrey Epstein's home
32.Tape recording or transcript of recording of conversation between Jeffrey Epstein and [REDACTED] Rush
33.Notepads found in Jeffrey Epstein's home and/or during trash pulls outside of his home during criminal investigation
34.The Palm Beach State Attorney's Criminal file against Jeffrey Epstein
35.All documents related to Jeffrey Epstein's 6/30/08 conviction
36.Jeffrey Epstein's criminal plea colloquy
37.Public records from the Department of Corrections related to Jeffrey Epstein
38.Records from the Florida Department of Law Enforcement related to Jeffrey Epstein
39.All statements made by Jeffrey Epstein
40.List of properties and vehicles in Larry Visoski's name
41.All of Jeffrey Epstein's Responses to Requests for Production, Requests for Admission, Answers to Interrogatories in this matter, and cases 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092

Case No.: 502009CA040800)000CMBAG

REVISED EXHIBIT LIST OF COUNTERPLAINTIFF,

Page 4 of II

DEF. NO.PLF. NO.DATE OFFEREDMARKADMIT TEDDESCRIPTION OF EXHIBITS
42.All discovery related responses of Jeffrey Epstein in this matter and cases 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802

09-81092
43.Jeffrey Epstein's Answers and Affirmative Defenses in all civil cases against him
44.All Complaints in which Jeffrey Epstein was a plaintiff or defendant
45.Jeffrey Epstein's Deposition testimony and discovery responses in this case and cases 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092
46.Jeffrey Epstein's Deposition testimony and discovery responses in State Court cases LM v. Jeffrey Epstein, Case No. 502008CA028051XXXXMB AB and E.W. v. Jeffrey Epstein, Case No. 502008CP003626XXXXMB
47.Jeffrey Epstein Deposition Testimony and discovery responses in State Court case Jeffrey Epstein v. Scott Rothstein, et al. Case No. 502009CA040800XXXXMBAG
48.Any and all newspaper articles, online articles or publications related to Jeffrey Epstein
49.Report and Analysis of Jeffrey Epstein's assets
50.Video footage (DVD) of walk through site inspection of Jeffrey Epstein's home.
51.Photos of all of Jeffrey Epstein's properties, cars, boats and planes
52.Probable Cause Affidavits prepared against Jeffrey Epstein and [REDACTED]
53.Audio tape of [REDACTED]
54.Photographs, videos and books taken in the search warrant of Jeffrey Epstein's home
55.Documents related to or evidencing Jeffrey Epstein's donations to law enforcement
56.Victim Notification Letter from US Attorney's Office to Victim

Case No.: 502009CA040800XXXXMBAG

REVISED EXHIBIT LIST OF COUNTERPLAINTIFF,

Page 5 of I I

PLF. DATE DEF.
OFFERED MARK ADMIT
TEDDESCRIPTION OF EXHIBITS
57Expert Dr. L. Dennison Report of Victim
58Palm Beach Police Department Incident It ort dated 4/20/06
59.All reports and documentation gen by Im Beach Police
Department related to Jeffrey E i
60.All Witness Statements gener ed b m Beach Police
Department relating to Jeffrey t
61.Passenger Manifests of Jeffrey pstein's aircraft and private plane flight logs
62Passenger lists f, taken by Jeffrey Epstein
/ fr‘
63.Letter from y to Alberto Pinto regarding house island yolk
64JeffreVtistea's bank statements
..-.4.44. N ffreNpstein's tax returns
65.C2 emails involving communications of Jeffrey Epstein, and Amanda Grant DVD of plea and colloquy taken on 6-30-08 CS) Transcript of plea and colloquy taken on 6-30-08 Massage Table I'lli
69. OLotions taken from Jeffrey Epstein's home during search warrant warrant
l e
71.Vibrators, dildos and other sex toys taken from Jeffrey Epstein's home during search warrant
72.No Contact Orders entered against Jeffrey Epstein
73Criminal Score Sheet regarding Jeffrey Epstein
74.Documents evidencing Jeffrey Epstein's Community

