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Epstein Release Interview Victim Statements Evidence Maxwell
← Back to Epstein v. Rothstein, No. 50-2009-CA-040800-XXXX-MB (Fla. 15th Cir. Ct. 2009)
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Filing E-Filed AM EXHIBIT A FILED PALM BEACH COUNTY FL SHARON BOCK CLERK AM Filing E-Filed AM JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendants IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO COUNTER-PLAINTIFFS BRADLEY EDWARDS SECOND AMENDED EXHIBIT LIST COMES NOW the Counter-Plaintiff BRADLEY EDWARDS and hereby files his Amended Exhibit List as follows INDEX TO OBJECTIONS No objection All objections All objections except authenticity Irrelevant or immaterial Probative value substantially outweighed by danger of unfair prejudice confusion of issues misleading the jury or needless presentation of cumulative evidence Privileged Opinion Hearsay Authenticity lacking Other please identify basis of objection Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Second Amended Exhibit List Counter-Plaintiff Marked Marked for No Description of Exhibit Objection in Evidence Identification All applicable criminal statutes All applicable Florida Statutes Photos and information of Jeffrey Epsteins homes airplanes and automobiles Order confirmation from Amazon.com for purchase of books SM A Realistic Introduction Slave Craft Roadmap for Erotic Servitude-Principles Skills and Tools and Training Miss Abernathy A Workbook for Erotic Slaves and Their Owners Non-Prosecution Agreement Jane Doe Complaint Messages taken from message pads found at Epsteins home Documents related to Jeffrey Epstein produced by Alfredo Rodriguez Jeffrey Epsteins flight logs Jeffrey Epsteins phone records Sarah Kellens phone records Jail Visitation Logs Jeffrey Epsteins probation file All probable cause affidavits related to criminal investigation of Jeffrey Epstein Victims statements to the FBI related to criminal investigation of Jeffrey Epstein Video of Epstein Property Inspection Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Second Amended Exhibit List Application for Search Wan-ant of Jeffrey Epsteins home Complaint Jane Doe Epstein and all subsequent Amended Complaints All records of homes properties bank accounts and any all records related to Jeffrey Epsteins assets Jeffrey Epsteins passport or copy Jeffrey Epsteins drivers license or copy List of corporations owned by Jeffrey Epstein Yearbooks of Jane Doe Royal Palm Beach High School Year Book Royal Palm Beach High School Year Book Palm Beach Gardens High School Year Book Affidavit and Application for Search WaITant on Jeffrey Epsteins home from Palm Beach State Attorneys File Exhibit Notepads found in Jeffrey Epsteins home and/or during trash pulls outside of his home during criminal investigation The Palm Beach State Attorneys Criminal file against Jeffrey Epstein All documents related to Jeffrey Epsteins conviction Jeffrey Epsteins criminal plea colloquy List of properties and vehicles in Larry Visoskis name Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Second Amended Exhibit List All of Jeffrey Epsteins Responses to Requests for Production Requests for Admission Answers to InteITogatories in this matter and in cases All discovery related responses of Jeffrey Epstein in this matter and in cases Jeffrey Epsteins Answers and Affirmative Defenses in all civil cases against him All Complaints in which Jeffrey Epstein is/was a defendant Jeffrey Epsteins Deposition testimony and discovery responses in this case and in cases Jeffrey Epsteins Deposition testimony and discovery responses in State Court cases LM Jeffrey Epstein Case No AB and E.W Jeffrey Epstein Case No Jeffrey Epstein Deposition Testimony and discovery responses in State Court case Jeffrey Epstein Scott Rothstein et al Case No Any and all newspaper aicles online articles or publications related to Jeffrey Epstein Report and Analysis of Jeffrey Epsteins assets Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Second Amended Exhibit List Video footage DVD of walk through site inspection of Jeffrey Epsteins home Photos of all of Jeffrey Epsteins properties cars boats and planes Probable Cause Affidavits prepared against Jeffrey Epstein and Sarah Kellen Documents related to or evidencing Jeffrey Epsteins donations to law enforcement Victim Notification Letter from US Attorneys Office to Victims CW SR Expert Dr Dennison Reeds Report of Victim Palm Beach Police Department Incident Report dated All reports and documentation generated by Palm Beach Police Department related to Jeffrey Epstein All Witness Statements generated by Palm Beach Police Department relating to Jeffrey Epstein Passenger Manifests of Jeffrey Epsteins aircraft and private plane flight logs Passenger lists for flights taken by Jeffrey Epstein Letter from Jeffrey Epstein to Alberto Pinto regarding house island project Jeffrey Epsteins bank statements Jeffrey Epsteins tax returns MC2 emails involving communications of Jefli-ey Epstein Jeff Fuller Maritza Vasquez Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Second Amended Exhibit List Pappas Suat Jean Luc Brunel and Amanda Grant DVD of plea and colloquy taken on Transcript of plea and colloquy taken on Palm Beach Police Department Incident Report dated unredacted No Contact Orders entered against Jeffrey Epstein Criminal Score Sheet regarding Jeffrey Epstein Documents evidencing Jeffrey Epsteins Community Control and Probation Jeffrey Epsteins Sex Offender Registrations from various states Jeffrey Epsteins Booking photograph CAD calls to EL BRILLO WAY PALM BEACH FL List of Jeffrey Epsteins House contacts Documents related to Jeffrey Epsteins investments Letter from Chief Michael Reiter to Barry Krischler Palm Beach Police Department Incident Report dated redacted Letter from Guy Fronstin to Assistant State Attorney Letter from Guy Fronstin to Assistant State Attorney Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Second Amended Exhibit List Letter from Guy Fronstin to Assistant State Attorney Letter from Guy Fronstin to Assistant State Attorney Letter from Guy Fronstin to Assistant State Attorney Letter from Goldberger All subpoenas issued to State Grand Jury Documents related to the rental of a vehicle for Vanessa Zalis Teds Sheds Documents Documents related to property searches of Jeffrey Epsteins properties AITest Wa1Tant of Sarah Kellen Police report regarding Alexandra Hall picking up money dated List of Trilateral Commission Members of Alan Dershowitz Letter dated and Statute Guy Fronstin letter dated Jeffrey Epstein Account Information Jeffrey Epstein Criminal Closeout Sheet JEGE Inc Passenger Manifest Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Second Amended Exhibit List Hyperion Air Passenger Manifest Flight information for Dana Bums Passenger List Palm Beach flights Jeffrey Epstein notepad notes re Maria Pleadings of Jane Doe and US case Jeffrey Epstein 5th Amendment Speech Reiter letter to Krisher Alexandra Hall Police Report Victims school records and transcripts Victim Notification letter to Virginia Roberts Police report of Juan Alessi theft at Jeffrey Epsteins home Victims Medical Records from Dr Randee Speciale All surveillance conducted by law enforcement on Jeffrey Epsteins home Emails received from Palm Beach Records related to Jeffrey Epstein All items listed on the Palm Beach Police Property Report Lists and/or Property Receipts All copies of convictions related to Jeffrey Epstein Jeffrey Epstein criminal records All documents produced by Palm Beach Police Department prior to the deposition of Detective Recarey Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Second Amended Exhibit List Statements deposition transcripts videotaped depositions and transcripts taken in connection with this and all related cases and exhibits thereto Any and all expert witness reports and/or records generated in preparation for this litigation by any party to this cause Demonstrative aids and exhibits including but not limited to charts diagrams and models surveys photographs and similar material including blow-ups of the listed items/exhibits Edwards reserves all objections to Epsteins Exhibits Edwards reserves the right to supplement and/or amend his Exhibit List By listing an Exhibit Edwards is not waiving his right to object to same at trial and does not waive their right to amend same All exhibits listed by Epstein subject to Edwards objections All pleadings and attachments in the action under the Crime Victims Rights Act prosecuted by Bradley Edwards on behalf of victims of Epsteins criminal molestations Edwards Motions for Summary Judgment all attachments thereto and all Undisputed Facts All time records and hourly billing documentation produced in discovery All deposition testimony and discovery responses by Epstein submitted in this action Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Second Amended Exhibit List All pleadings filed by Epstein in the Rothstein bankruptcy proceeding All submissions by Epstein in connection with the Rothstein deposition All Settlement Agreements between Epstein and victims of his sexual molestations Phone Journal taken from Epsteins home and produced to the FBI by Alfredo Rodriguez Photo depicting Virginia Roberts Ghislaine Maxwell and Prince Andrew All flight logs for any Jeffrey Epstein owned or controlled aircraft All emails produced by Defendant and/or all emails produced by Plaintiff in this case Evidence of contributions to the Palm Beach Police Dept Dr Bernard Jansen Expert Rep011 Attachments and Back-up Documents October Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Complaint December Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Fourth Amended Counterclaim January Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Plaintiff/Counter-Defendant Jeffrey Epsteins Answer and Affirmative Defenses to Defendant/Counter-Plaintiff Bradley Edwards Fourth Amended Counterclaim February Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Second Amended Exhibit List Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Notice of Voluntary Dismissal August Brad Edwards Times Records and Billing Records related to this matter Jeffrey Epsteins NY State Online Sex Offender Registry Profile New York Post article Billionaire Jeffrey Epstein Im a sex offender not a predator February Medical Records New York Presbyterian Hospital re Virginia Guiffre Hand Drawing of Bart Simpson signed by Matt Groening Proposed Joint Letter to the Special Master Front and Back of Hard Copy Color Photo Virginia Mar-A-Lago Color photo of Virginia Roberts on ferry New York Scenic photo of Time Square Virginia Roberts photo on back of ship Picture of room in New York Color photo of man on horse New Mexico Ranch Color photo of Virginia Roberts at Zorro Ranch standing in front of gate sign with New Mexico Ranch Virginia Roberts photo on horse front of ranch Virginia Roberts photo standing against rocks red coat Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Second Amended Exhibit List Virginia Roberts standing against rocks red coat far with back photo white back date Virginia Robe1is photo riding horse blue jacket far Virginia Roberts photo on side of horse hand up Virginia Roberts photo on side of horse Virginia Roberts photo outside next to tables Virginia Roberts photo red coat leaning on rail Virginia Roberts photo standing outside next to fireplace Virginia Roberts photo standing in front of ranch Virginia Roberts photo with hand over head black/white Virginia Roberts photo standing next to piano Virginia Roberts photo in front of fireplace museum Virginia Roberts photo in front of wagon in museum Color photo of Virginia Roberts in front of museum exhibition Santa Fe New Mexico Photograph in Spain Jeffrey Epstein and Ghislaine Maxwell in front of building Virginia Roberts Australia Storage Photo Book Cover photo book Scenic photo with back photo white Scenic photo with back photo white Scenic photo with back photo white Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Second Amended Exhibit List Scenic photo with back photo white Virginia Roberts steps with trees overhead Scenic photo with back photo white Scenic photo with back photo white Scenic photo with back photo white Scenic photo with back photo white Scenic photo with back photo white and black Scenic photo with back photo white and black Scenic photo with back photo white and black Virginia Roberts on steps with children with back photo white and black Virginia Roberts on street white wall far with back photo white and black Travel envelope Singapore Airlines Travel Cover with handwritten notes by Virginia Roberts Thailand Hotel Receipts Court Docket for Jane Doe No Epstein Typed List of Victims Co-Conspirators unique to the investigation of Jeffrey Epstein Ghislaine Maxwell deposition FBI Form Interview of Virginia Giuffre in Australia Redacted Mark Epstein Deposition Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Second Amended Exhibit List March email of Assistant U.S Attorney Ann Marie Villafana Summary of the Case Coonan File Color photos of Ghislaine Maxwell one with Jeffrey Epstein Airport Codes Demonstrative March New York Post Uppity Tranny to Epstein Pay Up DVD of Epstein PBPD El Brillo Search Wan-ant Walk Through DVD Audio from Cassettes Part Alex Hall Redacted Transcript taken by Detective Joe Recarey and Detective Dawson with Exhibits Palm Beach Police Investigation Palm Beach PD Records Wachovia Bank Account Folder titled Sara Kellen Cell Phone Summary by Detective Recarey Enclosing phone records SAO FOIA Disc State Files Folder titled Sara Kellen Cell Sara Kellen Cell Phone Usage Folder titled Sara Kellen AT February Statement Demand Deposit Account Statement History for Household Bank Account Jeffrey Epstein or Ghislaine Maxwell or Alfredo Rodriguez Santa Monica Police Report May Folder titled PLANES lnforn1ation relating to Epsteins planes/aircrafts collected by the State Attorneys Office unique to the investigation of Jeffrey Epstein Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Second Amended Exhibit List Palm Beach House/Information Sheet Sworn Statement of Juan Alessi taken by Palm Beach Police Department Juan Alessi Deposition Vol I Juan Alessi Deposition Vol II Brochure for Boeing Super Passport application issued January Sentencing Transcript Alfredo Rodriguez Criminal Complaint Alfredo Rodriguez Plea Agreement Alfredo Rodriguez Photos of Jeffrey Epsteins properties and planes Photos of Jeffrey Epstein employees and former employees Jeffrey Epstein Guilty Plea documents Palm Beach County State Attorneys Response to Public Records Request including audio recordings Any and all responses to Subpoenas Duces Tecum with or without deposition All Interrogatories and Answers thereto Requests to Produce and Responses Requests for Admissions and Responses thereto Any and all documents produced in this action Any and all depositions taken in this action Any documents or other exhibit attached to or used during any deposition in this action Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Second Amended Exhibit List Any and all exhibits documents etc referred to in any deposition Any and all documents and exhibits designated by all parties to this action Any and all exhibits needed for impeachment or rebuttal Any and all pleadings filed in this action Any and all records produced or that will be produced by all records custodians relative to this action I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve I to all Counsel on the attached list this day of Flor a At E-Mail jsx searcylaw.com and searcylaw.com Primary E-Mail scarolateam searcylaw.com Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida Phone Fax Attorneys for Bradley Edwards Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Second Amended Exhibit List COUNSEL LIST Jack Scarola Esquire scarolateam searcylaw.com Searcy Denney Scarola Barnhart Shipley PA Palm Beach Lakes Boulevard West Palm Beach FL Phone Fax Attorneys for Bradley Edwards Scott Link Esq Link Rockenbach P.A Scott linkrocklaw.com Kara linkrocklaw.com Palm Beach Lakes Boulevard Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein William Chester Brewer Esquire wcblaw aol.com wcblawasst gmail.com Australian A venue Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Jack A Goldberger Esquire jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss P.A Australian A venue Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Second Amended Exhibit List Bradley Edwards Esquire staff.efile pathtojustice.com Farmer Jaffe Weissing Edwards Fistos Lehrman P.L Andrews Avenue Suite Fort Lauderdale FL Phone Fax Tonja Haddad Coleman Esquire tonja tonjahaddad.com efiling tonjahaddad.com Tonja Haddad P.A SE 7th Street Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein Marc Nurik Esquire marc nuriklaw.com One Broward Blvd Suite Fort Lauderdale FL Phone Fax Attorneys for Scott Rothstein Filing E-Filed AM JEFFREY EPSTEIN Plaintiff/Counter-Defendant SCOTT ROTHSTEIN individually and BRADLEY EDWARDS individually Defendants/Counter-Plaintiff I IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Case No PLAINTIFF/COUNTER-DEFENDANTS OBJECTIONS TO DEFENDANT COUNTER-PLAINTIFFS SECOND AMENDED EXHIBIT LIST Plaintiff/Counter-Defendant Jeffrey Epstein Epstein hereby files his Objections to Defendant/Counter-Plaintiff Bradley Edwards Edwards Second Amended Exhibit List dated December and states PRELIMINARY STATEMENT On November Edwards filed his Amended Exhibit List identifying exhibits D.E On November Epstein filed his Objections to Edwards exhibits D.E In addition on November Epstein filed his Revised Omnibus Motion in Limine which in part addressed those objections D.E The Court heard extensive arguments on Epsteins objections at special set hearings on November and December and made rulings on those objections While to date an Order has not been entered memorializing those rulings Epstein incorporates them herein On December Edwards filed a Second Amended Exhibit List identifying exhibits which modified some of his earlier disclosed exhibits and identified new items D.E At no time during the special set hearings did Edwards counsel advise the Court that he intended to amend the Exhibit List or that the parties and Court were working from an incorrect list Epstein will be filing a renewed Motion in Limine to address Edwards newly disclosed exhibits For ease of reference Epstein has highlighted the changes and new items identified LEGEND FOR OBJECTIONS All Objections All Objections except Authenticity Relevance OBJECTIONS Probative value substantially outweighed by danger of unfair prejudice confusion of issues misleading the jury or needless presentation of cumulative evidence Privileged Opinion Hearsay Authenticity Other please identify basis of objection Completeness Overbroad Not provided to Counsel for Epstein Prior to Filing Pretrial Stipulation Not a proper exhibit Trade secrets/Confidential No Edwards Exhibit Description Epsteins Objections All applicable criminal statutes All applicable Florida Statutes Photos and information of Jeffrey Epsteins homes airplanes and automobiles While Edwards produced many of the new exhibits on November he never identified them as trial exhibits on his Exhibit List and Epstein was not aware that he intended to rely on them at trial at the time of filing his Omnibus Motion in Limine No Edwards Exhibit Description Epsteins Objections Order confirmation from Amazon.com for purchase of books SM A realistic Introduction Slave Craft Roadmap for Erotic Servitude-Principles Skills and Tools and Training Miss Abernathy A Workbook for Erotic Slaves and Their Owners Non-Prosecution Agreement Jane Doe Complaint Messages taken from message pads found at Epsteins home Documents related to Jeffrey Epstein produced by Alfredo Rodriguez Jeffrey Epstein flight logs Jeffrey Epstein phone records Sarah Kellens phone records Jail Visitation Logs Jeffrey Epsteins probation file All probable cause affidavits related to criminal investigation of Jeffrey Epstein Victims statements to the FBI related to criminal investigation of Jeffrey Epstein iVideo E:Rstein Pro:RertY lns:Rection,1 Application for Search Warrant of Jeffrey Epsteins home Cannot be read Complaint Jane Doe Epstein and all subsequent as to Amended Complaints subsequent Amended Complaints All records of homes properties bank accounts and any all records related to Jeffrey Epsteins assets Jeffrey Epsteins passport or copy Jeffrey Epsteins drivers license or copy Cannot be read List of corporations owned by Jeffrey Epstein Yearbooks of Jane Doe Royal Palm Beach High School Year Book Royal Palm Beach High School Year Book Palm Beach Gardens High School Year Book No Edwards Exhibit Description Epsteins Objections Affidavit and Al plication for Search Warrant on Jeffrey Epsteins home from Palm Beach State Attorneys File Exhibit Notepads found in Jeffrey Epsteins home and/or during trash pulls outside of his home during criminal investigation The Palm Beach State Attorneys Criminal file against Jeffrey Epstein All documents related to Jeffrey Epsteins conviction Jeffrey Epsteins criminal plea colloquy List of properties and vehicles in Larry Visoski name The exhibit provided was an entire Motion which was denied not just the identified item All of Jeffrey Epsteins Responses to Requests for Production Requests for Admission Answers to Interrogatories in this matter and cases All discovery related responses of Jeffrey Epstein in this matter and cases Jeffrey Epsteins Answers and Affirmative Defenses in all civil cases against him All Complaints in which Jeffrey Epstein is/was defendant This also includes a motion which is not part of the stated exhibit Jeffrey Epsteins Deposition testimony and discovery responses in this case and cases Jeffrey Epsteins Deposition testimony and discovery responses in State Court cases LM Jeffrey Epstein Case No AB and E.W Jeffrey Epstein Case No Jeffrey Epstein Deposition Testimony and discovery responses in State Court case Jeffrey Epstein Scott Rothstein et al Case No No Edwards Exhibit Description Epsteins Objections Any and all newspaper articles online articles or publications related to Jeffrey Epstein Report and Analysis of Jeffrey Epsteins assets Video footage DVD of walk through site inspection of Jeffrey Epsteins home Photos of all of Jeffrey Epsteins properties cars boats and as to planes cars and boats Probable Cause Affidavits prepared against Jeffrey Epstein and Sarah Kellen Documents related to or evidencing Jeffrey Epsteins donations to law enforcement Victim Notification Letter from US Attorneys Office to Victims CW SR Expert Dr Dennison Reeds Report of Victim Palm Beach Police Department Incident Report dated All reports and documentation generated by Palm Beach Police Department related to Jeffrey Epstein All Witness Statements generated by Palm Beach Police Department relating to Jeffrey Epstein Passenger Manifests of Jeffrey Epsteins aircraft and private plane flight logs Passenger lists for flights taken by Jeffrey Epstein Letter from Jeffrey Epstein to Alberto Pinto regarding house island project Jeffrey Epsteins bank statements Jeffrey Epsteins tax returns MC2 emails involving communications of Jeffrey Epstein Jeff Fuller Maritza Vasquez Pappas Suat Jean Luc Brunel and Amanda Grant DVD of plea and colloquy taken on Transcript of plea and colloquy taken on Palm Beach