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Court Records as described by folder names.
Epstein Release Interview Victim Statements Evidence Maxwell
← Back to Epstein v. Rothstein, No. 50-2009-CA-040800-XXXX-MB (Fla. 15th Cir. Ct. 2009)
Extracted Text

On or before December Edwards shall produce to Epstein all trial exhibits that have not been previously produced in the form to be introduced at trial with the exception of Exhibit No which is addressed separately in paragraph below Tr On or before January Edwards shall produce to Epstein the specific court filings to be used as trial exhibits from the Crime Victims Rights Act proceeding Jane Does and United States of America U.S District Court Southern District of Florida Case No 80736-Civ-Marra/Johnson designated as Edwards Trial Exhibit No Edwards shall not produce each and every item identified on the Courts docket but shall cull out the specific items he intends to use at trial The Court hereby sustains Epsteins objection to Exhibit No as being overbroad The Court will revisit this ruling if Edwards narrows the documents he intends to introduce at trial Tr As set forth in more detail below the Court has sustained Epsteins objections to a number of Edwards trial exhibits Those objections will be sustained unless there is a showing at trial that the exhibits are relevant and material to the issues to be determined For example exhibits may be admissible if they relate to Edwards three clients L.M E.W and Jane Doe if they relate to issues concerning Edwards preparation and evaluation of his clients cases or for any other reason enunciated by the Court on the record at the November and December hearings In those instances Edwards will be allowed to speak generically about the facts surrounding those exhibits but will not necessarily be allowed to introduce the exhibits at trial without further Order of the Court The Court will make decisions on an item-by-item basis at the appropriate time Any discussions relating to an exhibit to which an objection has been sustained shall be conducted outside the presence of the jury Tr No As set forth in more detail below the Court defers rulings on Epsteins objections directed to Edwards trial exhibits concerning Epsteins net worth and in support of Edwards punitive damages claim The Comt will address these objections at the appropriate time Tr The Court makes the following specific findings LEGEND FOR EPSTEINS OBJECTIONS I All Objections All Objections except Authenticity Relevance Probative value substantially outweighed by danger of unfair prejudice confusion of issues misleading the jury or needless presentation of cumulative evidence Privileged Opinion 7-Hearsay Authenticity Other please identify basis of objection IO Completeness I I Overbroad Not provided to Counsel for Epstein Prior to Filing Pretrial Stipulation Not a proper exhibit Trade secrets/Confidential Edwards Exhibit Description Epsteins Courts Ruling Ob_jections All applicable criminal statutes II Not addressed at hearing All applicable Florida Statutes Not addressed at hearing Photos and information ofJeffrey Epsteins Tr I homes airplanes and automobiles Deferred Order confirmation from Amazon.com for Tr purchase of books SM I A realistic Sustained 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 IO Tr Overruled No Edwards Exhibit Description Epsteins Courts Ruling Ob_jections Jane Doe Complaint Tr Sustained Messages taken from message pads found at Tr Epsteins home Deferred Not to be mentioned during opening statements Documents related to Jeffrey Epstein produced by Alfredo Rodriguez Deferred Not to be mentioned during opening statements Jeffrey Epstein flight logs Sustained Jeffrey Epstein phone records II Sustained I Sarah Kellens phone records II Tr Sustained Jail Visitation Logs I I Tr Sustained Jeffrey Epsteins probation file II Tr I Sustained All probable cause affidavits related to criminal IO Tr investigation of Jeffrey Epstein Deferred Victims statements to the FBI related to criminal Tr investigation of Jeffrey Epstein Sustained Video of Search Warrant of Jeffrey Epsteins Tr I home being executed Sustained Application for Search Warrant of Jeffrey Cannot Tr Epsteins home be read Sustained Complaint Jane Doe Epstein and all subsequent as Tr Amended Complaints to subsequent Deferred Amended Complaints In his December Second Amended Exhibit List Edwards changed the description of this exhibit to Video of Epstein Property Inspection This Order does not make any rulings on the new description and may be subject to a new Motion in Limine as Epstein deems appropriate No Edwards Exhibit Description Epsteins Courts Ruling Objections All records of homes properties bank accounts Tr and any all records related to Jeffrey Epsteins Deferred assets Jeffrey Epsteins passport or copy Tr Sustained Jeffrey Epsteins drivers license or copy Cannot be read Tr Sustained List of corporations owned by Jeffrey Epstein Deferred Yearbooks of Jane Doe I Tr Not produced Deferred Royal Palm Beach High School Year Book Not produced Deferred Royal