Case No.: 502009CA040800XXXXMBAG

REVISED EXHIBIT LIST OF COUNTERPLAINTIFF,

Page 6 of I I

DEF. NO.PLF. NO.DATE OFFEREDMARKADMIT TEDDESCRIPTION OF EXHIBITS
Control and Probation
75.Jeffrey Epstein's Sex Offender Registration
76.Jeffrey Epstein's Booking photograph
77.CAD calls to 358 EL BRILLO WAY, PALM BEACH FL 33480
78.List of Jeffrey Epstein's House contacts
79.Documents related to Jeffrey Epstein's investments
80.Letter from Chief Michael Reiter to Barry Krischler
81.List of planes owned by Jeffrey Epstein
82.Letter from Guy Fronstin to Assistant State Attorney dated 1-11-06
83.Letter from Guy Fronstin to Assistant State Attorney dated 1-13-06
84.Letter from Guy Fronstin to Assistant State Attorney dated 2-17-06
85.Letter from Guy Fronstin to Assistant State Attorney dated 4-6-06
86.Letter from Guy Fronstin to Assistant State Attorney dated 4-10-06
87.Letter from Goldberger dated 6-22-06
88.All subpoenas issued to State Grand Jury
89.Documents related to the rental of a vehicle for [REDACTED]
90.Ted's Sheds Documents
91.Documents related to property searches of Jeffrey Epstein's properties
92.Arrest Warrant of [REDACTED]
93.Police report regarding [REDACTED] picking up money dated 11-28-04

[REDACTED] adv. Epstein

Case No.: 502009CA040800XXXXMBAG

REVISED EXHIBIT LIST OF COUNTERPLAINTIFF, [REDACTED]

Page 7 of 11

DEF. NO.PLF. NO.DATE OFFEREDMARKADMIT TEDDESCRIPTION OF EXHIBITS
94.List of Trilateral Commission Members of 2003
95.Alan Dershowitz Letter dated 4-19-06 and Statute 90.410
96.Guy Fronstin letter dated 4-17-06
97.Jeffrey Epstein Account Information
98.Jeffrey Epstein Criminal Closeout Sheet
99.Jeffrey Epstein Polygraph Test and Results
100.Victim's GED testing information and results
101.JEGE, Inc. Passenger Manifest
102.Hyperion Air Passenger Manifest
103.Flight information for [REDACTED]
104.Passenger List Palm Beach flights 2005
105.Jeffrey Epstein notepad notes
106.Pleadings of Jane Doe 1 and 2 v. US case
107.Jeffrey Epstein 5 th Amendment Speech
108.Reiter letter to Krisher dated 5-1-06
109.Jail receipts of Jeffrey Epstein
110.[REDACTED] Police Report dated 11-28-04
111.Compulsory Medial Examination of victim, CMA
112.Victim's school records and transcripts
113.Victim Notification letter dated 7-9-08

Case No.: 502009CA040800XXXXMBAG

REVISED EXHIBIT LIST OF COUNTERPLAINTIFF,

Page 8 of 11

DATE DEF. PLF.
OFFEREDMARK ADMIT TED DESCRIPTION OF EXHIBITS Victim's employment records from IHOP
115.Police report of Juan Alessi theft at Jeffre pstein's home
116.Victim's Medical Records from ?A' iris uvenile Facility
117.Victim's Medical Records fro dee Speciale
119.Victim's Medic from St. Mary's Medical Center
120Victim's e cords from United Health
121.A 1 I: e conducted by law enforcement on Jeffrey
' ome
122.ail received from Palm Beach Records related to Jeffrey tel
Ep in
124.All items taken in the execution of the search warrant of Jeffrey Epstein's home: 358 EL BRILLO WAY, VC PALM BEACH FL 33480 All copies of convictions related to Jeffrey Epstein all'. Jeffrey Epstein criminal records
126. ( S e
lk i OAll documents produced by Palm Beach Police Department prior to the deposition of Detective Recarey
129Statements, deposition transcripts, videotaped depositions and transcripts taken in connection with this and all related cases and exhibits thereto
130.Any and all expert witness reports and/or records generated
131.Curriculum vitaes of any and all listed experts
132.Curriculum vitae of Dr. Ryan