Police DeQartment Incident ReQort dated o7 unredacted No Contact Orders entered against Jeffrey Epstein Criminal Score Sheet regarding Jeffrey Epstein Documents evidencing Jeffrey Epsteins Community Control and Probation No Edwards Exhibit Description Epsteins Objections Jeffrey Epsteins Sex Offender Registrations from various states Jeffrey Epsteins Booking photograph Document says cannot rely on this for legal action CAD calls to EL BRILLO WAY PALM BEACH FL List of Jeffrey Epsteins House contacts document provided is not reflective of description Documents related to Jeffrey Epsteins investments Letter from Chief Michael Reiter to Barry Krischler Palm Beach Police DeQartment Incident ReQort dated redacted Letter from Guy Fronstin to Assistant State Attorney dated Letter from Guy Fronstin to Assistant State Attorney dated Letter from Guy Fronstin to Assistant State Attorney dated Letter from Guy Fronstin to Assistant State Attorney dated Letter from Guy Fronstin to Assistant State Attorney dated Letter from Goldberger dated All subpoenas issued to State Grand Jury Documents related to the rental of a vehicle for Vanessa document Zalis produced contains other items not identified on list Teds Sheds Documents document produced contains other items not identified on list Documents related to property searches of Jeffrey Epsteins properties Arrest Warrant of Sarah Kellen Police report regarding Alexandra Hall picking up money dated List of Trilateral Commission Members of No Edwards Exhibit Description Epsteins Objections Alan Dershowitz Letter dated and Statute Guy Fronstin letter dated Jeffrey Epstein Account Information Jeffrey Epstein Criminal Closeout Sheet JEGE Inc Passenger Manifest Hyperion Air Passenger Manifest Flight information for Dana Bums Passenger List Palm Beach flights Jeffrey Epstein notepad notes.re Maria Pleadings of Jane Doe and US case document provided is not what is identified on list Jeffrey Epstein th Amendment Speech Reiter letter to Krisher dated Alexandra Hall Police Report dated Victims school records and transcripts Victim Notification letter to Virginia Roberts Police report of Juan Alessi theft at Jeffrey Epsteins home Victims Medical Records from Dr Randee Speciale All surveillance conducted by law enforcement on Jeffrey Epsteins home Emails received from Palm Beach Records related to Jeffrey Epstein All items listed on the Palm Beach Police Property Report items not Lists and/or Property Receipts provided All copies of convictions related to Jeffrey Epstein Jeffrey Epstein criminal records All documents produced by Palm Beach Police Department prior to the deposition of Detective Recarey Statements deposition transcripts videotaped depositions and transcripts taken in connection with this and all related cases and exhibits thereto Any and all expert witness reports and/or records generated in preparation for this litigation by any party to this cause No Edwards Exhibit Description Epsteins Objections Demonstrative aids and exhibits including but not limited to charts diagrams and models surveys photographs and similar material including blow-ups of the listed items/exhibits Edwards reserves all objections to Epsteins Exhibits Not an exhibit Edwards reserves the right to supplement and/or amend his Not an exhibit Exhibit List By listing an Exhibit Edwards is not waiving his right to Not an exhibit object to same at trial and does not waive their right to amend same All exhibits listed by Epstein subject to Edwards Not an exhibit objections All pleadings and attachments in the action under the Crime Victims Rights Act prosecuted by Bradley Edwards on behalf of victims of Epsteins criminal molestations Edwards Motions for Summary Judgment all attachments thereto and all Undisputed Facts All time records and hourly billing documentation produced in discovery All deposition testimony and discovery responses by Epstein submitted in this action All pleadings filed by Epstein in the Rothstein bankruptcy proceeding All submissions by Epstein in connection with the Rothstein deposition All Settlement Agreements between Epstein and victims of his sexual molestations Phone Journal taken from Epsteins home and produced to the FBI by Alfredo Rodriguez duplicative of Exhibit No Photo depicting Virginia Roberts Ghislaine Maxwell and Prince Andrew All flight logs for any Epstein owned or controlled aircraft All emails produced by Defendant and/or all emails produced by Plaintiff in this case Evidence of contributions to the Palm Beach Police Dept duplicative of45 Dr Bernard Jansen Expert Report Attachments and Back-up Documents October Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Complaint December Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Fourth Amended Counterclaim January No Edwards Exhibit Description Epsteins Objections Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Plaintiff/Counter-Defendant Jeffrey Epsteins Answer and Affirmative Defenses to Defendant/Counter Plaintiff Bradley Edwardss Fourth Amended Counterclaim February Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Notice of Voluntary Dismissal Ammst Brad Edwards sic Times Records and Billing Records related to this matter Jeffrey Epsteins NY State Online Sex Offender Registry Profile New York Post article Billionaire Jeffrey Epstein Im a sex offender not a predator February Medical Records New York Presby_!erian Hospital re _1 Virginia Guiffre II i-iand Drawing of Bart Simpson ed bY Matt Groening Proposed Joint Letter to the Special Maste _1 Front and Back of Hard CopY Color Photo Virginia Mar I color photo of Virginia Roberts on fegy New York Scenic photo of Time Sguare tYg-ginia Roberts photo on back of shig Picture of room in New orK color photo of man on horse ili_ew Mexico Ranch color photo of Virginia Roberts at Zorro Ranch standing in front of gate sign with New Mexico Ranch tYg-ginia Roberts photo on horse front of ranch tYg-ginia Roberts photo standing gainst rocks red coat iVirginia Roberts standing against rocks red coat far with back photo white back date I tYg-ginia Roberts photo riding horse blue jacket fa tYg-ginia Roberts photo on side of horse hand ug tYg-ginia Roberts photo on side of horse tYg-ginia Roberts photo outside next to tables tYg-ginia Roberts photo red coat leaning on rail No Edwards Exhibit Description Epsteins Objections tYg-ginia Roberts Rhoto standing outside next to fireRlace tYg-ginia Roberts Rhoto standing in front of ranch tYg-ginia Roberts Rhoto with hand over head black/white tYg-ginia Roberts Rhoto standing next to Riano tYg-ginia Roberts Rhoto in front of fireRlace museum tYg-ginia Roberts Rhoto in front of wagon in museum Color photo of Virginia Roberts in front of museum exhibition Santa Fe New Mexico Photograph in Spain Jeffrey ERstein and Ghislaine Maxwell in front of buildingf tYg-ginia Roberts Australia Storag Photo Book Cover Rhoto book Scenic Rhoto with back Rhoto white Scenic Rhoto with back Rhoto white Scenic Rhoto with back Rhoto white Scenic Rhoto with back Rhoto white tYg-ginia Roberts steRS with trees overhead Scenic Rhoto with back Rhoto white Scenic Rhoto with back Rhoto white Scenic Rhoto with back Rhoto white Scenic Rhoto with back Rhoto white Scenic Rhoto with back Rhoto white and black Scenic Rhoto with back Rhoto white and black Scenic Rhoto with back Rhoto white and black firginia Roberts on steRS with children with back Rhoto white and black firginia Roberts on street white wall far with back photo white and black I ff ravel enveloRe Singapore Airlines Travel Cover with handwritten notes bY iVirginia Roberts No Edwards Exhibit Description Epsteins Objections Thailand Hotel Receipts Court Docket for Jane Doe No Epstein Typed List of Victims Co-Con 247pirators unigue to the _lQ investigation of Jeffrey Epsteiti Ghislaine Maxwell deposition _H FBI Form Interview of Virginia Giuffre in Australia _lQ Redacted Mark Epstein Deposition March email of Assistant U.S Attorney Ann _lQ Marie Villafana Summary of the Case Coonan File Color photos of Ghislaine Maxwell one with Jeffre_Y I I Epstein A.irRort Codes Demonstrative _lQ rvt:arch ew York Post Uppit:Y TrannY to Epstein Pay Up!1 DVD of Epstein PBPD El Brillo Search Warrant Walk only photo hromm DVD Audio from Cassettes Part bf DVDs provided Alex Hall Redacted Transcript taken by Detective Joe _lQ Recarev and Detective Dawson with Exhibits Palm Beach Police Investigation Palm Beach PD Records _lQ,_l achovia Bank Accoun Folder titled Sara Kellen Cell Phone Summary bi _lQ,_l Detective Recarey Enclosing phone records SAO FOIAi Disc State Files Folder titled Sara Kellen Cell Sara Kellen Cell Phone _lQ,_l Usage folder titl,ed Sara Kellen AT February _lQ,_l Statement Demand Deposit Account Statement History foti _lQ,_H Household Bank Account JeffreY Epstein or Ghi Maxwell or Alfredo Rodrigue Santa Monica Police Report MaY Folder titled PLANES Information relating to Epstein planes/aircrafts collected by the State Attorn Y.s Offic unique to the investigation of Jeffrey Epsteiti Palm Beach House/Information Sheet Sworn Statement of Juan Alessi taken bY Palm Beach I Police Department uan Alessi Deposition Yol I No Edwards Exhibit Description Epsteins Objections uan Alessi DeRosition ol II Brochure for Boeing SuRer PassRort aRRlication issued January Sentencing TranscripJ Alfredo Rodri ei _1 Criminal ComRlaint Alfredo Rodri ei _1 Plea Agreement Alfredo Rodri ei Photos of Jeffrey ERsteins RroRerties and Rlanes Photos of Jeffrey ERstein emRloy:ees and former emRloy:ees effrey ERstein Guilty Plea documents Palm Beach County State Attorneys Response to Public _1 Records Request including audio recordings Any and all responses to Subpoenas Duces Tecum with or without deposition All Interrogatories and Answers thereto Requests to Produce and Responses Requests for Admissions and Responses thereto Any and all documents produced in this action Any and all depositions taken in this action Any documents or other exhibit attached to or used during any deposition in this action Any and all exhibits documents etc referred to in any deposition Any and all documents and exhibits designated by all parties to this action Any and all exhibits needed for impeachment or rebuttal Any and all pleadings filed in this action Any and all records produced or that will be produced by all records custodians relative to this action CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on December through the Courts e-filing portal pursuant to Florida Rule of Judicial Administration LINK ROCKENBACH PA Palm Beach Lakes Boulevard Suite West Palm Beach Florida fax By Isl Scott Link Scott Link FBN Kara Berard Rockenbach FBN Angela Many FBN 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 SERVICE LIST Jack Scarola Nichole Segal Searcy Denny Scarola Barnhart Shipley P.A Burlington Rockenbach P.A Palm Beach Lakes Boulevard Courthouse Commons Suite West Palm Beach FL West Railroad A venue mep searcylaw.com West Palm Beach FL jsx searcylaw.com njs FLAppellateLaw.com scarolateam searcylaw.com kbt FLAppellateLaw.com Co-Counsel for Defendant/Counter-Plaintiff Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Bradley Edwards Bradley Edwards Marc Nurik Edwards Pottinger LLC Law Offices of Marc Nurik Andrews Avenue Suite One Broward Boulevard Suite Fort Lauderdale FL Ft Lauderdale FL brad epllc.com marc nuriklaw.com staff.efile pathtojustice.com Counsel for Defendant Scott Rothstein Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Jack A Goldberger Atterbury Goldberger Weiss P.A Australian A venue Suite West Palm Beach FL goldberger agwpa.com smahoney agwpa.com Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein EXHIBIT Filing E-Filed PM JEFFREY EPSTEIN Plaintiff/Counter-Defendant SCOTT ROTHSTEIN individually and BRADLEY EDWARDS individually Defendants/Counter-Plaintiff IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Case No PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEINS AMENDED EXHIBIT LIST Plaintiff/Counter-Defendant Jeffrey Epstein hereby files this list of the trial exhibits he may introduce at the trial of this matter INDEX TO OBJECTIONS No Objection All objections All objections except authenticity Irrelevant or immaterial Probative value substantially outweighed by danger of unfair prejudice confusion of issues misleading the jury or needless presentation of cumulative evidence Privileged Opinion Hearsay Authenticity lacking Other please identify basis of objection No Date Description Objection Marked Marked in for Id Evidence Jeffrey Epstein Scott Rothstein Bradley Edwards and L.M th Judicial Circuit Case No Complaint with Exhibits Answer and Counterclaim of Defendant Bradley Edwards Default against Scott Rothstein Stipulation and Order of Dismissal with Prejudice as to L.M Individually Only Notice of Appearance of Bradley Edwards Notice of Voluntary Dismissal Without Prejudice of Bradley Edwards Bradley Edwards Fourth Amended Counterclaim Affidavit of Jeffrey Epstein Affidavit of Jeffrey Epstein Jeffrey Epsteins Motion for Summary Judgment Appendix in Support and all documents cited therein Misc All deposition transcripts exhibits and videotapes including but not limited to a Bradley Edwards Jeffrey Epstein Scott Rothstein Russell Adler Abrakas Joseph Discala Dean Russell Kretschmar Michael Legamaro Courtney Wild Misc Defendant/Counter-Plaintiff Bradley Edwards Answers Responses Objections and Privilege Logs in response to Plaintiff/Counter-Defendant Jeffrey Epsteins Interrogatories Requests for Admission Requests for Production and Subpoenas Duces Tecum Misc All documents produced by any party or non-party in this matter Misc All documents filed in the court file including pleadings motions responses affidavits discovery and exhibits Misc All hearing transcripts State of Florida Jeffrey Epstein th Judicial Circuit No Date Description Objection Marked Marked in for Id Evidence Transcript of Taped Statement of Tatum Miller Misc All other testimony transcripts and statements provided in the matter L.M Jeffrey Epstein th Judicial Circuit Case No Misc Court docket and all court filings referenced therein Complaint Amended Complaint Notice of Change of Firm and Address Defendant Epsteins Answer Affirmative Defenses to Plaintiffs Amended Complaint Notices of Production from Non Parties Stephen Alexander M.D Bruce Markowitz M.D and Charles Galecki M.D Notices of Taking Deposition and Subpoenas to Lawrence Paul Visoski Jr and David Hart Rogers Plaintiffs Request for Production to Defendant Defendant Epsteins Answer Affirmative Defenses to Plaintiffs Second Amended Complaint Plaintiffs Third Amended Complaint Stipulation of Dismissal With Prejudice Misc All testimony deposition transcripts exhibits and videotapes including but not limited to a L.M L.M Jeffrey Epstein USDC S.D Fla Case No Misc Court docket all court filings referenced therein and all discovery and discovery responses Complaint and Demand for Jury Trial Stipulation of Dismissal With Prejudice D.E Misc All testimony deposition transcripts exhibits and videotapes Federal Rule of Civil Procedure Rule E.W Jeffrey Epstein th Judicial Circuit Case No Misc Court docket all court filings referenced therein and all discovery and discovery responses Complaint No Date Description Objection Marked Marked in for Id Evidence Amended Complaint Notice of Change of Firm and Address Defendant Epsteins Answer Affirmative Defenses to Plaintiffs Amended Complaint Defendant Epsteins Motion for Order to Terminate or Limit Deposition and Response in Opposition to Plaintiffs Amended Motion to Compel for Sanctions Cross Notice of Taking Videotaped Deposition of Alfredo Rodriguez Defendant Epsteins Answer Affirmative Defenses to Plaintiffs Second Amended Complaint Plaintiffs Request for Entry Upon Land Plaintiffs Third Amended Complaint Stipulation of Dismissal With Prejudice Order Adopting Stipulation and Dismissing Case With Prejudice Misc All testimony deposition transcripts exhibits and videotapes including but not limited to a E.W Jane Doe Jeffrey Epstein USDC S.D Fla Case No Misc Court docket all court filings referenced therein and all discovery and discovery responses Complaint D.E Defendant Epsteins Motion to Stay and/or Continue Action for Time Certain Based on Parallel Civil and Criminal Proceedings with Incorporated Memorandum of Law D.E Notice of Change of Address and Firm Affiliation D.E Plaintiffs Motion to Strike References to Non Prosecution Agreement or in the Alternative to Lift Protective Order Barring Jane Does Attorneys from Revealing Provisions in the Agreement D.E Plaintiffs First Amended Complaint D.E Order Consolidating Cases for Purposes of Discovery and Procedural Motions that Relate to Multiple Cases D.E No Date Description Objection Marked Marked in for Id Evidence to Notices of Taking Deposition and Subpoenas to Ghislane Noelle Maxwell Leslie Wexler Donald Trump Mark Epstein Nadia Marcinkova Jean Luc Bruhel Sarah Kellen Michael Freidman Rosalie Freidman and Michael Sanka Stipulation of Dismissal With Prejudice D.E Final Order of Dismissal With Prejudice D.E Misc All testimony deposition transcripts exhibits and videotapes Jane Doe Jeffrey Epstein Consolidated Action USDC S.D Fla Case No Misc Court docket all court filings referenced therein and all discovery and discovery responses Plaintiff Jane Does Motion for Injunction Restraining Fraudulent Transfer of Assets Appointment of a Receiver to Take Charge of Property of Epstein and to Post a Million Bond to Secure Potential Judgment D.E Plaintiff Jane Does 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 Million Bond to Secure Potential Judgment D.E Plaintiff Jane Does Notice that Additional Evidence of Epsteins Fraudulent Asset Transfers Will be Filed Shortly etc D.E Plaintiff Jane Does 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 Order D.E Misc All testimony deposition transcripts exhibits and videotapes Jane Doe United States of America CVRA USDC S.D Fla Case No Emergency Victims Petition for Enforcement of Crime Victims Rights Act U.S.C Section D.E No Date Description Objection Marked Marked in for Id Evidence Transcript of Hearing Before the Honorable Kenneth A Marra Rothstein Rosenfeldt Adler and Stuart Rosenfeldt Scott Rothstein th Judicial Circuit Broward County Case No Misc Court docket all court filings referenced therein and all discovery and discovery responses Amended Complaint Misc All testimony deposition transcripts exhibits and videotapes In re Rothstein Rosenfeldt Adler P.A USBC S.D Fla Case No Motion of the U.S Trustee for an Order Directing the Appointment of a Chapter Trustee and Objection to Retention of Chief Restructuring Officer D.E Verified Complaint for Damages and Other Relief D.E Privilege Log of Farmer Jaffe Weissing Edwards Fistos Lehrman Misc All testimony deposition transcripts exhibits and videotapes including but not limited to a Scott Rothstein Jack John Scarolas and Russell Adler United States of America Scott Rothstein Forfeiture Action USDC S.D Fla Case No 09-CV-61780-Zloch-Rosenbaum Verified Complaint for Forfeiture in Rem D.E I Amended Verified Complaint for Forfeiture in Rem D.E Amended Verified Complaint for Forfeiture in Rem D.E The Florida Bar Matters The Florida Bar Inquiry/Complaint Form Jeffrey Epstein filed against Bradley Edwards William Berger and Scott Rothstein Approval of Scott Rothsteins disbarment The Florida Bar Scott Walter Rothstein Supreme Court Case No No Date Description Objection Marked Marked in for Id Evidence The Florida Bars Notice of No Probable Cause and Letter of Advice to Accused In re Complaints by Jeffrey Epstein and the Florida Bar against Bradley James Edwards Case No United States of America Scott Rothstein USDC S.D Fla Case No Information charging Scott Rothstein Plea Agreement between the United States of America and Scott Rothstein Governments Motion to Withdraw its Motion for Reduction of Sentence Razorback Funding LLC et al Scott Rothstein et al th Judicial Circuit Broward County Florida Case No Misc Court docket all court filings referenced therein and all discovery and discovery responses Complaint Amended Complaint Misc All testimony deposition transcripts exhibits and videotapes including but not limited to a Scott Rothsteins testimony Rothstein Rosenfeldt Adler Communication E-mail from Russell Adler to Bradley Edwards cc p.m Mark Nurik E-mail from Bradley Edwards to Russell Adler p.m E-mail from Bradley Edwards to Russell Adler p.m E-mail from William Berger to Bradley a.m Edwards Russell Adler Steven Jaffe Matthew Weissing and Gary Farmer E-mail from Susan Stirling to Bradley Edwards p.m E-mail from Bradley Edwards to Russel Adler p.m E-mail from Bradley Edwards to Susan Spencer p.m Wendel E-mail from Susan Spencer Wendell to Bradley p.m Edwards No Date Description Objection Marked Marked in for Id Evidence E-mail from Bradley Edwards to Timothy Malloy p.m E-mail from Timothy Malloy to Bradley Edwards p.m E-mail from Susan Spencer Wendell to Bradley p.m Edwards E-mail from Bradley Edwards to William p.m Berger E-mail from William Berger to Grace Torres cc p.m Russell Adler and Bradley Edwards E-mail from Bradley Edwards to Susan a.m Stirling cc Carla Martinez E-mail from Bradley Edwards to Eric Glasser p.m E-mail from Bradley Edwards to Michele Dargan p.m Palm Beach Daily News E-mail from Bradley Edwards to Paul Cassell p.m E-mail from Michele Dargan to Bradley Edwards p.m E-mail from Bradley Edwards to Michele Dargan p.m E-mail from Michele Dargan to Bradley Edwards p.m E-mail from Bradley Edwards to Michele Dargan p.m E-mail from Michele Dargan to Bradley Edwards p.m E-mail from Bradley Edwards to Michele Dargan p.m E-mail from Michele Dargan to Bradley Edwards p.m E-mail from Bradley Edwards to Michele Dargan p.m E-mail from Michele Dargan to Bradley Edwards p.m E-mail from Bradley Edwards to Michele Dargan p.m E-mail from Michele Dargan to Bradley Edwards p.m E-mail from Bradley Edwards to Michele Dargan a.m No Date Description Objection Marked Marked in for Id Evidence E-mail from Bradley Edwards to Russell Adler p.m William Berger and Steven Jaffee E-mail from Michele Dargan Palm Beach Daily p.m News to Bradley Edwards E-mail from Bradley Edwards to William p.m Berger E-mail from Bradley Edwards to Michele Dargan p.m E-mail from Michele Dargan to Bradley Edwards p.m E-mail from Bradley Edwards to Russell Adler p.m E-mail from Bradley Edwards to Michele Leone p.m E-mail from Bradley Edwards to Michele Dargan a.m E-mail from Michele Dargan to Bradley Edwards a.m E-mail from Jacquie Johnson to Bradley Edwards p.m Letter from Bradley Edwards re cross noticing depositions E-mail from Priscila A Nascimento to Scott p.m Rothstein cc Amy Howard and Adelita Cabello E-mail from Bradley Edwards to Susan Spencer a.m Wendel E-mail from Susan Spencer Wendel to Bradley a.m Edwards E-mail from Bradley Edwards to Michele Dargan a.m E-mail from Michele Dargan to Bradley Edwards a.m E-mail from Cara Holmes to Bradley Edwards p.m E-mail from Michele Dargan to Bradley Edwards p.m E-mail from Michele Dargan to Bradley Edwards p.m E-mail from Bradley Edwards to Michele Dargan p.m E-mail from Bradley Edwards to Michele Dargan p.m No Date Description Objection Marked Marked in for Id Evidence E-mail from Bradley Edwards to Michele Dargan p.m E-mail from Michele Dargan to Bradley Edwards a.m E-mail from Bradley Edwards to Michael Isikoff p.m E-mail from Michael Isikoffto Bradley Edwards p.m E-mail from Bradley Edwards to Michael Isikoff a.m E-mail from Michael Isikoffto Bradley Edwards a.m E-mail from Bradley Edwards to Michael Isikoff a.m E-mail from Michael Isikoffto Bradley Edwards p.m E-mail from Michael Isikoffto Bradley Edwards p.m E-mail from Bradley Edwards to Mike Fisten cc p.m Ken Jenne E-mail from Bradley Edwards to Michael Isikoff p.m E-mail from Michael Isikoffto Bradley Edwards a.m E-mail from Bradley Edwards to Jacquie Johnson a.m E-mail from Bradley Edwards to Ken Jenne p.m E-mail from Bradley Edwards to Conchita Sarnoff p.m E-mail from Conchita Sarnoff to Bradley Edwards a.m E-mail from Bradley Edwards to Conchita Sarnoff p.m E-mail from Conchita Sarnoff to Bradley Edwards a.m E-mail from Elizabeth Villar to Bradley Edwards p.m and Ken Jenne cc Jacquie Johnson Pat Roberts and Mike Fisten E-mail from Conchita Sarnoff to Bradley Edwards p.m E-mail from Conchita Sarnoff to Bradley Edwards p.m No Date Description Objection Marked Marked in for Id Evidence E-mail from Bradley Edwards to Conchita Sarnoff p.m E-mail from Conchita Sarnoff to Bradley Edwards p.m E-mail from Bradley Edwards to Conchita Sarnoff p.m E-mail from Conchita Sarnoff to Bradley Edwards p.m E-mail from Bradley Edwards to Conchita Sarnoff a.m E-mail from Conchita Sarnoff to Bradley Edwards a.m E-mail from Bradley Edwards to Conchita Sarnoff a.m E-mail from Conchita Sarnoff to Bradley Edwards p.m E-mail from Conchita Sarnoff to Bradley Edwards p.m E-mail from Bradley Edwards to Conchita Sarnoff p.m E-mail from Conchita Sarnoff to Bradley Edwards p.m E-mail from Bradley Edwards to Conchita Sarnoff p.m E-mail from Conchita Sarnoff to Bradley Edwards p.m E-mail from Conchita Sarnoff to Bradley Edwards p.m E-mail from Bradley Edwards to Conchita Sarnoff p.m E-mail from Conchita Sarnoff to Bradley Edwards p.m E-mail from Conchita Sarnoff to Bradley Edwards p.m E-mail from Bradley Edwards to Elizabeth Villar p.m cc Ken Jenne and Pat Roberts E-mail from Bradley Edwards to Russell Adler p.m E-mail from Jacquie Johnson to Ann Marie p.m Villafana cc Bradley Edwards E-mail from Bradley Edwards to Susan Spencer p.m Wendel No Date Description Objection Marked Marked in for Id Evidence E-mail from Bradley Edwards to Beth p.m Williamson E-mail from Bradley Edwards to Michele Dargan p.m E-mail from Conchita Sarnoff to Bradley Edwards p.m E-mail from Conchita Sarnoff to Bradley Edwards p.m E-mail from Bradley Edwards to Conchita Sarnoff a.m E-mail from Conchita Sarnoff to Bradley Edwards a.m E-mail from Conchita Sarnoff to Bradley Edwards p.m E-mail from Conchita Sarnoff to Bradley a.m Edwards cc Renee/Carlos Morrison E-mail from Bradley Edwards to Conchita Sarnoff a.m E-mail from Conchita Sarnoff to Bradley Edwards a.m E-mail from Mike Fisten to Conchita Sarnoff p.m E-mail from Bradley Edwards to Ken Jenn and a.m Elizabeth Villar E-mail from Bradley Edwards to Nigel Rosser a.m E-mail from Nigel Rosser to Bradley Edwards a.m E-mail from Michael Isikoffto Bradley Edwards p.m E-mail from Bradley Edwards to Mike Fisten p.m E-mail from Bradley Edwards to Michael Isikoff p.m cc Jacquie Johnson E-mail from Michael Isikoffto Bradley Edwards p.m cc Jacquie Johnson E-mail from Bradley Edwards to Richard Johnson p.m E-mail from Grant Smith to Scott Rothstein Bradley Edwards Ken Jenne Kip Hunter and Russell Adler cc Grant Smith E-mail from Mike Fisten to Bradley Edwards p.m No Date Description Objection Marked Marked in for Id Evidence E-mail from Bradley Edwards to Jacquie Johnson p.m cc Mike Fisten E-mail from Bradley Edwards to Conchita Sarnoff a.m E-mail from Conchita Sarnoff to Bradley Edwards a.m E-mail from Russell Adler to Bradley Edwards cc a.m Jacquie Johnson E-mail from Bradley Edwards to Mike Fisten cc p.m Jacquie Johnson E-mail from ABA Journal Weekly Newsletter to a.m Scott Rothstein E-mail from Bradley Edwards to Ken Jenne a.m E-mail from George Rush to Bradley Edwards p.m E-mail from Ken Jenne to Scott Rothstein p.m E-mail from Bradley Edwards to Jacquie Johnson a.m E-mail from Jacquie Johnson to Russell Adler Cara p.m Holmes Mike Fisten Michael Wheeler Marc Nurik William Berger Bradley Edwards Barry Stone and Ken Jenne cc Robert Busche E-mail from Jacquie Johnson to Bradley Edwards p.m Marc Nurik Michael Wheeler Cara Holmes William Berger Russell Adler and Robert Busche E-mail from William Berger to Pat Carter and a.m Bradley Edwards cc Grace Torres and Jacquie Johnson E-mail from Pat Diaz to Bradley Edwards p.m E-mail from Debra Villegas to Scott Rothstein a.m E-mail from Russell Adler to Jacquie Johnson and a.m Bradley Edwards Billing Contract for Services between Searcy Denny Scarola Barnhart Shipley and Bradley Edwards No Date Description Objection Marked Marked in for Id Evidence N/D Spreadsheet of Brad Edwards Time in Edwards adv Evstein Searcy Denney Scarola Barnhart and Shipley Invoices for Disbursements to Bradley Edwards BJE039 Search Denney Scarola Barnhart and Shipley Matter Ledger Report BJE06 BJE03 Miscellaneous Rothstein Rosenfeldt Adlers Firm Directory Farmer Jaffe Weissing Edwards Fistos Lehrman Our Attorneys website printout https://w.pathtojustice.com about-us attorneys Criminal Complaint United States of America Alfredo Rodriguez USDC S.D Fla Case No Affidavit of Bradley James Edwards Affidavit of Bradley James Edwards Misc Subpoenas and Notices of Deposition for Alan Dershowitz David Copperfield and Leonard Baird Critton Luttier Coleman LLPs website printout for Robert Critton Jr https w.lawclc.com/team members Robert-d-critton-jr Fowler White Burnett P.A website printout for Joseph Ackerman Jr http://w.fowler white.com Attorneys/id/3/read Bradley Edwards N/D The National Crime Victim Bar Association presentation excerpt of article by Bradley Edwards Who is Responsible for Child Sexual Abuse N/D The Florida Bars website member profile printout for Bradley James Edwards N/D National Association of Distinguished Counsel biographical information for Bradley Edwards The National Trial Lawyers Top Under Directory directory/?last_ name Edwards city state FL No Date Description Objection Marked Marked in for Id Evidence The National Trial Lawyers Profile View of Brad Edwards http://w thenationaltriallawyers org/profil view/Brad/Edwards/4409 Lawyers.com website information for Bradley Edwards lauderdale Bradley-J-Edwards-3489098-a Kubicki Drapers website attorney information for Brad Edwards Kubicki Drapers website attorney information for Brad Edwards The American Registry Website printouts of recognitions received by Bradley Edwards Farmer Jaffe Weissing Edwards Fistos Lehrman P.L.s website printout http://w.abuseandassault.com Abuse_ Under_ Investigation Farmer Jaffe Weissing Edwards Fistos Lehrman P.L.s website printout http w.abuseandassault.com Abuse_ Under_ Investigation Farmer Jaffe Weissing Edwards Fistos Lehrman P.L.s website printout releases Farmer Jaffe Weissing Edwards Fistos Lehrman website printout http://w.abuseandassault.com Abuse Home Farmer Jaffe Weissing Edwards Fistos Lehrman P.L.s website printout http://w.abuseandassault.com Abuse_ Under_ Notabl Cases Farmer Jaffe Weissing Edwards Fistos Lehrman P.L.s website attorney information for Brad Edwards edwards UZJOPpWTOXO Farmer Jaffe Weissing Edwards Fistos Lehrman P.L.s website printout press-releases UZJTy5WTOXO Farmer Jaffe Weissing Edwards Fistos Lehrman P.L.s website attorney information for Brad Edwards with referenced articles No Date Description Objection Marked Marked in for Id Evidence A Winter Journal of Criminal Law and Criminology Volume Issue Crime Victims Rights During Criminal Investigations Applying the Crime Victims Rights Act Before Criminal Charges are Filed Politico Victims in Underage Sex Case Want Prosecutors to Testify Palm Beach Daily News Jeffrey Epstein Sex Scandal Alan Dershowitz Suffers Setback in Defamation Case Palm Beach Daily News Epstein Victims Attorneys Seek Partial Victory in Defamation Suit Palm Beach Post Boca-Resident Model Nabs Million Followin2 Six-Year Divorce Battle Daily Mail.Com Florida Model Gets Whopping Million Payout from Real Estate Tycoon Ex Husband After Nasty Six-Year Divorce Battle Palm Beach Daily News Appellate Court Reverses Palm Beach Sex Offender Jeffrey Epsteins Victory Daily Business Review Attorneys Suit Against Billionaire Allowed as Lon2 as Justices Say Its OK I Palm Beach Daily News Judge Keeps Thousands of Epstein Documents Sealed WCVB5 Jury Awards Million to Mass Widower in Fatal Cabana Crash NBC6 Jury Awards Million in Fatal Cabana Crash CBS Miami Jury Awards Millions to Husband of Pre2nant Woman Killed bv Drunk Driver Sun Sentinel Jury Awards Million to Widower in Fatal Cabana Crash Daily Business Review The Lawyer Suing Legal Legend Alan Dershowitz Over Sex Offender The Washington Post Eleventh Circuit Rules that Discovery Can Move Forward on My Crime Victims Ri2hts Act Case Palm Beach Daily News Appeals Court Rules Against Sex Offender Attorneys for Underage Victims Seek to Overturn Sweetheart Plea Sun-Sentinel Victims Win Right to See Negotiation that Led to Lenient Plea Deal Agreement for Billionaire Sex Offender No Date Description Objection Marked Marked in for Id Evidence Palm Beach Post Appellate Ruling Could Force Feds to Reconsider Sex Changes Against Palm Beacher Epstein Palm Beach Daily News Newest Lawsuit Against Epstein Expected to Include Victim Testimony CBS Miami Exclusive Sexual Assault Victim Allef.!es Abuse bv Former Youth Pastor Sun-Sentinel Elevator Fall Nets Woman Million Jury Award July Daily Business Review Top Florida Verdicts Settlements of Daily Business Review Suit Accuses Goldrush Strip Club of Scheme to Bilk Professionals Palm Beach Daily Business Review Jeffrey Epstein Amends Lawsuit Claims Victims Attorney Threatened to Depose His Friends Farmer Jaffe Weissings Facebook page with referenced articles A Lawnewz.com The Shameful Way Feds Protected Convicted Pedophile Billionaire Jeffrev Epstein Fox News Flight Logs Show Bill Clinton Flew on Sex Offenders Jet Much More than Previously Known Sun-Sentinel Feds Deceived Us About Billionaire Sex Offenders Sweetheart Deal Teen Victims Sav NBC News Lawyers Victims Not Told of Sweetheart Deal for Jeffrey Epstein NY Daily News Jeffrey Epstein Accusers Sue Feds Over Hidden Non-Prosecution Conspiracy Farmer Jaffe Appeals Court Rules in Favor of Crime Victims Rights in Registered Pedophile Jef rev Evstein Case Daily Business Review Prosecutors Must Turn Over Docs in Billionaire Sex Offender Jeffrey Epstein Case Misc Court and arrest information Bradley James Edwards Duval County Court Case No MM-074-AXXA-MA Misc Court and arrest information Bradley James Edwards Duval County Case No No Date Description Objection Marked Marked in for Id Evidence Exemption and/or Limitation Exclusion Tax Assessment of Notice of Satisfaction of Lien Relative to Tax Exemption Misc Docket and all court filings referenced therein U.S Bank National Association Bradley Edwards th Judicial Circuit Broward County Case No Petition/Complaint U.S Bank National Association Bradley Edwards th Judicial Circuit Broward County Case No Bradley Edwards Answer and Affirmative Defenses U.S Bank National Association Bradley Edwards th Judicial Circuit Broward County Case No Notice of Sale U.S Bank National Association Bradley Edwards th Judicial Circuit Broward County Case No Final Summary Judgment of Mortgage Foreclosure U.S Bank National Association Bradley Edwards th Judicial Circuit Broward County Case No Certificate of Sale U.S Bank National Association Bradley Edwards th Judicial Circuit Broward County Case No Certificate of Title U.S Bank National Association Bradley Edwards th Judicial Circuit Broward County Case No Misc Docket and all court filings referenced therein Wells Fargo Bank N.A Bradley Edwards th Judicial Circuit Broward County Case No 0CA0 AXCE Petition/Complaint Wells Fargo Bank N.A Bradley Edwards th Judicial Circuit Broward County Case No Final Summary Judgment of Mortgage Foreclosure Wells Fargo Bank N.A Bradley Edwards th Judicial Circuit Broward County Case No 0CA0 AXCE Notice of Sale Wells Fargo Bank N.A Bradley Edwards th Judicial Circuit Broward County Case No No Date Description Objection Marked Marked in for Id Evidence Certificate of Sale Wells Fargo Bank NA Bradley Edwards th Judicial Circuit Broward County Case No Certificate of Title Wells Fargo Bank NA Bradley Edwards th Judicial Circuit Broward County Case No Misc Docket and all court filings referenced therein Ft United Bank Bradley Edwards th Judicial Circuit Broward County Case No Complaint Ft United Bank Bradley Edwards th Judicial Circuit Broward County Case No Stipulation for Settlement Ft United Bank Bradley Edwards th Judicial Circuit Broward County Case No Misc Docket and all court filings referenced therein Wells Fargo Bank NA Bradley Edwards th Judicial Circuit Broward County Case No AXWE Complaint Wells Fargo Bank NA Bradley Edwards th Judicial Circuit Broward County Case No Bradley Edwards Motion to Dismiss Wells Fargo Bank NA Bradley Edwards th Judicial Circuit Broward County Case No AXWE Order Denying Motion to Dismiss Wells Fargo Bank NA Bradley Edwards th Judicial Circuit Broward County Case No AXWE Answer to Complaint Wells Fargo Bank NA Bradley Edwards th Judicial Circuit Broward County Case No Mediation Report Wells Fargo Bank NA Bradley Edwards th Judicial Circuit Broward County Case No Mediation Report Wells Fargo Bank NA Bradley Edwards th Judicial Circuit Broward County Case No Corporate Detail Printout from Sunbiz.org for The Law Office of Brad Edwards Associates LLC No Date Description Objection Marked Marked in for Id Evidence Articles of Organization for Florida Limited Liability Company for The Law Office of Brad Edwards Associates LLC Limited Liability Company Annual Report for The Law Office of Brad Edwards and Associates Limited Liability Company Annual Report for The Law Office of Brad Edwards and Associates Florida Bar Rules including but not limited to Florida Bar Rule Complaint Donald Baker The City of Hollywood et al Case No D.E Omnibus Order on Defendants Motion to Dismiss Donald Baker The City of Hollywood et al Case No D.E U.S Court of Appeals Opinion Donald Baker City of Hollywood et al Case No New Times Broward Palm-Beach Tale of the Tape Experts Dr Bernard Jansens Expert Report with attachments Misc All documents produced or relied upon or referenced by Dr Bernard Jansen in preparing his Report Expert Witness Report of Dr Bernard Jansen in Virf.!inia Giuffre Ghislaine Maxwell USDC NY Supplemental Expert Witness Report of Dr Bernard Jansen in Virginia Giuffre Ghislaine Maxwell USDCNY Misc All public records news articles and prior testimony of Dr Bernard Jansen Other Articles Kendall Coffey Law Firm Victimized by Scott Rothstein Legal Junkies WSJ Law Blog Rothstein Rosenfeldt Adler Ft Lauderdale Law Firm Dissolution Ponzi Scheme New Times Broward-Palm Beach Chief Judge Scott Rothstein Firm Has No Money and is Goin into Receivership No Date Description Objection Marked Marked in for Id Evidence The New York Times Fraud Accusations Against Florida Lawyer Set Off a Race to Return His Donations Rothstein Returns After Contemplating Suicide Partner Says Florida Law Firm Asks to be Dissolved Sun Sentinel Scott Rothstein Investment Deals Seemed Too Good to be True Funds News FBI Agents Search Law Firm in Missing Funds Probe New Times Broward-Palm Beach Scott Rothstein The Jeffrey Epstein and Bill Clinton Ploy Rothstein Accomplice Still on Lam Tour of Scott Rothstein Office Reveals Gallery of Whos Who Sun Sentinel FBI Doubts Rothstein Ran a Ponzi Scheme Alone Palm Beach Post FBI Doubts Rothstein Scheme a One-Man Show Sun Sentinel High-Ranking Police Officers Guarded Over Rothstein Inside the Rothstein Swindle Part I Sun Sentinel Rothstein Asks to Voluntarily Give Up Law License Rothstein and Dreier How Much Alike Inside the Rothstein Swindle Part II Former RAA Attorneys Take New Jobs Scherer Files Suit Af.winst Rothstein et al Article by Paul Brinkman Rothstein Feeder Geor2e Levins U2lv Past Geor2e Levin was Rothstein Whale Rothstein Associate Levy Got Protection from Plantation Covs Main Line Firms Clients Invested Million with Ponzi Lawyer Sun-Sentinel Scott Rothstein You re in Town Full of Thieves Miami Herald Feds Scott Rothstein Ponzi Scheme Paid Salaries at Law Firm The Rothstein Wires Sun Sentinel Florida Bar Looking at Former Attorneys from Rothstein Firm No Date Description Objection Marked Marked in for Id Evidence July Sun Sentinel Former Scott Rothstein Attorneys Cleared bv the Florida Bar South Florida Business Journal A Year After Rothstein Many Questions Unanswered The Florida Bar Scott Rothstein Scandal One Year Later Forbes Rothstein Expose Details Sex Murder and Corruption Behind Floridas Lar2est Ponzi Scheme Five Years on Rothstein Ponzi Still Resonates Palm Beach Daily News Epstein Paid Three Women Million to End Undera2e Sex Lawsuits General All public records and news articles relating to Scott Rothstein Rothstein Rosenfeldt Adler Bradley Edwards and any witnesses listed by either party All court dockets and filings in all matters against Jeffrey Epstein relating to any victims claims All prior testimony statements reports and affidavits of any witness or experts All charts/analyses prepared based on documents exchanged or later discovered All foundation exhibits All rebuttal and impeachment exhibits Demonstrative aids and exhibits including but not limited to charts timelines diagrams models surveys photographs and blow-ups All newly discovered documents/exhibits Any and all exhibits listed by Bradley Edwards by identifying these as exhibits Plaintiff is not waiving his right to object to any of Edwards exhibits introduced at trial Plaintiff/Counter-Defendant reserves his right to supplement this Exhibit List CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on November through the Courts e-filing portal pursuant to Florida Rule of Judicial Administration LINK ROCKENBACH PA Palm Beach Lakes Boulevard Suite West Palm Beach Florida fax By Isl Scott Link Scott Link FBN Kara Berard Rockenbach FBN Angela Many FBN 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 SERVICE LIST Jack Scarola Nichole Segal Searcy Denny Scarola Barnhart Shipley P.A Burlington Rockenbach P.A Palm Beach Lakes Boulevard Courthouse Commons Suite West Palm Beach FL West Railroad A venue mep searcylaw.com West Palm Beach FL jsx searcylaw.com njs FLAppellateLaw.com scarolateam searcylaw.com kbt FLAppellateLaw.com Co-Counsel for Defendant/Counter-Plaintiff Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Bradley Edwards Bradley Edwards Marc Nurik Edwards Pottinger LLC Law Offices of Marc Nurik Andrews Avenue Suite One Broward Boulevard Suite Fort Lauderdale FL Ft Lauderdale FL brad epllc.com marc nuriklaw.com staff.efile pathtojustice.com Counsel for Defendant Scott Rothstein Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Tonja Haddad Coleman Fred Haddad S.E Seventh Street Suite Haddad Navarro PLLC Ft Lauderdale FL Financial Plaza Suite tonj a tonjahaddad.com Fort Lauderdale FL efiling tonjahaddad.com dee haddadandnavarrolaw.com Co-Counsel for Plaintiff/Counter-Defendant Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein Jeffrey Epstein Jack A Goldberger Atterbury Goldberger Weiss P.A Australian A venue Suite West Palm Beach FL goldberger agwpa.com smahoney agwpa.com Co-Counsel for Plaintiff/Counter-Defendant Jeffrev Evstein Filing E-Filed PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendants I OBJECTIONS TO COUNTER-DEFENDANT JEFFREY EPSTEINS AMENDED EXHIBIT LIST Bradley Edwards by and through his undersigned counsel files his Objections to Counter Defendant Jeffrey Epsteins Amended Exhibit List dated November as follows INDEX TO OBJECTIONS No Objection Privileged All objections Opinion All objections except authenticity Hearsay Irrelevant or immaterial Authenticity lacking Probative value substantially outweighed Other please identify basis of objection by danger of unfair prejudice confusion of issues misleading the jury or needless presentation of cumulative evidence No Date Description Objection Marked Marked in for Id Evidence Jeffrey Epstein Scott Rothstein Bradley Edwards and L.M th Judicial Circuit Case No Complaint with Exhibits Answer and Counterclaim of Defendant Bradley Edwards Default against Scott Rothstein Stipulation and Order of Dismissal with Prejudice as to L.M Individually Only Notice of Appearance of Bradley Edwards Notice of Voluntary Dismissal Without Prejudice of Bradley Edwards Bradley Edwards Fourth Amended Counterclaim Affidavit of Jeffrey Epstein Affidavit of Jeffrey Epstein Jeffrey Epsteins Motion for Summary Judgment Appendix in Support and all documents cited therein Misc All deposition transcripts exhibits and videotapes including but not limited to a Bradley Edwards Jeffrey Epstein Scott Rothstein Russell Adler Abrakas Joseph Discala Dean Russell Kretschmar Michael Legamaro Courtney Wild Misc Defendant/Counter-Plaintiff Bradley Edwards Answers Responses Objections and Privilege Logs in response to Plaintiff/Counter-Defendant Jeffrey Epsteins Inten-ogatories Requests for Admission Requests for Production and Subpoenas Duces Tecum Misc All documents produced by any party or non-party in this matter Misc All documents filed in the court file including pleadings motions responses affidavits discovery and exhibits Misc All hearing transcripts State of Florida Jeffrey Epstein th Judicial Circuit No Date Description Objection Marked Marked in for Id Evidence Transcript of Taped Statement of Tatum Miller Misc All other testimony transcripts and statements provided in the matter L.M Jeffrey Epstein th Judicial Circuit Case No Misc Court docket and all court filings referenced therein Complaint Amended Complaint Notice of Change of Firm and Address Defendant Epsteins Answer Affim1ative Defenses to Plaintiffs Amended Complaint Notices of Production from Non Parties Stephen Alexander M.D Bruce Markowitz M.D and Charles Galecki M.D Notices of Taking Deposition and Subpoenas to Lawrence Paul Visoski Jr and David Hart Rogers Plaintiffs Request for Production to Defendant Defendant Epsteins Answer Affirmative Defenses to Plaintiffs Second Amended Complaint Plaintiffs Third Amended Complaint Stipulation of Dismissal With Prejudice Misc All testimony deposition transcripts exhibits and videotapes including but not limited to a L.M L.M Jeffrey Epstein USDC S.D Fla Case No Misc Court docket all court filings referenced therein and all discovery and discovery responses Complaint and Demand for Jury Trial Stipulation of Dismissal With Prejudice D.E Misc All testimony deposition transcripts exhibits and videotapes Federal Rule of Civil Procedure Rule E.W Jeffrey Epstein th Judicial Circuit Case No Misc Comi docket all comi filings referenced therein and all discovery and discovery responses Complaint No Date Description Objection Marked Marked in for Id Evidence Amended Complaint Notice of Change of Firm and Address Defendant Epsteins Answer Affirmative Defenses to Plaintiffs Amended Complaint Defendant Epsteins Motion for Order to Terminate or Limit Deposition and Response in Opposition to Plaintiffs Amended Motion to Compel for Sanctions Cross Notice of Taking Videotaped Deposition of Alfredo Rodriguez Defendant Epsteins Answer Affirmative Defenses to Plaintiffs Second Amended Complaint Plaintiffs Request for Entry Upon Land Plaintiffs Third Amended Complaint Stipulation of Dismissal With Prejudice Order Adopting Stipulation and Dismissing Case With