Case No.: 502009CA040800XXXXMBAG

REVISED EXHIBIT LIST OF COUNTERPLAINTIFF,

Page 9 of I I

DEF. NO.PLF. NO.DATE OFFEREDMARKADMIT TEDDESCRIPTION OF EXHIBITS
133.Any articles or publications of Dr. Ryan █
134.Any articles or publications of Dr. Richard Hall
135.Any articles or publications of Dr. L. Dennison █
136.All items and documentation review by Dr. L. Dennison █
137.Transcript and video (DVD) of IME of Victims
138.All exhibits to Dr. L. Dennison █ Deposition
139.All exhibits to Dr. Richard █ Deposition
140.All items and documents reviewed by Dr. Richard █
141.All items and documents reviewed by Dr. Ryan █
142.All exhibits listed on the Epstein's Exhibit List
143.Demonstrative aids and exhibits including, but not limited to, anatomical charts, diagrams and models, surveys, photographs and similar material including blow-ups of the aforesaid items.
144.Any and all mortality tables
145.█ reserves all objections to Epstein's Exhibits
146.█ reserves the right to supplement and/or amend his Exhibit List
147.By listing an Exhibit, █ is not waiving his right to object to same at trial and does not waive their right to amend same.
148.All exhibits listed by Epstein subject to █ objections.
149.All pleadings and attachments in the action under the Crime Victims Rights Act prosecuted by █ █ on behalf of victims of Epstein's criminal molestations.
150.All attachments to █ Motion for Summary Judgment.

Case No.: 502009CA040800=OCMBAG

REVISED EXHIBIT LIST OF COUNTERPLAINTIFF,

Page 10 of II

DEF. PLF. DATE
OFFEREDMARK ADMIT
TEDDESCRIPTION OF EXHIBITS
151.All time records and hourly billing documentation produced in discovery.
152.All deposition testimony and discovery submitted in this action.ones by Epstein
153.All pleadings filed by Epstein in tl bankruptcy proceeding.hste
154.All submissions by Epstein i deposition.• n with the Rothstein
155.All Settlement Agreeme of his sexual moleifakans.een Epstein and victims

Plaintiff reserves the right to amend this list.

I HEREBY CERTIFY that a true and y of the foregoing has been furnished by E-Service to all counsel on the attached li

law.com; mep®searcylaw.com

ar No.: 169440

Denney Scarola Barnhart & Shipley, P.A.

9 Palm Beach Lakes Boulevard

West Palm Beach, Florida 33409

Phone: (561) 686-6300

Fax: (561) 383-9451

Attorneys for J.

Case No.: 502009CA04080000OMBAG

REVISED EXHIBIT LIST OF COUNTERPLAINTIFF,

Page I I of I I

COUNSEL LIST

Jack A. Goldberger, Esquire

jgoldberger@agwpa.com;

smahoney@agwpa.com

Atterbury, Goldberger & Weiss, P.A.

250 Australian Avenue South, Suite 1400

West Palm Beach, FL 33401

Phone: (561)-659-8300

Fax: (561)-835-8691

Attorneys for Jeffrey Epstein

J. Esquire

staff.efile®pathtojustice.com

=, Jaffe, Weissing, Fistos

Lehrman, FL

425 North Andrews Avenue, Suite 2

Fort Lauderdale, FL 33301

Phone: (954) 524-2820

Fax: (954) 524-2822

Fred Haddad, Esquire

Dee®FredHaddadLaw.com;

haddadfin@aol.com

Fred Haddad, P.A.

One Financial Plaza, Sui

Fort Lauderdale, ?F S 333 , +0

Phone: (954)-467-6767

Fax: (954)467-3599

Attorneys for Jeffrey E

Marc S. Nurik,

marc@nurikla

Law Offices o S. Nurik

One E Blvd., Suite 700

Fort e, FL 33301

-745-5849

-745-3556

ys for Scott Rothstein

onja Haddad Coleman, Esquire

tonja@tonjahaddad.com;

Debbie@Tonjahaddad.com

Tonja Haddad, P.A.

315 SE 7th Street, Suite 301

Fort Lauderdale, FL 33301

Phone: (954)467-1223

Fax: (954)-337-3716

Attorneys for Jeffrey Epstein

Draft: efta02775419

Other records

Prepared source

PALM BEACH COUNTY. FL SHARON R BOCK. CLERK." U- • 29I 874/mep JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, J. individually, and L.M., individually, Defendant, IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG REVISED 4(\<1/4 EXHIBIT LIST OF COUNTERPLAINTIFF. COMES NOW the Counterplaintiff, BRADLEY J. by and through his undersigned attorneys and hereby lists xhil4s for trial as follows: | DEF. PLF. NO. NO. | DATE Ek OFFERED --b— C | i ottDMIT TED DESCRIPTION OF EXHIBITS EXHIBITS EXPECTED TO BE USED | …