Prejudice Misc All testimony deposition transcripts exhibits and I videotapes including but not limited to a E.W Jane Doe Jeffrey Epstein USDC Fla Case No Misc Court docket all court filings referenced therein and I all discovery and discovery responses Complaint I Defendant Epsteins Motion to Stay and/or Continue Action for Time Certain Based on Parallel Civil and Criminal Proceedings with Incorporated Memorandum of Law D.E Notice of Change of Address and Firm Affiliation D.E Plaintiffs Motion to Strike References to Non Prosecution Agreement or in the Alternative to Lift Protective Order Barring Jane Does Attorneys from Revealing Provisions in the Agreement D.E Plaintiffs First Amended Complaint D.E Order Consolidating Cases for Purposes of Discovery and Procedural Motions that Relate to Multiple Cases D.E No Date Description Objection Marked Marked in for Id Evidence to Notices of Taking Deposition and Subpoenas to Ghislane Noelle Maxwell Leslie Wexler Donald Trump Mark Epstein Nadia Marcinkova Jean Luc Bruhel Sarah Kellen Michael Freidman Rosalie Freidman and Michael Sanka Stipulation of Dismissal With Prejudice D.E Final Order of Dismissal With Prejudice D.E Misc All testimony deposition transcripts exhibits and videotapes Jane Doe Jeffrey Epstein Consolidated Action USDC S.D Fla Case No Misc Court docket all court filings referenced therein and all discovery and discovery responses Plaintiff Jane Does Motion for Injunction Restraining Fraudulent Transfer of Assets Appointment of a Receiver to Take Charge of Property of Epstein and to Post a Million Bond to Secure Potential Judgment D.E Plaintiff Jane Does 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 Million Bond to Secure Potential Judgment D.E Plaintiff Jane Does Notice that Additional Evidence of Epsteins Fraudulent Asset Transfers Will be Filed Shortly etc D.E Plaintiff Jane Does 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 Order D.E Misc All testimony deposition transcripts exhibits and videotapes Jane Doe United States of America CVRA USDC S.D Fla Case No Emergency Victims Petition for Enforcement of Crime Victims Rights Act U.S.C Section D.E No Date Description Objection Marked Marked in for Id Evidence Transcript of Hearing Before the Honorable Kenneth A Marra Rothstein Rosenfeldt Adler and Stuart Rosenfeldt Scott Rothstein th Jutlicial Circuit BrowarUCounty Case No Misc Court docket all court filings referenced therein and all discovery and discovery responses Amended Complaint Misc All testimony deposition transcripts exhibits and videotapes In re Rothstein Rosenfeldt Adler P.A USBC S.D Fla Case No Motion of the U.S Trustee for an Order Directing the Appointment of a Chapter Trustee and Objection to Retention of Chief Restructuring Officer D.E Verified Complaint for Damages and Other Relief D.E Privilege Log of Fanner Jaffe Weissing Edwards Fistos Lehrman Misc All testimony deposition transcripts exhibits and videotapes including but not limited to a Scott Rothstein Jack John Scarolas and Russell Adler United States of America Scott Rothstein Forfeiture Action USDC S.D Fla Case No 09-CV-61780-Zloch-Rosenbaum Verified Complaint for Forfeiture in Rem D.E Amended Verified Complaint for Forfeiture in Rem D.E Amended Verified Complaint for Forfeiture in Rem D.E Tlte Florida Bar Matters The Florida Bar Inquiry/Complaint Form Jeffrey Epstein filed against Bradley Edwards William Berger and Scott Rothstein Approval of Scott Rothstein disbarment The Florida Bar Scott Walter Rothstein Supreme Court Case No No Date Description Objection Marked Marked in for Id Evidence The Florida Bars Notice of No Probable Cause and Letter of Advice to Accused In re Complaints by Jeffrey Epstein and the Florida Bar against Bradley James Edwards Case No United States of Amelica Scott Rothstein USDC S.D Fla Case No Information charging Scott Rothstein Plea Agreement between the United States of America and Scott Rothstein Governments Motion to Withdraw its Motion for Reduction of Sentence Razorback Funding LLC et al Scott Rothstein et al th Juaicial Circuit Broward County Florida Case No Misc Court docket all court filings referenced therein and all discovery and discovery responses Complaint Amended Complaint Misc testimony deposition transcripts exhibits and videotapes including but not limited to a Scott Rothsteins testimony Rothstein Rosenfeldt Adler Communication E-mail from Russell Adler to Bradley Edwards cc p.m Mark Nurik E-mail from Bradley Edwards to Russell Adler p.m E-mail from Bradley Edwards to Russell Adler p.m E-mail from William Berger to Bradley a.m Edwards Russell Adler Steven Jaffe Matthew Weissing and Gary Farmer E-mail from Susan Stirling to Bradley Edwards p.m E-mail from Bradley Edwards to Russel Adler p.m E-mail from Bradley Edwards to Susan p.m Spencer Wendel E-mail from Susan Spencer Wendell to Bradley p.m Edwards No Date Description Objection Marked Marked in for Id Evidence E-mail from Bradley Edwards to Timothy Malloy p.m E-mail from Timothy Malloy to Bradley Edwards p.m E-mail from Susan Spencer Wendell to Bradley p.m Edwards E-mail from Bradley Edwards to William p.m Berger E-mail from William Berger to Grace Torres cc p.m Russell Adler and Bradley Edwards E-mail from Bradley Edwards to Susan a.m Stirling cc Carla Martinez E-mail from Bradley Edwards to Eric Glasser p.m E-mail from Bradley Edwards to Michele Dargan p.m Palm Beach Daily News E-mail from Bradley Edwards to Paul Cassell p.m E-mail from Michele Dargan to Bradley Edwards p.m E-mail from Bradley Edwards to Michele Dargan p.m E-mail from Michele Dargan to Bradley Edwards p.m E-mail from Bradley Edwards to Michele Dargan p.m E-mail from Michele Dargan to Bradley Edwards p.m E-mail from Bradley Edwards to Michele Dargan p.m E-mail from Michele Dargan to Bradley Edwards p.m E-mail from Bradley Edwards to Michele Dargan p.m E-mail from Michele Dargan to Bradley Edwards p.m E-mail from Bradley Edwards to Michele Dargan p.m E-mail from Michele Dargan to Bradley Edwards p.m E-mail from Bradley Edwards to Michele Dargan a.m No Date Description Objection Marked Marked in for Id Evidence E-mail from Bradley Edwards to Russell Adler p.m William Berger and Steven Jaffee E-mail from Michele Dargan Palm Beach Daily p.m News to Bradley Edwards E-mail from Bradley Edwards to William Berger E-mail from Bradley Edwards to Michele Dargan p.m E-mail from Michele Dargan to Bradley Edwards p.m E-mail from Bradley Edwards to Russell Adler p.m E-mail from Bradley Edwards to Michele Leone p.m E-mail from Bradley Edwards to Michele Dargan a.m E-mail from Michele Dargan to Bradley Edwards a.m E-mail from Jacquie Johnson to Bradley Edwards p.m Letter from Bradley Edwards re cross noticing depositions E-mail from Priscila A Nascimento to Scott p.m Rothstein cc Amy Howard and Adelita Cabello E-mail from Bradley Edwards to Susan Spencer a.m Wendel E-mail from Susan Spencer Wendel to Bradley a.m Edwards E-mail from Bradley Edwards to Michele Dargan a.m E-mail from Michele Dargan to Bradley Edwards a.m E-mail from Cara Holmes to Bradley Edwards p.m E-mail from Michele Dargan to Bradley Edwards p.m E-mail from Michele Dargan to Bradley Edwards p.m E-mail from Bradley Edwards to Michele Dargan p.m E-mail from Bradley Edwards to Michele Dargan No Date Description Objection Marked Marked in for Id Evidence E-mail from Bradley Edwards to Michele Dargan p.m E-mail from Michele Dargan to Bradley Edwards a.m E-mail from Bradley Edwards to Michael Isikoff p.m E-mail from Michael Isikoff to Bradley Edwards p.m E-mail from Bradley Edwards to Michael Isikoff a.m E-mail from Michael Isikoff to Bradley Edwards a.m E-mail from Bradley Edwards to Michael Isikoff a.m E-mail from Michael Isikoff to Bradley Edwards p.m E-mail from Michael Isikoffto Bradley Edwards p.m E-mail from Bradley Edwards to Mike Fisten cc p.m Ken Jenne E-mail from Bradley Edwards to Michael Isikoff p.m E-mail from Michael Isikoff to Bradley Edwards a.m E-mail from Bradley Edwards to Jacquie Johnson a.m E-mail from Bradley Edwards to Ken Jenne p.m E-mail from Bradley Edwards to Conchita Sarnoff p.m E-mail from Conchita Sarnoff to Bradley Edwards a.m E-mail from Bradley Edwards to Conchita Sarnoff p.m E-mail from Conchita Sarnoff to Bradley Edwards a.m E-mail from Elizabeth Villar to Bradley Edwards p.m and Ken Jenne cc Jacquie Johnson Pat Robe1is and Mike Fisten E-mail from Conchita Sarnoff to Bradley Edwards p.m E-mail from Conchita Sarnoff to Bradley Edwards p.m No Date Description Objection Marked Marked in for Id Evidence E-mail from Bradley Edwards to Conchita Sarnoff p.m E-mail from Conchita Sarnoff to Bradley Edwards E-mail from Bradley Edwards to Conchita Sarnoff p.m E-mail from Conchita Sarnoff to Bradley Edwards p.m E-mail from Bradley Edwards to Conchita Sarnoff a.m E-mail from Conchita Sarnoff to Bradley Edwards a.m E-mail from Bradley Edwards to Conchita Sarnoff a.m E-mail from Conchita Sarnoff to Bradley Edwards p.m E-mail from Conchita Sarnoff to Bradley Edwards p.m E-mail from Bradley Edwards to Conchita Sarnoff p.m E-mail from Conchita Sarnoff to Bradley Edwards p.m E-mail from Bradley Edwards to Conchita Sarnoff p.m E-mail from Conchita Sarnoff to Bradley Edwards p.m E-mail from Conchita Sarnoff to Bradley Edwards p.m E-mail from Bradley Edwards to Conchita Sarnoff p.m E-mail from Conchita Sarnoff to Bradley Edwards p.m E-mail from Conchita Sarnoff to Bradley Edwards p.m E-mail from Bradley Edwards to Elizabeth Villar p.m cc Ken Jenne and Pat Roberts E-mail from Bradley Edwards to Russell Adler p.m E-mail from Jacquie Johnson to Ann Marie p.m Villafana cc Bradley Edwards E-mail from Bradley Edwards to Susan Spencer p.m Wendel No Date Description Objection Marked Marked in for Id Evidence E-mail from Bradley Edwards to Beth p.m Williamson E-mail from Bradley Edwards to Michele Dargan p.m E-mail from Conchita Sarnoff to Bradley Edwards p.m E-mail from Conchita Sarnoff to Bradley Edwards p.m E-mail from Bradley Edwards to Conchita Sarnoff a.m E-mail from Conchita Sarnoff to Bradley Edwards a.m E-mail from Conchita Sarnoff to Bradley Edwards o.m E-mail from Conchita Sarnoff to Bradley a.m Edwards cc Renee/Carlos Morrison E-mail from Bradley Edwards to Conchita Sarnoff a.m E-mail from Conchita Sarnoff to Bradley Edwards a.m E-mail from Mike Fisten to Conchita Sarnoff p.m E-mail from Bradley Edwards to Ken Jenn and a.m Elizabeth Villar E-mail from Bradley Edwards to Nigel Rosser a.m E-mail from Nigel Rosser to Bradley Edwards a.m E-mail from Michael Isikoffto Bradley Edwards p.m E-mail from Bradley Edwards to Mike Fisten p.m E-mail from Bradley Edwards to Michael Isikoff o.m cc Jacquie Johnson E-mail from Michael Isikoff to Bradley Edwards p.m cc Jacquie Johnson E-mail from Bradley Edwards to Richard Johnson p.m E-mail from Grant Smith to Scott Rothstein p.m Bradley Edwards Ken Jenne Kip Hunter and Russell Adler cc Grant Smith E-mail from Mike Fisten to Bradley Edwards p.m No Date Description Objection Marked Marked in for Id Evidence E-mail from Bradley Edwards to Jacquie Johnson p.m cc Mike Fisten E-mail from Bradley Edwards to Conchita Sarnoff a.m E-mail from Conchita Sarnoff to Bradley Edwards a.m E-mail from Russell Adler to Bradley Edwards cc a.m Jacquie Johnson E-mail from Bradley Edwards to Mike Fisten cc p.m Jacquie Johnson E-mail from ABA Journal Weekly Newsletter to a.m Scott Rothstein E-mail from Bradley Edwards to Ken Jenne a.m E-mail from George Rush to Bradley Edwards p.m E-mail from Ken Jenne to Scott Rothstein p.m E-mail from Bradley Edwards to Jacquie Johnson a.m E-mail from Jacquie Johnson to Russell Adler Cara p.m Holmes Mike Fisten Michael Wheeler Marc Nurik William Berger Bradley Edwards Barry Stone and Ken Jenne cc Robert Buschel E-mail from Jacquie Johnson to Bradley Edwards p.m Marc Nurik Michael Wheeler Cara Holmes William Berger Russell Adler and Robert Buschel E-mail from William Berger to Pat Carter and a.m Bradley Edwards cc Grace Torres and Jacquie Johnson E-mail from Pat Diaz to Bradley Edwards p.m E-mail from Debra Villegas to Scott Rothstein a.m E-mail from Russell Adler to Jacquie Johnson and a.m Bradley Edwards Billing Contract for Services between Searcy Denny Scarola Barnhart Shipley and Bradley Edwards No Date Description Objection Marked Marked in for Id Evidence N/D Spreadsheet of Brad Edwards Time in Edwards adv Epstein Searcy Denney Scarola Barnhart and Shipleys Invoices for Disbursements to Bradley Edwards BJE03 BJE0 Searcy Denney Scarola Barnhart and Shipleys Matter Ledger Report BJE06 BJE038 Miscellaneous Rothstein Rosenfeldt Adlers Firm Directory Farmer Jaffe Weissing Edwards Fistos Lehrman P.L.s Our Attorneys website printout Criminal Complaint United States of America Alfredo Rodriguez USDC S.D Fla Case No Affidavit of Bradley James Edwards Affidavit of Bradley James Edwards Misc Subpoenas and Notices of Deposition for Alan Dershowitz David Copperfield and Leonard Baird Critton Luttier Coleman LLPs website printout for Robert Critton Jr htt12s://w.lawclc.com/team members Robert d-critton-jr Fowler White Burnett P.A.s website printout for Joseph Ackerman Jr htt12://w.fowler white.com Attornevs/id/3/read Bradley Edwards NID The National Crime Victim Bar Association presentation excerpt of aicle by Bradley Edwards Who is Responsible for Child Sexual Abuse NID The Florida Bars website member profile printout for Bradley James Edwards NID National Association of Distinguished Counsel biographical info1mation for Bradley Edwards The National Trial Lawyers Top Under Directory htt12://w.thenationaltrialla ers.org/to12-40 under-40 directory:/?last name Edwards citY state FL No Date Description Objection Marked Marked in for Id Evidence The National Trial Lawyers Profile View of Brad Edwards htt12://w.thenationaltrialla ers.org/12rofile view/Brad/Edwards/4409 La ers.com website info1mation for Bradley Edwards htt12 w.la ers.com/florida/fort lauderdale Bradl ey-J-Edwards-3489098-a Kubicki Drapers website attorney information for Brad Edwards Kubicki Drapers website attorney information for Brad Edwards The American Registry Website printouts of recognitions received by Bradley Edwards Farmer Jaffe Weissing Edwards Fistos Lehnnan website printout htt12 w.abuseandassault.com Abuse Un der Investigation Farmer Jaffe Weissing Edwards Fistos Lehrman website printout htt12 w.abuseandassault.com Abuse Under Investigation Farmer Jaffe Weissing Edwards Fistos Lehrman P.L.s website printout htt12 w.12athtojustice.com/media center/12ress-releases Farmer Jaffe Weissing Edwards Fistos Lehrman P.L website printout htt12://w.abuseandassault.com Abuse Farmer Jaffe Weissing Edwards Fistos Lehm1an website printout htt12 w.abuseandassault.com Abuse Under otabl Cases Farmer Jaffe Weissing Edwards Fistos Lehnnan P.L.s website attorney information for Brad Edwards w.12athtojustice.com attorneys/brad Farmer Jaffe Weissing Edwards Fistos Lehrman website printout htt12 w.12athtojustice.com/media center/achived-12ress Farmer Jaffe Weissing Edwards Fistos Lehrman website attorney infonnation for Brad Edwards with referenced articles No Date Description Objection Marked Marked in for Id Evidence A Winter Journal of Criminal Law and Criminology Volume Issue Crime Victims Rights During Criminal Investigations Applying the Crime Victims Rights Act Before Criminal Charges are Filed Politico Victims in Underage Sex Case Want Prosecutors to Testify Palm Beach Daily News Jeffrey Epstein Sex Scandal Alan Dershowitz Suffers Setback in Defamation Case Palm Beach Daily News Epstein Victims Attorneys Seek Partial Victory in Defamation Suit Palm Beach Post Boca-Resident Model Nabs Million Following Six-Year Divorce Battle Daily Mail.Com Florida Model Gets Whopping Million Payoutfi Real Estate Tycoon Ex-Husband After Nasty Six-Year Divorce Battle Palm Beach Daily News Appellate Court Reverses Palm Beach Sex Offender Jeffrey Epsteins Victory Daily Business Review Attorneys Suit Against Billionaire Allowed as Long as Justices Say Its OK I Palm Beach Daily News Judge Keeps Thousands of Epstein Documents Sealed WCVB5 Jury Awards Million to Mass Widower in Fatal Cabana Crash NBC6 Jury Awards Million in Fatal Cabana Crash CBS Miami Jury Awards Millions to Husband of Pregnant Woman Killed by Drunk Driver Sun Sentinel Jury Awards Million to Widower in Fatal Cabana Crash Daily Business Review The Lawyer Suing Legal Legend Alan Dershowitz Over Sex Offender The Washington Post Eleventh Circuit Rules that Discovery Can Move Forward on My Crime Victims Rights Act Case Palm Beach Daily News Appeals Court Rules Against Sex Offender Attorneys for Underage Victims Seek to Overturn Sweetheart Plea Sun-Sentinel Victims Win Right to See Negotiation that Led to Lenient Plea Deal Agreement/or Billionaire Sex Offender No Date Description Objection Marked Marked in for Id Evidence Palm Beach Post Avvellate Rulin1 Could Force Feds to Reconsider Sex Changes Against Palm Beacher Epstein Palm Beach Daily News Newest Lawsuit A1;ainst Epstein Expected to Include Victim Testimony CBS Miami Exclusive Sexual Assault Victim Alleges Abuse by Former Youth Pastor Sun-Sentinel Elevator Fall Nets Woman Million Jury Award July Daily Business Review Top Florida Verdicts Settlements of I Daily Business Review Suit Accuses Goldrush Strip Club of Scheme to Bilk Professionals Palm Beach Daily Business Review Jeffrey Epstein Amends Lawsuit Claims Victims Attorney Threatened to Depose His Friends Farmer Jaffe Weissings Facebook page with referenced articles A Lawnewz.com The Shameful Wav Feds Protected Convicted Pedophile Billionaire Jeffrey Epstein Fox News Fli1;ht LoJ;s Shmv Bill Clinton Flew on Sex Offenders Jet Much More than Previously Known Sun-Sentinel Feds Deceived Us About Billionaire Sex Offenders Sweetheart Deal Teen Victims Say NBC News Lawyers Victims Not Told of Sweetheart Deal for Jeffrey Epstein NY Daily News Jeffrey Epstein Accusers Sue Feds Over Hidden Non-Prosecution Conspiracy Farmer Jaffe Avveals Court Rules in Favor of Crime Victims Rights in Registered Pedophile Jeffi Epstein Case Daily Business Review Prosecutors Must Turn Over Docs in Billionaire Sex Offender Jefji Epstein Case Misc Court and arrest info1mation Bradley James Edwards Duval County Court Case No Misc Court and arrest information Bradley James Edwards Duval County Case No No Date Description Objection Marked Marked in for Id Evidence Exemption and/or Limitation Exclusion Tax Assessment of Notice of Satisfaction of Lien Relative to Tax Exemption Misc Docket and all court filings referenced therein US Bank National Association Bradley Edwards th Judicial Circuit Broward County Case No Petition/Complaint US Bank National Association Bradley Edwards th Judicial Circuit Broward County Case No Bradley Edwards Answer and Affirmative Defenses US Bank National Association Bradley Edwards th Judicial Circuit Broward County Case No Notice of Sale US Bank National Association Bradley Edwards th Judicial Circuit Broward County Case No Final Summary Judgment of Mortgage Foreclosure US Bank National Association Bradley Edwards th Judicial Circuit Broward County Case No Ce1iificate of Sale US Bank National Association Bradley Edwards th Judicial Circuit Broward County Case No Certificate of Title US Bank National Association Bradley Edwards th Judicial Circuit Broward County Case No Misc Docket and all court filings referenced therein Wells Fargo Bank NA Bradley Edwards th Judicial Circuit Broward County Case No AXCE Petition/Complaint Wells Fargo Bank NA Bradley Edwards th Judicial Circuit Broward County Case No Final Summary Judgment of Mortgage Foreclosure Wells Fargo Bank NA Bradley Edwards I th Judicial Circuit Broward County Case No Notice of Sale Wells Fargo Bank NA Bradley Edwards th Judicial Circuit Broward County Case No No Date Description Objection Marked Marked in for Id Evidence Ce1iificate of Sale Wells Fargo Bank NA Bradley Edwards th Judicial Circuit Broward County Case No Certificate of Title Wells Fargo Bank NA Bradley Edwards th Judicial Circuit Broward County Case No Misc Docket and all court filings referenced therein 1st United Bank Bradley Edwards th Judicial Circuit Broward County Case No Complaint pt United Bank Bradley Edwards th Judicial Circuit Broward County Case No Stipulation for Settlement st United Bank Bradley Edwards th Judicial Circuit Broward County Case No Misc Docket and all court filings referenced therein Wells Fargo Bank NA Bradley Edwards th Judicial Circuit Broward County Case No AXWE Complaint Wells Fargo Bank NA Bradley Edwards th Judicial Circuit Broward County Case No Bradley Edwards Motion to Dismiss Wells Fargo Bank NA Bradley Edwards th Judicial Circuit Broward County Case No AXWE Order Denying Motion to Dismiss Wells Fargo Bank NA Bradley Edwards th Judicial Circuit Broward County Case No AXWE Answer to Complaint Wells Fargo Bank NA Bradley Edwards th Judicial Circuit Broward County Case No Mediation Report Wells Fargo Bank NA Bradley Edwards th Judicial Circuit Broward County Case No Mediation Report Wells Fargo Bank NA Bradley Edwards th Judicial Circuit Broward County Case No Corporate Detail Printout from Sunbiz.org for The Law Office of Brad Edwards Associates LLC No Date Description Objection Marked Marked in for Id Evidence Articles of Organization for Florida Limited Liability Company for The Law Office of Brad Edwards Associates LLC Limited Liability Company Annual Report for The Law Office of Brad Edwards and Associates Limited Liability Company Annual Report for The Law Office of Brad Edwards and Associates Florida Bar Rules including but not limited to Florida Bar Rule Complaint Donald Baker The City of Hollywood et al Case No HUCK D.E Omnibus Order on Defendants Motion to Dismiss Donald Baker The City of Hollywood et al Case No D.E U.S Comi of Appeals Opinion Donald Baker City of Hollywood et al Case No New Times Broward Palm-Beach Tale of the Ta Dr Bernard Jansens Expert Report with attachments Misc All documents produced or relied upon or referenced by Dr Bernard Jansen in preparing his Re ort Expe1i Witness Report of Dr Bernard Jansen in Virginia Giuffre Ghislaine Maxwell USDC NY Supplemental Expert Witness Report of Dr Bernard Jansen in Virginia Gitiffre Ghislaine Maxwell USDC NY Misc All public records news articles and prior testimony of Dr Bernard Jansen Other Articles Kendall Coffey Law Firm Victimized by Scott Rothstein Legal Junkies WSJ Law Blo Rothstein Rosenfeldt Adler Ft Lauderdale Law Firm Dissolution Ponzi Scheme New Times Broward-Palm Beach Chie Jud Scott Rothstein Firm Has No Money and is Goin into Receivershi No Date Description Objection Marked Marked in for Id Evidence The New York Times Fraud Accusations ARainst Florida Lawyer Set Off a Race to Return His Donations Rothstein Returns After Contemplating Suicide Partner Says Florida Law Firm Asks to be Dissolved Sun Sentinel Scott Rothstein Investment Deals Seemed Too Good to be True Funds News FBI ARents Search Law Firm in Missing Funds Probe New Times Broward-Palm Beach Scott Rothstein The Jeffi Epstein and Bill Clinton Ploy Rothstein Accomplice Still on Lam Tour of Scott Rothstein Office Reveals Gallery of Whos Who Sun Sentinel FBI Doubts Rothstein Ran a Ponzi Scheme Alone Palm Beach Post FBI Doubts Rothstein Scheme a One-Man Show Sun Sentinel Hif!h-RankinK Police Officers Guarded Over Rothstein Inside the Rothstein Swindle Part I Sun Sentinel Rothstein Asks to Voluntarily Give Up Law License Rothstein and Dreier How Much Alike Inside the Rothstein Swindle Part II Former RAA Attorneys Take New Jobs Scherer Files Suit ARainst Rothstein et al Article by Paul Brinkman Rothstein Feeder George Levins Ugly Past Georf!e Levin was Rothstein Whale Rothstein Associate Levy Got Protection fi Plantation Cops Main Line Firms Clients Invested Million with Ponzi Lawyer Sun-Sentinel Scott Rothstein You re in Town Full of Thieves Miami Herald Feds Scott Rothstein Ponzi Scheme Paid Salaries at Law Firm The Rothstein Wires Sun Sentinel Florida Bar LookinK at Former Attorneys from Rothstein Firm No Date Description Objection Marked Marked in for Id Evidence July Sun Sentinel Former Scott Rothstein Attorneys Cleared by the Florida Bar South Florida Business Journal A Year After Rothstein Many Questions Unanswered The Florida Bar Scott Rothstein Scandal One Year Later Forbes Rothstein Expose Details Sex Murder and Corruption Behind Floridas Largest Ponzi Scheme Five Years on Rothstein Ponzi Still Resonates Palm Beach Daily News Epstein Paid Three Women Million to End Underage Sex Lawsuits i Jlrt fi I iif All public records and news articles relating to Scott Rothstein Rothstein Rosenfeldt Adler Bradley Edwards and any witnesses listed by either party All court dockets and filings in all matters against Jeffrey Epstein relating to any victims claims All prior testimony statements rep01is and affidavits of any witness or experts All charts/analyses prepared based on documents exchanged or later discovered All foundation exhibits All rebuttal and impeachment exhibits Demonstrative aids and exhibits including but not limited to charts timelines diagrams models surveys photographs and blow-ups All newly discovered documents/exhibits Any and all exhibits listed by Bradley Edwards by identifying these as exhibits Plaintiff is not waiving his right to object to any of Edwards exhibits introduced at trial Plaintiff/Counter-Defendant reserves his right to supplement this Exhibit List I HEREBY CERTIFY that a true and c01Tect copy of the foregoing was sent via E-Serve to all Counsel on the attached list this day of December Jr A rney E-Mail jsx searcylaw.com and mmccann searcylaw.com Primary E-Mail _scarolateam searcylaw.com Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida Phone Jack A Goldberger Esquire jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss P.A Australian A venue Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Nichole Segal Esquire njs FLAppellateLaw.com kbt FLAppellateLaw.com Burlington Rockenbach P.A Railroad Avenue Suite West Palm Beach FL Phone Attorneys for Bradley Edwards Bradley Edwards Esquire staff.efile pathtojustice.com Andrews A venue Suite Fort Lauderdale FL Phone COUNSEL LIST Fax Scott Link Esquire Eservice linkrocklaw.com Scott linkrocklaw.com Kara linkrocklaw.com Angela linkrocklaw.com Tanya linkrocklaw.com Link Rockenbach P.A Palm Beach Lakes Boulevard Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Marc Nurik Esquire marc nuriklaw.com One Broward Blvd Suite Fort Lauderdale FL Phone Fax Attorneys for Scott Rothstein EXHIBIT Filing E-Filed PM JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendant IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO SEVENTH AMENDED AND SUPPLEMENTAL WITNESS LIST OF COUNTER-PLAINTIFF BRADLEY EDWARDS Counter-Plaintiff BRADLEY EDWARDS by and through his undersigned attorneys hereby supplements his list of witnesses for trial as follows WITNESSES EXPECTED TO BE PRESENTED Bradley Edwards Jeffrey Epstein Sarah Vickers formerly Kellen c/o John Stephenson Peachtree Street Atlanta Georgia Nadia Marcinkova c/o Erica Dubno Third A venue Suite New York New York Virginia Roberts Guiffre c/o Stan Pottinger Twin Lakes Road Suite South Salem NY EDWARDS ADV EPSTEIN Case No Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley Edwards Page of22 Maria Farmer c/o Peter Guirguis Esq Mintz Gold LLP Third A venue th Floor New York Annie Farmer c/o Peter Guirguis Esq Mintz Gold LLP Third Avenue th Floor New York Nadia Bjorlin Riverside Drive Suite Sherman Oaks CA Alexandra Hall c/o Robert Josefsberg Esq Podhurst Orseck PA One S.E rd Avenue Suite Miami FL Robert Josefsberg Esquire Podhurst Orseck PA One S.E rd Avenue Suite Miami FL Detective Joseph Recarey Palm Beach Police Depaiiment South County Road Palm Beach FL Chief Michael Reiter Palm Beach Police Department South County Road Palm Beach FL John Connolly c/o Simon Schuster 6th A venue New York New York EDWARDS ADV EPSTEIN Case No Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley Edwards Page of22 Charles Lichtman Esquire Berger Singerman East Las Olas Boulevard Suite F01i Lauderdale FL Courtney Wild c/o Adam Horowitz Horowitz Law North Andrews A venue Suite Fort Lauderdale FL Antonio Figueroa Tony Palm Coast Florida Records Custodian of Palm Beach Police Department South County Road Palm Beach FL Records Custodian of United States Attorneys Office for the Southern District of Florida Records Custodian of the Federal Bureau of Investigations Spencer Kuvin Esquire Australian Avenue West Palm Beach Florida Theodore Leopold Esquire Cohen Milstein PGA Boulevard Suite Palm Beach Gardens Florida Rinaldo Rizzo c/o Robe1i Lewis East 45th Street I 17th Floor New York NY Adam Horowitz Esquire Andrews Ave Suite Ft Lauderdale FL EDWARDS ADV EPSTEIN Case No Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley Edwards Page of22 Isidro Garcia Esquire Garcia Law Firm P.A Datum Street Suite West Palm Beach FL Earleen Cote Esquire Kubicki Draper One East Broward Boulevard Suite Fort Lauderdale FL Bernard Jansen Ph.D c/o Jack Scarola Searcy Denney Scarola Barnhart Shipley Palm Beach Lakes Blvd West Palm Beach FL William Berger Esquire Weiss Handler Cornwell P.A Glades Road Suite Boca Raton FL WITNESSES WHICH MAY BE CALLED IF THE NEED ARISES Adriana Mucinska South Shore Drive Miami Beach FL Landon Thomas c/o New York Times Eighth A venue New York NY Oren Kramer c/o Boston Provident L.P 5th Avenue New York NY Lawrence La Vecchio United States Attorneys Office Southern District of Florida Broward Financial Center Fo1i Lauderdale Florida EDWARDS ADV EPSTEIN Case No Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley Edwards Page of22 Amanda Laszlo c/o Adam Horowitz Horowitz Law North Andrews A venue Suite Fort Lauderdale FL Evgenia Ignatieva Broadway New York NY Anouska DeGeorgiou Edinburgh Avenue Los Angeles CA Angelique Garcia c/o Adam Horowitz Horowitz Law North Andrews Avenue Suite Fort Lauderdale FL Carolyn Andriamo c/o Jack Scarola Searcy Denney Scarola Barnhart Shipley Palm Beach Lakes Blvd West Palm Beach FL Ashley Davis c/o Robert Josefsberg Esq Podhurst Orseck PA One S.E rd A venue Suite Mian1i FL Brandy Brenson c/o Spencer Kuvin South Australian Ave West Palm Beach Florida Molly Smythe c/o Robert Josefsberg Esq Podhurst Orseck PA One S.E rd Avenue Suite Miami FL EDWARDS ADV EPSTEIN Case No Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley Edwards Page of22 Com1ney Langley c/o Spencer Kuvin South Australian Ave West Palm Beach Florida William Scherer Esquire Federal Hwy Fort Lauderdale FL Paul Cassell Esq University Street Salt Lake City Utah UT Faith Pentek c/o Adam Horowitz Horowitz Law North Andrews Avenue Suite Fort Lauderdale FL Teala Davies Clark Street West Hollywood CA Felicia Esposito Cartwright c/o Robert Josefsberg Esq Podhurst Orseck PA One S.E rd Avenue Suite Miami FL Jennifer Amenold c/o Robert Josefsberg Esq Podhurst Orseck PA One S.E rd A venue Suite Miami FL Jennifer Pitts Catino c/o Robert Josefsberg Esq Podhurst Orseck PA One S.E rd A venue Suite Miami FL EDWARDS ADV EPSTEIN Case No Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley Edwards Page of22 Prince Andrew Albert Christian Edwards Duke of York Buckingham Palace Road London SWlA lAA Frederic Fekkai Address Currently Unknown Kara Henderson c/o Robert Josefsberg Esq Podhurst Orseck PA One S.E rd A venue Suite Miami FL Lesley Groff c/o Mike Miller A venue of the Americas New York NY Dave Rogers c/o Bruce Reinhart Flagler Drive Ste West Palm Beach FL Lauren Murphy c/o Adam Horowitz Horowitz Law North Andrews A venue Suite Fort Lauderdale FL Leigh Skye Patrick c/o Robert Josefsberg Esq Podhurst Orseck PA One S.E rd A venue Suite Miami FL Meagan Dorshel c/o Robert Josefsberg Esq Podhurst Orseck PA One S.E rd Avenue Suite Miami FL EDWARDS ADV EPSTEIN Case No Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley Edwards Page of22 Michelle Licata c/o Adam Horowitz Horowitz Law N01ih Andrews A venue Suite F01i Lauderdale FL Molly Smythe c/o Robe1i Josefsberg Esq Podhurst Orseck PA One S.E rd Avenue Suite Miami FL Tod Meister Seminole A venue Palm Beach FL Rhiannon Schwegel c/o Robert Josefsberg Esq Podhurst Orseck PA One S.E rd Avenue Suite Miami FL Sabrina Ewart c/o Robert Josefsberg Esq Podhurst Orseck PA One S.E rd A venue Suite Miami FL Saige Gonzales c/o Spencer Kuvin South Australian Ave West Palm Beach Florida Johanna Sjoberg c/o Marshall Dore Louis NW third Street Suite Miami FL Jason Richards Federal Bureau of Investigation NW nd AVE Miami FL EDWARDS ADV EPSTEIN Case No Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley Edwards Page of22 Shawna Rivera c/o Bradley Edwards Esq Edwards Pottinger LLC North Andrews Avenue Suite Fort Lauderdale FL Tatum Miller c/o Bradley Edwards Esq Edwards Pottinger LLC North Andrews Avenue Suite Fort Lauderdale FL Vanessa Zalis c/o Adam Horowitz Horowitz Law North Andrews Avenue Suite Fort Lauderdale FL Virginia Alvarez c/o Adam Horowitz Horowitz Law North Andrews A venue Suite Fort Lauderdale FL Yolanda Lopez c/o Adam Horowitz Horowitz Law North Andrews A venue Suite Fort Lauderdale FL Nezbitt Kurkendall Federal Bureau of Investigation NW nd Ave Miami FL Daynia Nida c/o Isidro Garcia Garcia Law Firm P.A Datura Street Suite West Palm Beach FL EDWARDS ADV EPSTEIN Case No Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley Edwards Page of22 Igor Zinoview Address Currently Unknown Pralaya Cuomo Address CmTently Unknown Svetlana Pozhidaeva East Street New York NY Seth Lehrman North Andrews Ave Suite Fort Lauderdale FL Matt eissing North Andrews Ave Suite Fort Lauderdale FL Maria Villafana Australian Avenue West Palm Beach FL Any additional individuals identified as victims by the United States Attorneys Office and whose identities were conveyed to Jeffrey Epstein as part of a list supplied as it related to the NP A Leslie Wexner Three Limited Parkway Columbus Ohio President Donald Trnmp cl Alan Garten Esq Fifth A venue New York NY LaiTy Visoski Pine Point Road Riviera Beach FL Maritza Vasquez SW Terrace Miami FL EDWARDS ADV EPSTEIN Case No Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley Edwards Page of22 Maximilia Cordero c/o William Unroch Esquire West End Apt New York NY Brittany Beale c/o Spencer Kuvin Australian Avenue West Palm Beach Florida Melissa Eaton Share Rd Tallahassee FL Danielle Hendrick Dicenso c/o Robert Josefsberg Esq Podhurst Orseck PA One S.E rd A venue Suite Miami FL David Copperfield David Seth Kokin Glowing Sunset Lane Las Vegas NV Haley Robson 72ND CTN West Palm Beach FL Michael Fisten Weston FL Russell Adler Delray Beach FL Marie Alessi Fairway Lakes Dr Boynton Beach FL Janusz Banasiak El Brillo Way Palm Beach FL EDWARDS ADV EPSTEIN Case No Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley Edwards Page of22 Beata Banasiak El Brillo Way Palm Beach FL Juan Alessi Fairway Lakes Dr Boynton Beach FL Michael Friedman A venida Madero La Quinta CA Jeny Goldsmith Silver Fox Lane West Palm Beach FL Rosalie Freedman Avenida Madero La Quinta CA aldson Cotrin Address Currently Unknown Dana Burns East 66TH Street Apt lP New York NY Cecelia Stein Unknown South Africa Glenn Dubin 5th Ave Unit New York NY Abigail Wexner Three Limited Parkway Columbus Ohio Officer Munyan Palm Beach Police Department South County Road EDWARDS ADV EPSTEIN Case No Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley Edwards Page of22 Palm Beach FL Officer Minot Palm Beach Police Department South County Road Palm Beach FL Sgt Sorge Palm Beach Police Department South County Road Palm Beach FL Christina enero Address CmTently Unknown Joseph Pagnano Flagler Drive Suite West Palm Beach FL Stephan Kosslyn Garfield Street Cambridge MA Cecile Dejongh Estate Mafolie St Thomas VI Tommy Mottola Caribbean Road Palm Beach FL Mike Sanka Beverly Drive Suite Beverly Hills CA Cecilia Steen SI A Witness William Bill Riley Coral Ridge Drive Coral Springs FL EDWARDS ADV EPSTEIN Case No Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley Edwards Page of22 Howard Rubenstein A venue of the Americas New York NY Robe1i Meister Seminole Ave Palm Beach FL Todd Meister Seminole Ave Palm Beach FL President William Clinton William Hammond Fontana Place Royal Palm Beach FL Robert Roxburgh North Flagler Dr West Palm Beach Florida Michele Pagan Palm Beach Police Department South County Road Palm Beach FL Michele Dawson Palm Beach Police Department South County Road Palm Beach FL Amy F01iimer North Old Country Road Wellington FL Anna Skidan East th Street Apt 6E New York NY EDWARDS ADV EPSTEIN Case No Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley Edwards Page of22 Christina Venero NW Fresco Way Apt Jensen Beach FL Dara Gehringer Dara Preece Kingston Court West Palm Beach Florida Juliana Barbosa Pinta Road Miami FL Latasha Lowe c/o Adam Horowitz Horowitz Law North Andrews Avenue Suite Fmi Lauderdale FL Melissa Hanes Sunshine Blvd West Palm Beach Florida Zack Bryan Larch Way Wellington Florida Zinta Braukis Avenue Los Angeles CA Larry Morrison Cobblefield Dr Wellington FL Story Cowles Olive Ave Unit West Palm Beach FL Michael Dawson Palm Beach Police Department South County Road Palm Beach FL EDWARDS ADV EPSTEIN Case No Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley Edwards Page of22 Salaam Kahlid Monroe Menores Ave Apt Coral Gables FL Jelitza Negrette Chandlers Warf Portland ME Sergia Cordero Brickell Bay Drive Miami FL Cassandra Rivera El Claro Circle West Palm Beach FL Randee Speciale Palm Beach Victim Services North Dixie Highway West Palm Beach FL Nicole Hesse Address Cunently Unknown Steven Hoffenberg Address Currently Unknown Michael Stroll Address CmTently Unknown Douglas Shoettle Riverside Dr New York NY Ghislaine Maxwell Address Cunently Unknown Amazon Records Custodian Yellow Cab Records Custodian EDWARDS ADV EPSTEIN Case No Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley Edwards Page of22 Citrix Systems Inc Records Custodian Federal Bureau oflnvestigation Records Custodian Milton Girls Juvenile Facility Records Custodian East Milton Road Milton FL School District of Palm Beach County Records Custodian Forest Hill Blvd Suite West Palm Beach FL St Marys Medical Center Records Custodian th Street West Palm Beach FL Wellington Reginal Hospital Records Custodian Forrest Hill Blvd Wellington FL All witnesses that Defendants have listed on their Witness List not objected to by Plaintiff All rebuttal witnesses All People on Jeffrey Epsteins Inmate Visitor Log while he was in jail WITNESS TESTIMONY EXPECTED TO BE PRESENTED BY MEANS OF DEPOSITION Mark Epstein Vandam Street New York NY Adriana Ross Adriana Mucinska c/o Alan Ross Esq Louella Rabuyo El Brillo Way Palm Beach FL Alfredo Rodriguez EDWARDS ADV EPSTEIN Case No Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley Edwards Page of22 c/o Federal Public Defender or Bureau of Prisons SW 86TH Lane Miami FL Scott Rothstein c/o Mark Nurik One East Broward Boulevard Suite Fort Lauderdale Florida Jeffrey Epstein Courtney Wild c/o Adam Horowitz Horowitz Law North Andrews A venue Suite Fo11 Lauderdale FL EXPERT WITNESSES Bernard Jansen Ph.D c/o Jack Scarola Searcy Denney Scarola Barnhai1 Shipley Palm Beach Lakes Blvd West Palm Beach FL The following witnesses are attorneys that are not retained or specially employed to provide expert testimony but may provide opinions relating to the propriety of Brad Edwards conduct of discovery in the prosecution of the Epstein claims Robert Josefsberg Esquire Podhurst Orseck PA One S.E rd A venue Suite Miami FL Charles Lichtman Esquire Berger Singerman East Las Olas Boulevard Suite Ft Lauderdale FL EDWARDS ADV EPSTEIN Case No Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley Edwards Page of22 Spencer Kuvin Esquire Australian Avenue West Palm Beach Florida Theodore Leopold Esquire Cohen Milstein PGA Boulevard Suite Palm Beach Gardens Florida Adam Horowitz Esquire Andrews Ave Suite Ft Lauderdale FL Isidro Garcia Esquire Garcia Law Firm P.A Datura Street Suite West Palm Beach FL Earleen Cote Esquire Kubicki Draper One East Broward Boulevard Suite Fort Lauderdale FL William Berger Esquire Weiss Handler Cornwell P.A Glades Road Suite Boca Raton FL Plaintiff reserves the right to amend this list EDWARDS ADV EPSTEIN Case No Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley Edwards Page of22 I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all Counsel on the attached list this day of Florida Bar No Attofey Mail jsx searcylaw.com and me secylaw.com Pri a E-Mail _scarolateam searcylaw.com Se Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida Phone Fax Attorneys for Bradley Edwards EDWARDS ADV EPSTEIN Case No Seventh Amended and Supplemental Witness List of Counterplaintiff Bradley Edwards Page of22 COUNSEL LIST Jack Scarola Esquire scarolateam searcylaw.com Searcy Denney Scarola Barnhart Shipley PA Palm Beach Lakes Boulevard West Palm Beach FL Phone Fax Attorneys for Bradley Edwards Scott Link Esq Link Rockenbach P.A Scott linkrocklaw.com Kara linkrocklaw.com Palm Beach Lakes Boulevard Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein William Chester Brewer Esquire wcblaw aol.com wcblawasst gmail.com Australian A venue Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Jack A Goldberger Esquire jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss P.A Australian A venue Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein EDWARDS ADV EPSTEIN Case No Seventh Amended and Supplemental Witness List ofCounterplaintiffBradley Edwards Page of22 Bradley Edwards Esquire staff.efile pathtojustice.com Fanner Jaffe Weissing Edwards Fistos Lehrman P.L Andrews A venue Suite Fort Lauderdale FL Phone Fax Tonja Haddad Coleman Esquire tonja tonjahaddad.com efiling tonjahaddad.com Tonja Haddad P.A SE 7th Street Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein Marc Nurik Esquire marc nuriklaw.com One Broward Blvd Suite Fort Lauderdale FL Phone Fax Attorneys for Scott Rothstein EXHIBIT Filing E-Filed PM JEFFREY EPSTEIN Plaintiff/Counter-Defendant SCOTT ROTHSTEIN individually and BRADLEY EDWARDS individually Defendants/Counter-Plaintiff IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Case No PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEINS AMENDED TRIAL WITNESS LIST Plaintiff/Counter-Defendant Jeffrey Epstein files this Amended Trial Witness List as follows Bradley Edwards c/o Edwards Pottinger LLC Andrews A venue Suite Fort Lauderdale FL Scott Rothstein c/o Marc Nurik Law Offices of Marc Nurik One Broward Blvd Suite Ft Lauderdale FL Joseph Ackerman Jr c/o Fowler White Burnett North Flagler Drive Suite West Palm Beach FL William Berger c/o Greenspoon Marder Broward Boulevard Suite Ft Lauderdale FL Jonathan Birkman c/o Quraishi Birkman PLLC S.E Eighth Street Deerfield Beach FL Wayne Black c/o Wayne Black Associates One Brickell Square Brickell Avenue Suite Miami FL Chester Brewer Jr c/o Chester Brewer Jr P.A Australian Avenue South Suite West Palm Beach FL Robert Busche c/o Busche Gibbons P.A S.E Third Avenue Suite One Financial Plaza Ft Lauderdale FL Paul Cassell c/o Hatch James Dodge P.C West Broadway Suite Salt Lake City UT Tonja Haddad Coleman c/o Tonja Haddad P.A S.E Seventh Street Suite Ft Lauderdale FL Robert Critton Jr c/o Critton Luttier Coleman LLP Banyan Boulevard Suite West Palm Beach FL Pasquale Pat Diaz c/o Pat Diaz Associates Inc Executive Park Drive Suite Weston FL Abraxas A.J Discala Address Unknown Jane Doe c/o Edwards Pottinger LLC Andrews Avenue Suite Fort Lauderdale FL Mercedes Estrada Address Unknown Gary Farmer Jr c/o Gary Farmer Jr P.A N.E th Avenue Lighthouse Point FL Michael Fisten c/o Blue Line Investigative Solutions Sheridan Street Suite Hollywood FL Christina Fitch Address Unknown Shawn Gilbert Address Unknown Scott A Goldstein c/o The Law Offices of Scott Goldstein P.A Congress Avenue Suite Boynton Beach FL Cara Holmes Sheridan St Ft Lauderdale FL Steven Jaffe c/o Upchurch Watson White Max Pine Island Road Suite Plantation FL Rodney Janis c/o Goldberg Segalla LLP Lakeview Avenue Suite West Palm Beach FL Kenneth Jenne Address Unknown Jacquie Johnson Address Unknown Denis A Kleinfeld c/o Kleinfeld Legal Advisors P.A N.E th Street Suite North Miami Beach FL Christopher Knight c/o Fowler White Burnett North Flagler Drive Suite West Palm Beach FL Dean Kretschmar c/o Soaring Eagle Investments LLC N.E th Court Ft Lauderdale FL Seth Lehrman c/o Edwards Pottinger LLC Andrews Avenue Suite Fort Lauderdale FL Michael Legamaro c/o Legamaro Banipal LLP Wacker Drive Suite Chicago IL George Levin Address Unknown Charles Lichtman c/o Berger Singerman LLP Las Olas Blvd Suite Fort Lauderdale FL Carl Linder c/o Greenspoon Marder Brickell Ave Suite Miami FL Mark Luttier c/o Critton Luttier Coleman LLP Banyan Boulevard Suite West Palm Beach FL L.M c/o Edwards Pottinger LLC Andrews Avenue Suite Fort Lauderdale FL Maribel Matiska Address Unknown Priscilla Nascimento Address Unknown Marc Nurik c/o Law Offices of Marc Nurik One Broward Boulevard Suite Ft Lauderdale FL Michael Pike c/o Pike Lustig LLP Mercer A venue Suite West Palm Beach FL FrankPreve Address Unknown Thane Ritchie c/o Ritchie Capital Management Address Unknown Patrick Roberts c/o Blue Line Investigative Solutions Sheridan Street Suite Hollywood FL David Rogers Easton Drive Lake Worth FL Alan Sakowitz c/o Pointe Development Company Kane Concourse Floor Bay Harbor Islands FL Lilly Ann Sanchez c/o The LS Law Firm Four Seasons Tower Suite Brickell A venue Miami FL Jack Scarola c/o Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach FL William Scherer c/o Conrad Scherer LLP Federal Highway Suite Ft Lauderdale FL Jack Simony c/o Platinum Partners New York NY Susan Stirling c/o Promise Healthcare Inc N.W st Street Boca Raton FL Barry Stone Liseron Boynton Beach FL Debra Villegas Address Unknown Larry Visoski Pine Point Road Riviera Beach FL Linda Von Allmen Address Unknown E.W c/o Edwards Pottinger LLC Andrews Avenue Suite Fort Lauderdale FL Beth Williamson Address Unknown Ronald Wise Address Unknown Phaedra Xanthos CPA CFE Riverland Road Ft Lauderdale FL Any and all witnesses listed by Bradley Edwards depending on their testimony in Edwards case in chief REBUTTAL WITNESSES Katherine Ezell S.W 7pt Place Miami FL Allan Garten Barlow Road Aurora OR Adam Horowitz c/o Horowitz Law Andrews Avenue Suite Fort Lauderdale FL Amy Josefsberg-Ederi c/o Miami-Dade State Attorneys Office N.W th Avenue Miami FL Robert Josefsberg c/o Podhurst Orseck P.A SunTrust International Center One S.E Third Avenue Suite Miami FL Stuart Mermelstein c/o Herman Law Firm P.A Town Center Circle Suite Boca Raton FL Richard Willits c/o Richard Willits P.A Wandering Woods Way Ponte Vedra FL Iliana Yarzabal c/o Fowler White Burnett P.A Brickell Arch Brickell Avenue Floor Miami FL Any and all witnesses whose names appear in depositions interrogatories or documents produced in response to requests for production provided by Bradley Edwards depending on the testimony in Edwards case in chief EXPERT WITNESS Culver Skip Smith I Culver Smith I P.A South Australian Avenue Suite West Palm Beach FL Telephone Subject Matter Mr Smith will testify as to legal ethics and responsibility probable cause and professional reputation Substance of the Facts and Opinions The pleadings and information that was available before the original civil proceeding was initiated and discovered during the pendency of the original civil proceeding and deposition testimony Summary of Grounds for Each Opinion Mr Smith has not reached his final op1mons Curricula Vitae A copy of Mr Smiths Curricula Vitae is attached as Exhibit A Epstein reserves the right to list and/or call any and all newly discovered witnesses upon proper notice and to call and/or produce any and all additional witnesses necessary for impeachment or rebuttal Epstein reserves the right to amend and/or supplement this Witness List upon proper notice to the parties and the Court CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on December through the Courts e-filing portal pursuant to Florida Rule of Judicial Administration Jack Scarola LINK ROCKENBACH PA Palm Beach Lakes Boulevard Suite West Palm Beach Florida fax By Isl Scott Link Scott Link FBN Kara Berard Rockenbach FBN Angela Many FBN 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 SERVICE LIST Nichole Segal Searcy Denny Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard Burlington Rockenbach P.A Courthouse Commons Suite West Railroad A venue West Palm Beach FL mep searcylaw.com jsx searcylaw.com scarolateam searcylaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards West Palm Beach FL njs FLAppellateLaw.com kbt FLAppellateLaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Bradley Edwards Marc Nurik Edwards Pottinger LLC Law Offices of Marc Nurik Andrews Avenue Suite One Broward Boulevard Suite Fort Lauderdale FL Ft Lauderdale FL brad epllc.com marc nuriklaw.com staff.efile pathtojustice.com Counsel for Defendant Scott Rothstein Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Jack A Goldberger Atterbury Goldberger Weiss P.A Australian A venue Suite West Palm Beach FL goldberger agwpa.com smahoney agwpa.com Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein CULVER SMITH I P.A South Australian Avenue Suite West Palm Beach FL w.culversmithlaw.com OCCUPATION/PROFESSION Lawyer and consultant Culver Smith I CURRICULUM VITAE ofc fax cell csmith culversmithlaw.com Practice emphasis Counseling and representation of lawyers law firms and others on ethics professional responsibility professional disciplinary proceedings sanctions disqualification unlicensed practice of law malpractice and loss prevention service as expert witness in litigation involving such matters conduct of ethics audits for law firms counseling and representation of applicants for admission or reinstatement to the bar counseling and representation of public officials and employees on ethics compliance and complaints conduct of internal corporate investigations service as special magistrate arbitrator and mediator representation and consultation on appeals in all courts More than forty-five years of experience in the field as well as experience in law-firm management EXPERIENCE Counsel for respondents in hundreds of lawyer-disciplinary unlicensed-practice-of-law and bar admission proceedings including appeals in the Supreme Court of Florida Representation in dozens of disqualification and sanctions proceedings Testifying/consulting expert in numerous cases involving lawyer ethics and professional responsibility issues Wide variety of civil litigation and appeals including matters involving contracts business torts professional responsibility and malpractice corporate and partnership relationships officer and director liability and trust and estate disputes EDUCATION AND LICENSING Bachelor of Arts Washington and Lee University Doctor of Jurisprudence Washington and Lee University College of Law replaced LLB conferred Admitted to practice in Florida California now inactive U.S District Court Southern District of Florida U.S Court of Appeals Eleventh Circuit Culver Smith I CURRICULUM VITAE PROFESSIONAL EMPLOYMENT HISTORY Law Clerk to Judge George Shannon Jr and Judge Robert Mann District Court of Appeal of Florida Second District summarized briefs and records-on-appeal researched law drafted opinions Associate Jones Adams Paine Foster P.A West Palm Beach associate in midsize law firm for four months before commencing active military duty researched law drafted pleadings and briefs conducted depositions and handled motion hearings Lieutenant Judge Advocate Generals Corps U.S Naval Reserve active duty as military lawyer two years at Naval Law Center San Diego CA prosecuting and defending courts-martial cases two years as staff judge advocate at Naval Air Station Miramar Fightertown U.S.A San Diego CA advising commanding officer on wide variety of military and civilian legal matters Associate John Dell P.A West Palm Beach associate in small general-practice law firm handled various litigation and nonlitigation matters Shareholder Dell and Smith P.A West Palm Beach shareholder in small general practice law firm handled various litigation matters including personal-injury and commercial cases Shareholder Adams Coogler Watson Smith P.A West Palm Beach shareholder in small-to-midsize insurance-defense firm handled defense of personal-injury product-liability and professional-malpractice cases Partner Steel Hector Davis LLP West Palm Beach senior litigator in large Miami based law firms West Palm Beach office chaired office litigation department recruited trained and supervised litigation associates and legal assistants handled wide variety of complex civil business litigation professional-malpractice cases and probate litigation Shareholder Jones Foster Johnston Stubbs P.A West Palm Beach shareholder in midsize general-practice law firm handled wide variety of civil business litigation and probate litigation Partner Holland Knight LLP West Palm Beach senior litigator in international law firms West Palm Beach office handled wide variety of civil business litigation probate litigation and appeals served as office Executive Partner Shareholder Culver Smith P.A West Palm Beach solo trial and appellate practice substantial focus on lawyer ethics and professional responsibility Partner Fox Rothschild LLP West Palm Beach senior litigator in national law firms West Palm Beach office Shareholder Culver Smith P.A West Palm Beach solo legal and consulting practice substantial focus on ethics professional responsibility and related matters appellate representation and consultation Culver Smith I CURRICULUM VITAE PROFESSIONAL AND LAW-RELATED SERVICE The Florida Bar Member Board of Governors Executive Committee Member Professional Ethics Committee Chairperson Member Vision Commission Chairperson MJP/Reciprocity-State Focus Committee Bar Admissions Subgroup Member Standing Committee on Professionalism Vice Chairperson Member Hawkins Commission on Discipline System Member Special Committee to Review ABA Model Rules Member Ethics Review Panel Member Law-Related Education Committee Member Long Range Planning Committee Chairperson author/editor of Meeting the Challenges A Strategic Plan for the Florida Bar Member Special Committee to Study Composition of Board of Governors Vice Chairperson Commission on Lawyer Professionalism principal author of Florida Bar Ideals and Goals of Professionalism and Florida Lawyers Creed of Professionalism adopted superseded Chairperson Special Committee on Priorities for the Member Special Committee to Study Reapportionment of the Board of Governors author of The Florida Bars answer and counterpetition in Florida Bar re Amendments to Rules Regulating the Florida Bar Reapportionment So 2d Fla adopting Florida Bars proposed plan for apportionment of Board of Governors Member Program Evaluation Committee Chairperson Chairperson Special Study Committee on Lawyer Referral Services Member Special Study Committee on Model Rules of Professional Conduct Member Fifteenth Judicial Circuit Grievance Committee Chairperson Member Civil Procedure Rules Committee Member Trial Lawyers Section and Appellate Practice Section Culver Smith I CURRICULUM VITAE Palm Beach County Bar Association President President-Elect Secretary Member Board of Directors President Young Lawyers Section Member Professionalism Committee Co-Chairperson Member Solo Small Firm Practitioners Committee Member Judicial Campaign Practices Commission Member Historical Committee Chairperson Member Historic Courtroom Fundraising Committee Member Long Range Planning Committee Member Revitalization of the Bar Committee Chairperson Bulletin Editorial Committee Chairperson Circuit Court Civil Practice Committee Chairperson New Member Orientation Committee Chairperson Membership Committee American College of Trial Lawyers Fellow Member Florida State Committee Member Legal Ethics and Professionalism Committee f/k/a Legal Ethics Committee Chairperson Tri-State Meeting Committee Association of Professional Responsibility Lawyers Member Member Program Committee Chairperson Florida Association of Bar Defense Lawyers Charter member member Board of Directors Culver Smith I CURRICULUM VITAE American Bar Association Member Center for Professional Responsibility Member Section of Litigation The Florida Bar Foundation Member Board of Directors Executive Committee Member Development Committee Member Improvements in the Administration of Justice IOTA Grant Committee Chairperson Investment Committee Vice Chairperson Law Student Assistance IOTA Grant Committee Member Legal Assistance for the Poor IOTA Grant Committee Chairperson Palm Beach County Fellows Campaign Member Steering Committee Palm Beach County Fellows Campaign Fourth District Court of Appeal 50th Anniversary Committee Inc Member Board of Directors Fourth District Court of Appeal Historical Society Inc Member Board of Directors Member Florida Fifteenth Circuit Judicial Nominating Committee Chairperson Chairperson Ad Hoc Magistrate Selection Panel United States District Court Southern District of Florida Member Florida Fifteenth Judicial Circuit Media Committee Member Florida Fifteenth Judicial Circuit Indigent Services Committee Culver Smith I CURRICULUM VITAE PROFESSIONAL AWARDS AND RECOGNITION Presidents Award of Merit The Florida Bar Presidents Award of Merit The Florida Bar Professionalism Award Palm Beach County Bar Association Outstanding Past Local Bar President Florida Council of Bar Presidents LAW-RELATED ARTICLES AND PU Bl/CATIONS The Pink Elephant in the Office Palm Beach County Bar Association Bulletin December pp Earned Fees to Be Shared Between Counsel-Operating Account or Trust Account Palm Beach County Bar Association Bulletin February The New Florida Bar Professionalism Expectations-What Now Palm Beach County Bar Association Bulletin January The Monster in the Closet Trust-Account Responsibility Palm Beach County Bar Association Bulletin February Unprofessional Versus Unethical Caution Slippery Road Ahead Palm Beach County Bar Association Bulletin February The Supreme Courts New Code for Resolving Professionalism Complaints Palm Beach County Bar Association Bulletin July August Motions to Withdraw Euphemystism on Parade Palm Beach County Bar Association Bulletin October2012,p Tribute to a Mentor Palm Beach County Bar Association Bulletin April Can You Hear Me Now And Who Else Is Listening Palm Beach County Bar Association Bulletin October Code of Pretrial and Trial Conduct Teaching Syllabus American College of Trial Lawyers Irvine co-author/contributor The Dance of the Lawyer Expert What Ethical Issues and When Palm Beach County Bar Association Bulletin September Through the Looking Glass When Is an Earned Retainer Earned Palm Beach County Bar Association Bulletin December Terminal One-Upmanship and Other Phenomena of the Lawyering Life Palm Beach County Bar Association Bulletin November Threatening Disciplinary Proceedings In the Mind of the Beholder Palm Beach County Bar Association Bulletin November Outsourcing Legal Work Smart Practice Management or Ethical Quagmire Palm Beach County Bar Association Bulletin April Culver Smith I CURRICULUM VITAE Lawyers Ancillary Businesses Palm Beach County Bar Association Bulletin March The Adversary System A Matter of Theology Palm Beach County Bar Association Bulletin December Investigators Gone Wild Who Pays the Tab in a Blame-the-Lawyers World Palm Beach County Bar Association Bulletin October pp Changes to the Rules of Professional Conduct Palm Beach County Bar Association Bulletin July-August pp Metadata What Are the Ethical Implications Palm Beach County Bar Association Bulletin June Chapter Theories of Liability Professional Liability of Lawyers in Florida 4th ed the Florida Bar Tallahassee also authored same chapter in earlier editions Business Transactions With a Client Are You a Lawyer or an Entrepreneur Palm Beach County Bar Association Bulletin May Identifying the Client The First Line of Defense Palm Beach County Bar Association Bulletin January pp Confidentiality and the Snitch Rule An Ethical Catch-22 Palm Beach County Bar Association Bulletin December Report of the Legal Ethics Committee of the American College of Trial Lawyers on Duties of Confidentiality American College ofTrial Lawyers Irvine CA co-author/contributor The Bar Looks at the Future The Florida Bar Journal vol no May LAW-RE LA TED SPEECHES AND PRESENTATIONS Professionalism Expectations and Contentious Cases at Palm Beach County Bar Association LLC Member Disputes seminar West Palm Beach June Professionalism at Palm Beach County Bar Association Modification of Parenting Plans Seven Practical Tips seminar West Palm Beach April Great Expectations Professionalism Expectations for Florida Lawyers at The Florida Bar Putting the Pro in Professionalism symposium West Palm Beach April panelist Expert Witnesses Part Permissible Lawyer-Expert Testimony-What Can You Get Into Evidence at Association of Professional Responsibility Lawyers meeting Chicago August moderator Expert Witnesses Part at Association of Professional Responsibility Lawyers meeting Houston February moderator Ethical Considerations Your License Is in Play at Palm Beach County Bar Association Spying Spouses Divorce in a World of Cyber Warfare and E-Everything seminar West Palm Beach November Culver Smith I CURRICULUM VITAE The Tangled Web of Ethics Advertising Websites Social Media at The Florida Bar Family Law Section webinar September panelist Lawyer Beware Ethical Issues With Lawyer-Referral and Legal Support Services at The Florida Bar Masters Seminar on Ethics Orlando June including written materials Panel Discussion on Professionalism at The Florida Bar Young Lawyers Division Practicing With Professionalism seminar West Palm Beach May panelist Ethics Workshop at American College ofTrial Lawyers Tri-State Meeting Sea Island February panelist The New Oath of Admission at Florida Association for Women Lawyers Palm Beach County Chapter luncheon West Palm Beach November panelist Lawyer Beware Ethical Issues With For-Profit Referral and Legal-Support Services at Palm Beach County Bar Association Solo Small Firm Practitioners luncheon West Palm Beach November Lawyer Ancillary Business What Hat Are You Wearing Today-Lawyer or Entrepreneur at Association of Professional Responsibility Lawyers meeting San Francisco August panelist The Bars Professional Disciplinary System at Lorman Educational Services Legal Ethics in Florida seminar West Palm Beach May including written materials Terminating Representation at Lorman Educational Services Legal Ethics in Florida seminar West Palm Beach May including written materials Conflicts of Interest at Lorman Educational Services Legal Ethics in Florida seminar West Palm Beach May including written materials Commercial Litigation at Palm Beach County Bar Association Bench-Bar Conference West Palm Beach February panelist Ripped From the Case Law Corporate Internal Investigations Multiple Representations and U.S Ruehle at American Bankruptcy Institute Caribbean Insolvency Symposium Boca Raton February panelist and counsel for Appel lee in mock oral argument Ethics and Professionalism The Rothstein Scandal Beyond at University of Miami School of Law Center for Ethics Public Service Ethics Professional Responsibility Program Leadership Luncheon Series Coral Gables January panelist Evidentiary Foundations and Objections at Palm Beach County Bar Association Judicial Luncheon Series luncheon West Palm Beach November moderator Panel Discussion on Professionalism at The Florida Bar Young Lawyers Division Practicing With Professionalism seminar West Palm Beach October panelist Tanned Rested and Ready-Now What The Practical Side of Expert-Witnessing at Association of Professional Responsibility Lawyers meeting Chicago July moderator/panelist Firm Counsel Project Roundtable at American Bar Association National Legal Malpractice Conference Miami April moderator Culver Smith I CURRICULUM VITAE Opening Remarks at The Florida Bar Young Lawyers Division Practicing With Professionalism seminar Deerfield Beach February Panel Discussion on Professionalism at The Florida Bar Young Lawyers Division Practicing With Professionalism seminar West Palm Beach October panelist Ethics and Professionalism How to Build Your Reputation Keep Your License at University of Miami School of Law Center for Ethics Public Service Ethics Professional Responsibility Program seminar Coral Gables September panelist Trial and Pretrial Conduct on Paper and in Practice A Cut Above the Ordinary at Tenth Circuit Bench Bar Conference Colorado Springs September panelist The Bars Professional Disciplinary System at Lorman Educational Services Legal Ethics in Florida seminar West Palm Beach June including written materials Terminating Representation at Lorman Educational Services Legal Ethics in Florida seminar West Palm Beach June including written materials Conflicts of Interest at Lorman Educational Services Legal Ethics in Florida seminar West Palm Beach June including written materials Fifteenth Judicial Circuit Judicial Campaign Conduct Forum West Palm Beach May panelist Leadership Through Service at Palm Beach County Bar Association Leadership Academy-The Art of Leadership program West Palm Beach April panelist Oh What Tangled Webs We Weave Conflicts of Interest in Trust Estate Practice at The Florida Bar Real Property Probate Trust Law Section Trust Estate Symposium Litigating Under Floridas New Trust Code Fort Lauderdale and Tampa February and including written materials Conflicts of Interest at Palm Beach County Bar Association Professionalism Luncheon Series luncheon West Palm Beach February including written materials Investigators and Lawyers Gone Wild The Ethical Ramifications of Pretexting and Undercover Investigations at American College ofTrial Lawyers Tri-State Meeting Sea Island February including written materials Investigators and Lawyers Gone Wild The Ramifications of Covert and Deceptive Tactics at National Association of Legal Investigators conference Fort Lauderdale January Dealing With Difficult Opposing Counsel at Palm Beach County Bar Association Mentoring Luncheon Series luncheon West Palm Beach December panelist Panel Discussion on Professionalism at The Florida Bar Young Lawyers Division Practicing With Professionalism seminar West Palm Beach FL November panelist Ethics Shrugged Supervising Outside Agents in a Blame-the-Lawyers World at The Florida Bar Masters Seminar on Ethics Orlando June including written materials Dealing With Difficult Clients at Palm Beach County Bar Association Mentoring Luncheon Series luncheon West Palm Beach FL May panelist Culver Smith I CURRICULUM VITAE You Cant Always Say What You Want Limits on Lawyer Speech Post-Fieger at Association of Professional Responsibility Lawyers meeting Miami Beach February moderator/panelist Achieving Success in the Practice of Law Lessons Learned in Thirty-Nine Years at the Bar at Palm Beach County Bar Association Young Lawyers Section Lunch With the Legends Series luncheon West Palm Beach November Ethical Concerns Regarding Attorneys Ancillary Businesses at The Florida Bar Masters Seminar on Ethics Boca Raton June including written materials Masters Seminar on Ethics Conflicts of Interest at American College of Trial Lawyers Current Developments in Civil Procedure Evidence and Legal Ethics seminar Hollywood April including written materials Conflicts of Interest at CLE International Ethics seminar Tampa February including written materials Update on the New Rules of Professional Conduct at Palm Beach County Bar Association 14th Annual Professionalism Seminar West Palm Beach April Final Arguments at National Institute for Trial Advocacy NITA American College ofTrial Lawyers and Florida Legal Services Inc Critical Trial Skills for Legal Services Attorneys seminar Deerfield Beach January faculty member Ethics the Unauthorized Practice of Law How Paralegals Are Affected at Paralegal Association of Florida 26th Annual Meeting Seminar West Palm Beach September Avoiding Legal Malpractice at Professional Education Systems Institute The Briar Patch Thorny Issues in Florida Civil Litigation seminar Dania August including written materials Avoiding Malpractice at Palm Beach County Bar Association Family Law seminar West Palm Beach December Ethical Challenges Facing Todays Attorney at Palm Beach County Bar Association 9th Annual Ethics and Professionalism Workshop and Seminar West Palm Beach May Applied Ethics at the Palm Beach County Bar Association North County Section Ethics Seminar and Luncheon North Palm Beach May Avoiding Malpractice Claims at Holland Knight LLP Solo and Small-Firm Practitioners Seminar West Palm Beach January Avoiding Malpractice Claims at Holland Knight LLP Solo and Small-Firm Practitioners Seminar West Palm Beach November Palm Beach County Bar Association A Study in Professionalism seminar West Palm Beach April panelist Ethics and Malpractice at Palm Beach County Bar Association 4th Annual Ethics Luncheon West Palm Beach June Making the Standards of Professionalism Work at Palm Beach County Bar Association 3rd Annual Ethics Luncheon West Palm Beach May Culver Smith I CURRICULUM VITAE Jury System-New Approaches at American Inns of Court chapter meeting West Palm Beach February panelist Professionalism in Litigation Practice Outside the Courtroom at Palm Beach County Bar Association 2nd Annual Ethics Luncheon West Palm Beach May Making the Standards Work at Palm Beach County Bar Association 1st Annual Ethics Luncheon West Palm Beach March Role and Responsibility of Lawyers at Nova Southeastern University School of Law orientation assembly Fort Lauderdale August Conversations on Professionalism at Rumger Professional Issues Forum Orlando January panelist Role and Responsibility of Lawyers at ceremony for newly admitted Florida lawyers West Palm Beach October Role and Responsibility of Lawyers at ceremony for newly admitted Florida lawyers West Palm Beach May The Bar and Its Works at West Palm Beach Rotary Club luncheon West Palm Beach May CIVIC AND CHARITABLE SERVICE Member Board of Directors Hanley Center Foundation Inc d/b/a Hanley Foundation Treasurer Member Board of Directors Education Foundation of Palm Beach County Inc President Chairperson Honorary Co-Chairperson 25th Anniversary Spirit of Youth Awards Dinner February Member State Board of Directors Childrens Home Society of Florida Inc Member Governance Committee Member Division Advisory Board South Coastal Division Childrens Home Society of Florida Inc Chairperson Bylaws Committee Co-Chairperson Fund Development Committee Member Board of Directors Nelle Smith Residence for Girls Inc President Member Roger Dean Stadium Advisory Board Chairperson Member Board of Directors Greater West Palm Beach Division Florida/Puerto Rico Affiliate American Heart Association Member Economic Council of Palm Beach County Inc Member Education Committee Member Executive Committee Member Task Force on the Florida Constitution Member Strategic Action Committee Culver Smith I CURRICULUM VITAE Co-Chairperson Steering Committee Principals Leadership Training Institute joint project of the School Board of Palm Beach County and the Education Foundation of Palm Beach County Member School Board of Palm Beach County Superintendent-Candidates Citizens Interview Committee Member School Board of Palm Beach County Strategic Planning Committee Member Palm Beach County Court Facilities Planning Committee Member Coordinating Committee Project Mosaic community-wide collaboration to develop strategies for achieving stable racial balance in Palm Beach Countys public schools Member Steering Committee Education Foundation of Palm Beach County Superintendent Qualifications Forum Member Palm Beach County Champions WorldClass Schools Chairperson Member Campaign Cabinet United Way of Palm Beach County Inc Member Board of Directors Zoological Society of the Palm Beaches Inc Member Board of Directors Legal Aid Society of Palm Beach County Member Board of Directors YMCA of the Palm Beaches Inc Member Society for American Baseball Research SABR Co-Chairperson Host Committee Annual Convention Sustaining member Friends of the Hall of Fame National Baseball Hall of Fame and Museum Inc 19-date Member Board of Directors El Cid/Prospect Park/Southland Park Homeowners Association Member Palm Beach Chapter Washington and Lee University Alumni Association Chairperson MISCELLANEOUS ARTICLES AND PU Bl/CATIONS The Inquisitor General Palm Beach Post February op-ed Sticklers Unite Abolish Capital Punishment Part Palm Beach County Bar Association Bulletin January regarding capitalization Sticklers Unite Abolish Capital Punishment Part Palm Beach County Bar Association Bulletin November regarding capitalization Sticklers Unite Abolish Capital Punishment Part Palm Beach County Bar Association Bulletin October regarding capitalization Sticklers Unite Save Only the Lonely Palm Beach County Bar Association Bulletin May Culver Smith I CURRICULUM VITAE Sticklers Unite Ban Verbing the Noun Palm Beach County Bar Association Bulletin January pp Sticklers Unite Stamp Out Semicolonitis Palm Beach County Bar Association Bulletin July-August Sticklers Unite Save the Apostrophe Palm Beach County Bar Association Bulletin May Sticklers Unite Stamp Out Death by Comma Palm Beach County Bar Association Bulletin March From McGillicuddy to McGwire Baseball in Florida and the Caribbean Society for American Baseball Research Cleveland editor From McGillicuddy to McGwire Spring Home to Record-Setters From McGillicuddy to McGwire Baseball in Florida and the Caribbean Society for American Baseball Research Cleveland pp All-Time Florida-Born Major League Baseball Team From McGillicuddy to McGwire Baseball in Florida and the Caribbean Society for American Baseball Research Cleveland pp MISCELLANEOUS SPEECHES AND PRESENTATIONS Public Education The Lifeblood of Democracy given at Education Foundation of Palm Beach County Spirit of Youth Awards dinner West Palm Beach January Citizenship and the Search for Justice given at Daughters of the American Revolution Constitution Week luncheon Palm Beach September The Future of Public Education given at Sun-Sentinel The Palm Beach County Faces the Future forum Lake Worth May PERSONAL Born and reared in West Palm Beach Florida fourth-generation resident Married to Dr Donna Marks two children two grandchildren three stepchildren and three step-grandchildren Hobbies and interests Baseball-past present and future Piano Lexicology syntax and writing style EXHIBIT EXHIBIT Filing E-Filed AM JEFFREY EPSTEIN Plaintiff/Counter-Defendant SCOTT ROTHSTEIN individually and BRADLEY EDWARDS individually Defendants/Counter-Plaintiff IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Case No PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEINS NOTICE OF PROPOSED JURY INSTRUCTIONS AND VERDICT FORM Plaintiff/Counter-Defendant Jeffrey Epstein Epstein pursuant to Florida Rule of Civil Procedure files this Notice of Proposed Jury Instructions and Verdict Form Epstein adopts Defendant/Counter-Plaintiff Bradley Edwards Edwards November proposed Standard Civil Jury Instructions Nos and which Epstein has not restated here Epstein objects to Edwards November proposed Jury Instructions Nos and Adverse Inference and Edwards November and December Supplemental Instructions Epstein has provided alternative and additional instructions for the Courts consideration CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on December through the Courts e-filing portal pursuant to Florida Rule of Judicial Administration Jack Scarola LINK ROCKENBACH PA Palm Beach Lakes Boulevard Suite West Palm Beach Florida fax By Isl Scott Link Scott Link FBN Kara Berard Rockenbach FBN Angela Many FBN 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 SERVICE LIST Nichole Segal Searcy Denny Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard Burlington Rockenbach P.A Courthouse Commons Suite West Railroad A venue West Palm Beach FL mep searcylaw.com jsx searcylaw.com scarolateam searcylaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards West Palm Beach FL njs FLAppellateLaw.com kbt FLAppellateLaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Bradley Edwards Marc Nurik Edwards Pottinger LLC Law Offices of Marc Nurik Andrews Avenue Suite One Broward Boulevard Suite Fort Lauderdale FL Ft Lauderdale FL brad epllc.com marc nuriklaw.com staff.efile pathtojustice.com Counsel for Defendant Scott Rothstein Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Jack A Goldberger Atterbury Goldberger Weiss P.A Australian A venue Suite West Palm Beach FL goldberger agwpa.com smahoney agwpa.com Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Oath of Jurors Before Voir Dire Do you solemnly swear or affirm that you will answer truthfully all questions asked of you as prospective jurors so help you God Source Florida Standard Jury Instruction Civil Given Given as Modified Denied Withdrawn PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Qualifications Instruction Before Voir Dire Many of you have electronic devices such as cell phones smartphones tablets and laptops Even though you have not yet been selected as a juror there are some strict rules that you must follow about electronic devices When you are called to a courtroom the judge will give you specific instructions on the use of electronic devices These rules are so important that the judge may tell you that you must turn off your cell phone or other electronic devices completely or that you cannot have your cell phone or electronic devices in the courtroom If someone needs to contact you in case of an emergency the judge will provide you with a phone number where you can receive messages If the trial judge allows you to keep your cell phones computers or other electronic devices you cannot use them to take photographs video recordings or audio recordings of the proceedings in the courtroom or your fellow jurors You must not use them to search the Internet or to find out anything related to any cases in the courthouse Why is this restriction imposed This restriction is imposed because jurors must decide the case without distraction and only on the evidence presented in the courtroom I know that for some of you these restrictions affect your normal daily activities and may require a change in the way you are used to communicating and perhaps even in the way you are used to learning If you investigate research or make inquiries on your own the trial judge has no way to make sure that the information you obtain is proper for the case The parties likewise have no opportunity to dispute or challenge the accuracy of what you find Any independent investigation by a juror unfairly and improperly prevents the parties from having that opportunity our judicial system promises Between now and when you have been discharged from jury duty by the judge you must not discuss any information about your jury service with anyone including friends co-workers and family members You may tell those who need to know where you are that you have been called for jury duty If you are picked for a jury you may tell people that you have been picked for a jury and how long the case may take However you must not give anyone any information about the case itself or the people involved in the case You must also warn people not to try to say anything to you or write to you about your jury service or the case This includes face-to-face phone or computer communications I want to stress that you must not use electronic devices or computers to talk about this case including tweeting texting blogging e-mailing posting information on a website or chat room or any other means at all Do not send or accept any messages including e-mail and text messages about your jury service You must not disclose your thoughts about your jury service or ask for advice on how to decide any case The judge will tell you when you are released from this instruction Remember these rules are designed to guarantee a fair trial It is important that you understand the rules as well as the impact on our system of justice if you fail to follow them If it is determined that any one of you has violated this rule and conducted any type of independent research or investigation it may result in a mistrial A mistrial would require the case to be tried again at great expense to the parties and the judicial system The judge may also impose a penalty upon any juror who violates this instruction All of us are depending on you to follow these rules so that there will be a fair and lawful resolution of every case Source Florida Standard Jury Instruction Civil not numbered Given Given as Modified Denied Withdrawn PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Description of the Case Before Voir Dire Welcome I The clerk will now administer your oath Now that you have been sworn Id like to give you an idea about what we are here to do This is a civil trial A civil trial is different from a criminal case where a defendant is charged by the state prosecutor with committing a crime The subject of a civil trial is a disagreement between people or companies where the claims of one or more of these parties have been brought to court to be resolved It is called a trial of a lawsuit This case has two components First Plaintiff Jeffrey Epstein has a claim against Defendant Scott Rothstein for utilizing three cases that Rothstein firm had against Epstein to fabricate other claims and continue the operation of a Ponzi scheme Second about whether Plaintiff Jeffrey Epstein had probable cause to initiate and continue a civil proceeding against Defendant Bradley Edwards alleging that Edwards knew or should have known about Rothstein Ponzi scheme Bradley Edwards is an attorney In August and September while he was a sole practitioner Edwards filed three claims against Epstein for alleged sexual misconduct In late March Edwards joined the law firm of Rothstein Rosenfeldt and Adler RRA At the time he joined RRA Edwards held the title of partner and he turned over to Scott Rothstein the three clients who had brought claims against Epstein RRA continued to pursue these clients claims until the firm imploded in November It was publicly disclosed in early November that Rothstein the senior partner of RRA had conducted a fraudulent Ponzi scheme which in part had used the fact that sexual abuse claims against Epstein were being prosecuted by RRA to induce investors to buy interests in fictitious non-existent settlements of sexual abuse claims against Epstein Rothstein scheme raised hundreds of millions of dollars and was one of the largest frauds in U.S history In early December Epstein through his attorneys filed a lawsuit against Edwards Rothstein and one of Edwards clients Epstein alleged that while Edwards was a partner at RRA in the cases Edwards brought against Epstein when Edwards was a sole practitioner in were being used in to pursue issues and evidence unrelated to and unnecessary to the claims pled in those cases and instead were done to benefit and lure investors into Rothstein Ponzi scheme Edwards countersued Epstein for malicious prosecution Edwards contends that Epstein filed the lawsuit for the sole purpose of attempting to intimidate him into abandoning or cheaply compromising his clients claims Epstein eventually settled the cases with Edwards three clients A default was entered against Rothstein because he failed to respond to Epstein Complaint Epstein voluntarily withdrew his claims against Edwards client in August Epstein dismissed his claims against Edwards in August without prejudice to his right to reassert them at a later time The only claim pending is Edwards claim against Epstein for malicious prosecution The principal witnesses who may testify in this case are Jeffrey Epstein via video deposition Bradley Edwards Scott Rothstein via video deposition and Mr Edwards clients L.M E.W and Jane Doe Source Florida Standard Jury Instruction Civil Given Given as Modified Denied Withdrawn PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Introduction of Participants and Their Roles Who are the people here and what do they do Judge/Court I am the Judge You may hear people occasionally refer to me as The Court That is the formal name for my role My job is to maintain order and decide how to apply the rules of the law to the trial I will also explain various rules to you that you will need to know in order to do your job as the jury It is my job to remain neutral on the issues of this lawsuit Parties A party who files a lawsuit is called the Plaintiff A party that is sued is called the Defendant Attorneys The attorneys have the job of representing their clients That means they speak for their client here at the trial They have taken oaths as attorneys to do their best and to follow the rules for their profession Plaintiff/Counter-Defendants Counsel The attorney on this side of the courtroom Scott Link represents Jeffrey Epstein who is the person who filed the initial proceeding here at the courthouse His job is to present his clients side of things to you He and his client will be referred to most of the time as the Plaintiff or the Counter-Defendant Mr Link will you please introduce who is sitting at the table with you Defendant/Counter-Plaintiffs Counsel The attorney on this side of the courtroom Jack Scarola represents Bradley Edwards one of the defendants who has been sued and who brought a counterclaim against Mr Epstein His job is to present his clients side of things to you He and his client will usually be referred to here as the Defendant or the Counter-Plaintiff Mr Scarola will you please introduce who is sitting at the table with you Court Clerk This person sitting in front of me name is the court clerk He She is here to assist me with some of the mechanics of the trial process including the numbering and collection of the exhibits that are introduced in the course of the trial Court Reporter The person sitting at the stenographic machine name is the court reporter His Her job is to keep an accurate legal record of everything we say and do during this trial Bailiff The person over there name is the bailiff His Her job is to maintain order and security in the courtroom The bailiff is also my representative to the jury Anything you need or any problems that come up for you during the course of the trial should be brought to him her However the bailiff cannot answer any of your questions about the case Only I can do that Jury Last but not least is the jury which we will begin to select in a few moments from among all of you The jurys job will be to decide what the facts are and what the facts mean Jurors should be as neutral as possible at this point and have no fixed opinion about the lawsuit In order to have a fair and lawful trial there are rules that all jurors must follow A basic rule is that jurors must decide the case only on the evidence presented in the courtroom You must not communicate with anyone including friends and family members about this case the people and places involved or your jury service You must not disclose your thoughts about this case or ask for advice on how to decide this case I want to stress that this rule means you must not use electronic devices or computers to communicate about this case including tweeting texting blogging e-mailing posting information on a website or chat room or any other means at all Do not send or accept any messages to or from anyone about this case or your jury service You must not do any research or look up words names maps or anything else that may have anything to do with this case This includes reading newspapers watching television or using a computer cell phone the Internet any electronic device or any other means at all to get information related to this case or the people and places involved in this case This applies whether you are in the courthouse at home or anywhere else Many of you may have cell phones tablets laptops or other electronic devices with you here in the courtroom The trial judge should select one of the following two alternative instructions explaining the rules governing jurors use of electronic devices as explained in Note on Use Alternative A All cell phones computers tablets or other types of electronic devices must be turned off while you are in the courtroom Turned off means that the phone or other electronic device is actually off and not in a silent or vibrating mode You may use these devices during recesses but even then you may not use your cell phone or electronic device to find out any information about the case or communicate with anyone about the case or the people involved in the case Do not take photographs video recordings or audio recordings of the proceedings or of your fellow jurors After each recess please double check to make sure your cell phone or electronic device is turned off At the end of the case while you are deliberating you must not communicate with anyone outside the jury room You cannot have in the jury room any cell phones computers or other electronic devices If someone needs to contact you in an emergency the court can receive messages and deliver them to you without delay A contact phone number will be provided to you Alternative You cannot have any cell phones tablets laptops or other electronic devices in the courtroom You may use these devices during recesses but even then you may not use your cell phone or electronic device to find out any information about the case or communicate with anyone about the case or the people involved in the case Do not take photographs video recordings or audio recordings of the proceedings or your fellow jurors At the end of the case while you are deliberating you must not communicate with anyone outside the jury room If someone needs to contact you in an emergency the court can receive messages and deliver them to you without delay A contact phone number will be provided to you What are the reasons for these rules These rules are imposed because jurors must decide the case without distraction and only on the evidence presented in the courtroom If you investigate research or make inquiries on your own outside of the courtroom the trial judge has no way to make sure that the information you obtain is proper for the case The parties likewise have no opportunity to dispute or challenge the accuracy of what you find That is contrary to our judicial system which assures every party the right to ask questions about and challenge the evidence being considered against it and to present argument with respect to that evidence Any independent investigation by a juror unfairly and improperly prevents the parties from having that opportunity our judicial system promises Any juror who violates these restrictions jeopardizes the fairness of these proceedings and a mistrial could result that would require the entire trial process to start over A mistrial is a tremendous expense and inconvenience to the parties the court and the taxpayers If you violate these rules you may be held in contempt of court and face sanctions such as serving time in jail paying a fine or both All of your communications with courtroom personnel or me will be part of the record of these proceedings That means those communications shall either be made in open court with the court reporter present or if they are in writing the writing will be filed with the court clerk I have instructed the courtroom personnel that any communications you have with them outside of my presence must be reported to me and I will tell the parties and their attorneys about any communication from you that I believe may be of interest to the parties and their attorneys However you may communicate directly with courtroom personnel about matters concerning your comfort and safety such as juror parking location of break areas how and when to assemble for duty how you should dress what personal items can be brought into the courthouse or jury room and similar inquiries If you become aware of any violation of these instructions or any other instruction I give in this case you must tell me by giving a note to the bailiff Source Florida Standard Jury Instruction Civil Given Given as Modified Denied Withdrawn PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Explanation of the Voir Dire Process Epstein hereby adopts and incorporates Edwards Standard Jury Instruction PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Oath of Juror After Voir Dire Do you solemnly swear or affirm that you will well and truly try this case between the Plaintiff/Counter-Defendant Jeffrey Epstein and the Defendant/Counter-Plaintiff Bradley Edwards and a true verdict render according to the law and evidence so help you God Source Florida Standard Jury Instruction Civil Given Given as Modified Denied Withdrawn PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Explanation of the Trial Procedure Epstein hereby adopts and incorporates Edwards Standard Jury Instruction PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Note-Taking by Jurors Epstein hereby adopts and incorporates Edwards Standard Jury Instruction PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Juror Questions Epstein hereby adopts and incorporates Edwards Standard Jury Instruction PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Deposition Testimony Interrogatories Stipulated Testimony Stipulations and Admissions Epstein hereby adopts and incorporates Edwards Standard Jury Instruction By agreeing to the instruction Epstein does not waive the argument that some of the items should not be permitted to be used in this case Epstein agrees to the instruction so that in the event that either the parties agree or the Court rules that these types of items will be used the relevant instruction should proceed the item PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Instruction When First Item of Documentary Photographic or Physical Evidence is Admitted Epstein hereby adopts and incorporates Edwards Standard Jury Instruction PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Instruction When Evidence is First Published to Jurors Epstein hereby adopts and incorporates Edwards Standard Jury Instruction PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Instruction Regarding Visual or Demonstrative Aids Epstein hereby adopts and incorporates Edwards Standard Jury Instruction Epstein does not waive any objections to any particular demonstrative or visual aids by adopting the proposed instruction but includes the instruction in case the Court decides or the parties agree to permit any such items PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Evidence Admitted for a Limited Purpose Epstein hereby adopts and incorporates Edwards Standard Jury Instruction PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Instruction Before Recess We are about to take our first a recess Remember that all of the rules I have given you apply even when you are outside the courtroom such as at recess Remember the basic rule Do not talk to anyone including your fellow jurors friends family or co-workers about anything having to do with this trial except to speak to court staff This means no e-mailing text messaging tweeting blogging or any other form of communication You cannot do any research about the case or look up any information about the case Remember to observe during our recess the other rules I gave you If you become aware of any violation of any of these rules at all notify court personnel of the violation After each recess please double check to make sure that your cell phone or other electronic device is turned off completely that you do not bring your cell phone or other electronic device into the courtroom or jury room Source Florida Standard Jury Instruction Civil Given Given as Modified Denied Withdrawn PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Introduction Epstein hereby adopts and incorporates Edwards Standard Jury Instruction PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Summary of Claims The claims and defenses in this case are as follows Plaintiff Jeffrey Epstein claims that Defendant Scott Rothstein conspired with other lawyers and employees at the firm of Rothstein Rosenfeld and Adler for personal greed and enrichment and engaged in a pattern of racketeering that involved among other things marketing of non-existent settlements involving claims both real and fabricated against Epstein and engaging in improper litigation tactics in order to promote and sustain that Ponzi scheme Epstein brought claims for violations of Floridas Civil Remedies for Criminal Practices Act violations of Floridas Racketeer Influenced and Corrupt Organization RICO abuse of process fraud and conspiracy to commit fraud Rothstein did not defend those claims and consequently a default was entered against him A default is not an actual determination of the merits of the claim Instead it is a legal ruling that because the defendant did not contest the claim the defendant will be deemed to have committed the offense Consequently the sole issue for your determination on Epsteins claim against Rothstein is the amount of damages that should be awarded to Epstein against Rothstein for the harm that Rothstein caused to Epstein Epstein must prove the amount of damages he suffered by Rothstein actions by the greater weight of the evidence Plaintiff Jeffrey Epstein through his attorneys also filed claims called the civil proceeding against Defendant Bradley Edwards Epstein voluntarily dismissed his claims against Edwards before the claims were decided by the Court Epstein dismissal of the claims against Edwards was without prejudice to Epstein right to later reassert them Therefore those claims are not before you for your determination Edwards filed a Counterclaim for malicious prosecution against Epstein which alleged that Epstein maliciously and without probable cause filed and continued the civil proceeding against him and that this caused Edwards damage Epstein denies that claim and also asserts that he is entitled to a verdict in his favor Edwards must prove by the greater weight of the evidence that Epstein caused to be filed or continued the civil proceeding against Edwards maliciously and without probable cause and that Epstein lawsuit caused Edwards to suffer damage I will now define some of the terms you will use in deciding this case Source Florida Standard Jury Instruction Civil Fla Civ DG Sports Agency LLC First Round Mgmt LLC So 3d Fla th DCA effect of default Donohue Brightman So 2d Fla th DCA effect of default Clerks Default on January D.E Given Given as Modified Denied Withdrawn PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Greater Weight of the Evidence Epstein hereby adopts and incorporates Edwards Standard Jury Instruction PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Claim Against Rothstein Damages You must consider whether or not to award damages in favor of Jeffrey Epstein against Scott Rothstein for the claims that Jeffrey Epstein has raised against Scott Rothstein You should award Jeffrey Epstein an amount of money that the greater weight of the evidence shows will fairly and adequately compensate him for his loss injury or damage including any damage If you find that Jeffrey Epstein has not proven any loss or damage you may still award Jeffrey Epstein nominal damages such as one dollar Source Abuse of Process Valdes GAB Robins Am Inc So 2d Fla 3d DCA I Investments Payless Flea Market Inc So 3d Fla 4th DCA Nominal damages are sufficient to recover on an action for abuse of process See Stoler Levinson So 2d Fla 3d DCA North Star Capital Acquisitions LLC Krig Supp 2d M.D Fla Florida Standard Jury Instruction Contracts and Business Fraud Prieto Smoak Inc So 3d Fla th DCA See also Sena Pereira So 3d Fla th DCA Conspiracy Eagletech Communications Inc Bryn Mawr Inv Group Inc So 3d Fla th DCA quoting Raimi Furlong So 2d Fla 3d DCA Florida Civil Remedies for Criminal Acts Fla Stat Fla Stat Fla Stat Given Given as Modified Denied Withdrawn PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Issues on Claim I will now instruct you on what Edwards must prove to prevail on his claim for malicious prosecution against Epstein The issues you must decide on Edwards claim against Epstein are whether Epstein maliciously and without probable cause instituted or continued a civil proceeding against Edwards which later terminated in favor of Edwards and if so whether that action was a legal cause of damage to Edwards Edwards must prove each of these elements in order to prevail on his claim for malicious prosecution against Epstein I will now instruct you further on the individual elements of this claim Source Second Paragraph Florida Standard Jury Instruction This paragraph reflects the Standard Instruction but the order of the instructions has been changed to instruct the jury on the elements first then explain the elements to the jury It is Epsteins position this will allow the jury to better understand why they are being instructed on probable cause malice etc Alamo Rent-A-Car Inc Mancusi So 2d Fla Rivernider Meyer So 3d Fla th DCA Hickman Barclays Int Realty Inc So 3d Fla th DCA Third Paragraph Tatum Bros Real Estate Investment Co Watson So Fla Union Oil of Cal Amsco Division Watson So 2d Fla rd DCA Alamo Rent-A-Car Inc Mancusi So 2d Fla Given Given as Modified Denied Withdrawn PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Probable Cause Probable cause means that at the time of instituting and then continuing a civil proceeding against another the facts and circumstances known to Jeffrey Epstein were sufficiently strong to support a reasonable belief that the proceeding against Bradley Edwards was supported by existing facts It is Bradley Edwards burden to prove that Jeffrey Epstein lacked probable cause at every stage of the civil proceeding against Bradley Edwards from the filing of his suit to the termination of it You may find that Bradley Edwards failed to show a lack of probable cause even if some of the allegations in the civil proceeding brought by Jeffrey Epstein were ultimately shown to be untrue or if some of the claims would not have been successful The information that Jeffrey Epstein relied on does not have to be information gained first hand by Jeffrey Epstein but can be trustworthy information that was provided to Jeffrey Epstein You may find probable cause existed even if there was no certainty of the outcome of the proceeding You cannot base your finding as to probable cause on whether or not you believe that Bradley Edwards has proven that Jeffrey Epstein acted with malice Likewise you cannot base your findings as to whether there was a lack of probable cause on evidence that Jeffrey Epstein terminated his civil proceeding against Bradley Edwards Source First Paragraph Florida Standard Jury Instruction Civil Second Paragraph Endacott Int Hosp Inc So 2d Fla 3d DCA must show lack of probable cause for entire case or claim fails May Fundament So 2d Fla th DCA same Moity Bodin So 2d La Ct App where did not show lack of probable cause for at least several of allegations then no malicious prosecution Third Paragraph Gill Kostroff Supp 2d M.D Fla does not have to be first-hand information Endacott International Hospitality Inc So 2d Fla 3d DCA the defendants need not be certain of the outcome of the underlying proceeding to have probable cause for bringing the counterclaim Fourth Paragraph Tatum Bros Real Estate Investment Watson So Fla cannot infer probable cause based on finding of malice Central Florida Machinery Co Inc Williams So 2d Fla 2d DCA a bare showing of malice will not in turn permit an inference of a lack of probable cause Applestein Preston So 2d Fla 3d DCA when want of probable cause was not established the existence thereof could not be inferred from malice if malice was proved Although malice may be inferred from want of probable cause want of probable cause cannot be inferred from malice Endacott Int Hosp Inc So 2d Fla 3d DCA However termination of an underlying civil proceeding in favor of the present plaintiff is not sufficient evidence that the defendants lacked probable cause Given Given as Modified Denied Withdrawn PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Malice One acts maliciously in instituting or continuing a civil proceeding against another if he or she does so for the primary purpose of injuring the other or recklessly and without regard for whether the proceeding is justified or for any primary purpose except to bring an offender to justice or to establish what he or she considers to be a meritorious claim In determining whether Jeffrey Epstein acted maliciously you may consider all the circumstances at the time of the conduct complained of including any lack of probable cause to institute or continue the proceeding You are not required however to find malice because of a lack of probable cause to institute or continue the proceedings and you should not draw an inference of malice from a lack of probable cause if other evidence of the circumstances at the time of the conduct lead to a different conclusion Source First Paragraph Florida Standard Jury Instruction Second Paragraph Colonial Stores Inc Scarbrough So 2d Fla It is recognized that malice may be inferred from the absence of probable cause Adams Whitfield So 2d Fla Duval Jewelry Co Smith Fla So Fla However malice is not legally synonymous with the absence of probable cause White Miami Home Milk Producers Association Fla So The inference of malice from the absence of probable cause is not one oflaw but merely a presumption of fact which may be rebutted This is an inference which the jury is not required to draw and which it should not draw if other facts disclosed by the evidence lead to a different conclusion See Tatum Brothers Real Estate Investment Co Watson Fla So Given Given as Modified Denied Withdrawn PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Instituting or Continuing a Proceeding Epstein hereby adopts and incorporates Edwards Standard Jury Instruction PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Legal Cause Epstein hereby adopts and incorporates Edwards Standard Jury Instruction PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Bona Fide Termination Bradley Edwards must prove that the termination of Jeffrey Epsteins civil proceeding against him was a bona fide termination in favor of Bradley Edwards A termination of a civil proceeding is a bona fide termination of the civil proceeding only if it ended in a manner that demonstrated that the proceeding lacked merit You must consider the reasons for the voluntary dismissal by Jeffrey Epstein of his claims against Bradley Edwards as well as all of the circumstances surrounding the voluntary dismissal of those claims in making this determination Source Giving an instruction Florida Standard Jury Instructions Civil Notes on Use If a fact question exists concerning whether the prior proceeding terminated in favor of the claimant an additional instruction on that issue will be necessary See Shidlowsky National Car Rental Systems Inc So 2d Fla 3d DCA Freedman Crabro Motors Inc So 2d Fla 3d DCA First Paragraph Debrincat Fischer So 2d Fla element of malicious prosecution claim CA Hansen Corp Wicker Smith et al So 2d Fla 3d DCA plaintiff must show either a favorable decision on the merits or a bona fide termination Alamo Rent-A-Car Inc Mancusi So 2d Fla Second Paragraph Sharaka A Inc So 3d Fla 2d DCA citing Cohen Corwin So 2d Fla th DCA Third Paragraph Cohen Corwin So 2d Fla th DCA whether a voluntary dismissal qualifies as a bona fide termination of the proceedings in the defendants favor depends upon the reasons and circumstances underlying the dismissal Doss Bank of America N.A So 2d Fla th DCA whether a withdrawal or abandonment of a lawsuit constitutes a bona fide termination in favor of a person against whom the suit was brought depends on the total circumstances surrounding the withdrawal or abandonment Given Given as Modified Denied Withdrawn PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Burden of Proof on Claim Epstein hereby adopts and incorporates Edwards Standard Jury Instruction PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Malicious Prosecution Damages If you find for Jeffrey Epstein you will not consider the matter of damages But if you find for Bradley Edwards you should award Bradley Edwards an amount of money that the greater weight of the evidence shows will fairly and adequately compensate Bradley Edwards for such damage as the greater weight of the evidence shows was caused by the institution or continuation of the proceeding complained of Source Florida Standard Jury Instructions Civil Given Given as Modified Denied Withdrawn PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Weighing the Evidence Epstein hereby adopts and incorporates Edwards Standard Jury Instruction PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Believability of Witnesses Epstein hereby adopts and incorporates Edwards Standard Jury Instruction Epstein does not waive any argument that Edwards should not be permitted to present any expert testimony by inclusion of this jury instruction but includes it in the event the Court overrules Epsteins objections PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Multiple Claims Numerous Parties Consolidated Cases In your deliberations you will consider and decide several distinct claims including claims by Jeffrey Epstein against Scott Rothstein and one claim by Bradley Edwards against Jeffrey Epstein Although these claims have been tried together each is separate from the others and each party is entitled to have you separately consider each claim as it affects that party Therefore in your deliberations you should consider the evidence as it relates to each claim separately as you would had each claim been tried before you separately Source Florida Standard Jury Instruction Civil Given Given as Modified Denied Withdrawn PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Concluding Instruction Before Final Argument Epstein hereby adopts and incorporates Edwards Standard Jury Instruction PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO Closing Instructions Epstein hereby adopts and incorporates Edwards Standard Jury Instruction PLAINTIFF/COUNTER-DEFENDANTS PROPOSED JURY INSTRUCTION NO BIFURCATED ISSUE PUNITIVE DAMAGES There is an additional claim in this case that you must decide If you find for Bradley Edwards and against Jeffrey Epstein you must decide whether in addition to compensatory damages punitive damages are warranted as punishment to Jeffrey Epstein and as a deterrent to others Bradley Edwards claims that punitive damages should be awarded against Jeffrey Epstein for his conduct in maliciously prosecuting a civil proceeding against Bradley Edwards Punitive damages are warranted against Jeffrey Epstein if you find by clear and convincing evidence that Jeffrey Epstein was guilty of intentional misconduct or gross negligence which was a substantial cause of damage to Bradley Edwards Under those circumstances you may in your discretion award punitive damages against Jeffrey Epstein If clear and convincing evidence does not show such conduct by Jeffrey Epstein punitive damages are not warranted against Jeffrey Epstein Intentional misconduct means that Jeffrey Epstein had actual knowledge of the wrongfulness of the conduct and that there was a high probability that injury or damage to Bradley Edwards and despite that knowledge he intentionally pursued that course of conduct resulting in injury or damage Gross negligence means that Jeffrey Epsteins conduct was so reckless or wanting in care that it constituted a conscious disregard or indifference to the life safety or rights of persons exposed to such conduct Clear and convincing evidence differs from the greater weight of the evidence in that it is more compelling and persuasive As I have already instructed you greater weight of the evidence means the more persuasive and convincing force and effect of the entire evidence in the case If you decide that punitive damages are warranted against Jeffrey Epstein then we will have a separate proceeding in which to decide the amount of punitive damages if any to be assessed as punishment against Jeffrey Epstein and as a deterrent to others This amount would be in addition to the compensatory damages you have previously awarded In making this determination you should consider the following the nature extent and degree of misconduct and the related circumstances including the following A whether the wrongful conduct was motivated solely by unreasonable financial gam whether the unreasonably dangerous nature of the conduct together with the high likelihood of injury resulting from the conduct was actually known by Jeffrey Epstein Punitive damages have been bifurcated from the main trial so that this instruction should not be given unless it becomes appropriate whether at the time of damage Jeffrey Epstein had a specific intent to harm Bradley Edwards and the conduct of Jeffrey Epstein did in fact harm Bradley Edwards and the financial resources of Jeffrey Epstein and However you may not award an amount that would financially destroy Jeffrey Epstein You may in your discretion decline to assess punitive damages Source Florida Standard Jury Instruction Civil Given Given as Modified Denied Withdrawn JEFFREY EPSTEIN Plaintiff/Counter-Defendant SCOTT ROTHSTEIN individually and BRADLEY EDWARDS individually Defendants/Counter-Plaintiff IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Case No VERDICT FORM We the Jury find A Epsteins Claims Against Rothstein On Jeffrey Epsteins claims against Scott Rothstein what amount of damages did Jeffrey Epstein prove by the greater weight of the evidence that he suffered Edwards Counterclaim Against Epstein Did Bradley Edwards prove that an original civil proceeding was caused to be commenced or continued against him by Jeffrey Epstein YES NO If the Answer to Question is YES then proceed to Question If the Answer to Question is NO then please date and sign the verdict form and proceed no further Did Bradley Edwards prove that Jeffrey Epstein was the legal cause of the original civil proceeding against Bradley Edwards YES NO If the Answer to Question is YES then proceed to Question If the Answer to Question is NO then please date and sign the verdict form and proceed no further Did the termination of Jeffrey Epsteins original civil proceeding constitute a bona fide termination of that proceeding in favor of Bradley Edwards YES NO If the Answer to Question is YES then proceed to Question If the Answer to Question is NO then please date and sign the verdict form and proceed no further Did Bradley Edwards prove by the greater weight of the evidence that there was no probable cause for Jeffrey Epstein to initiate or continue his original civil proceeding against Bradley Edwards YES NO If the Answer to Question is YES then proceed to Question If the Answer to Question is NO then please date and sign the verdict form and proceed no further Did Edwards prove by the greater weight of the evidence that Epstein instituted or continued his original civil proceeding against Edwards maliciously YES NO If the Answer to Question is YES then proceed to Question If the Answer to Question is NO then please date and sign the verdict form and proceed no further Did Edwards prove by the greater weight of the evidence that Epsteins institution or continuation of his original civil proceeding against Edwards caused damage to Edwards YES NO If the Answer to Question is YES proceed to Question If the Answer to Question is NO then please date and sign the verdict form and proceed no further What amount of damage if any did Edwards prove by the greater weight of the evidence that he suffered as a result of Epsteins institution or continuation of his original civil proceeding against Edwards Did Edwards prove that punitive damages are warranted as punishment to Epstein for instituting or continuing his original civil proceeding against Edwards and as a deterrent to others from filing a civil proceeding without probable cause YES NO YOU HAVE REACHED YOUR VERDICT PLEASE SIGN AND DATE THIS VERDICT FORM SO SAY WE ALL this day of FOREPERSON A A 4A E0 A4 DE a qr?q rq qrCX HhL Kg lg d?a d6U a M3 flW y??S m/y t0 I F/Z V/j 1a qC KS u?v vZ O5 a qr rCX qC 0V I I dc rM?M rM 10Cy n??m?n k?o?h I A I w?!ac qr MCX 10Cy ITy qr M3 Ґ??1rA5R h?H?T3P K?z X?K H?o I Idc rM?M rM 10Cy f헊?f?Tz e?e:Aa I v"x i X5 EO5 5a r?q CX 9r Cy rq rqC M3 ş?:c p/p0 5H V)V 6T Y2 G5 qrM?r?qr?r9 q?10Cy rCX qr l1 X?l 3K fm?Q Z2f CX CX gT L??T 2E Cy 3P EM3 J4T L?h??M q?ᡚ?Y r??O?rJt CTX i P!e i I CTX rC YY I 1e 2j CTX X0T1i k3v Jh/e0h1 H(K W/Q0 CTX j?!k 5B r2 CTX A A A 4v z"p A A A0A?A AK CTX A A?!k CX qCX YCX i!d A fi8 l8 yuZ 6L pH m?c sP;0 6ZR Ni P0 0Q X(P0s s(s p0 Pp CTX qq dR B/J Va A y!k N?M??N rC f?Nla3 Yz N?q qr NEeD K?i N?M?qr EeD k??O d6 I I i i CTX GH FT I CTX U3 U3 U3 U3 S6 E"L I I I5K7C:I 9O U3 Cn qrr qr q??r?q 9qr CTX G5 qr CX rC l0 WS zN pf1 ODV8L?m jC1DxV CTX CTX A qr 10Cy rYY Ң??P?V CTX C"C rqM?rq?q?qr qr CTX YY Jb?C.y CTX CTX GG4 A A G5 C.C M??r 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