Palm Beach High School Year Book Not produced Deferred Palm Beach Gardens High School Year Book Not produced Deferred Affidavit and Application for Search Warrant on IO Tr Jeffrey Epsteins home Sustained In his December Second Amended Exhibit List Edwards modified this exhibit to include additional descriptive language from Palm Beach State Attorneys File Exhibit The Court finds that this language does not substantially change the exhibit and thus the Courts ruling holds No Edwards Exhibit Description Epsteins Courts Ruling Ob_jections Notepads found in Jeffrey Epsteins home and/or Tr during trash pulls outside of his home during Sustained in part and overruled in criminal investigation part The impact upon the issues as to preparedness knowledge as far as Mr Edwards is concerned his diligence as to discovery if those are called into question then this exhibit may be discussed The actual documents themselves are excessive and would be getting into other matters that would not be germane to Edwards three clients and therefore may not be used until discussed outside the presence of the jury The Palm Beach State Attorneys Criminal file against Jeffrey Epstein Sustained in part and ovem1Ied in part If Edwards had access to formulate his positions as to the legitimacy of his three clients claims this file may come into play The sheer amount of the criminal file would also be relevant to Mr Epsteins state of mind at the time he filed the underlying Complaint The individual pages are not subject to admission and would need to be discussed outside the presence of the iurv All documents related to Jeffrey Epsteins Tr conviction Deferred I Jeffrey Epsteins criminal plea colloquy Tr Deferred List of properties and vehicles in Larry Visoskis Tr I name The exhibit Deferred provided was an entire Motion which was denied not just the identified item No Edwards Exhibit Description Epsteins Courts Ruling Objections All of Jeffrey Epsteins Responses to Requests for Tr Production Requests for Admission Answers to Deferred Interrogatories in this matter and cases All discovery related responses of Jeffrey Epstein Not addressed at hearing in this matter and cases Jeffrey Epsteins Answers and Affinnative II Tr Defenses in all civil cases against him Deferred All Complaints in which Jeffrey Epstein is/was defendant This also includes Deferred a motion which is not part of the stated exhibit Jeffrey Epsteins Deposition testimony and Not addressed at hearing discovery responses in this case and cases Jeffrey Epsteins Deposition testimony and Not addressed at hearing discovery responses in State Court cases LM Jeffrey Epstein Case No AB and E.W Jeffrey Epstein Case No Jeffrey Epstein Deposition Testimony and Not addressed at hearing discovery responses in State Court case Jeffrey Epstein Scott Rothstein et al Case No Any and all newspaper articles online articles or Tr publications related to Jeffrev Eostein Deferred Report and Analysis of Jeffrey Epsteins assets Deferred Video footage DVD of walk through site Tr inspection of Jeffrey Epsteins home Deferred Photos of all of Jeffrey Epsteins properties cars boats and planes as to cars and Deferred boats Probable Cause Affidavits prepared against Jeffrey Eostein and Sarah Kellen Deferred No Edwards Exhibit Description Epsteins Courts Ruling Objections Documents related to or evidencing Jeffrey Tr Epsteins donations to law enforcement Sustained Victim Notification Letter from US Attorneys Tr Office to Victims Sustained Expert Dr Dennison Reeds Report of Victim Tr Sustained Palm Beach Police Department Incident Report Tr dated Sustained All reports and documentation generated by Palm Tr Beach Police Department related to Jeffrey Sustained Epstein All Witness Statements generated by Palm Beach Tr Police Department relating to Jeffrey Epstein Sustained Passenger Manifests of Jeffrey Epsteins aircraft Tr and private plane flight logs Sustained Passenger lists for flights taken by Jeffrey Epstein Sustained Letter from Jeffrey Epstein to Alberto Pinto Tr regarding house island project Sustained Jeffrey Epsteins bank statements Tr Deferred Jeffrey Epsteins tax returns Tr Deferred MC2 emails involving communications of Jeffrey Tr Epstein Jeff Fuller Maritza Vasquez Pappas Suat Not Produced Jean Luc Brunel and Amanda Grant Reserved ruling because documents not available DVD of plea and colloquy taken on Tr Sustained Transcript of plea and colloquy taken on Tr Sustained Massage Table document Tr marked as No Sustained is not a massage table In his December Second Amended Exhibit List Edwards modified this exhibit to include additional descriptive language CW SR The Court finds that this language does not substantially change the exhibit and thus the Courts ruling holds In his December Second Amended Exhibit List Edwards changed the description of this exhibit to Palm Beach Police Department Incident Report dated unredacted This Order does not make any rulings on the new description and may be subject to a new Motion in Limine as Epstein deems appropriate No Edwards Exhibit Description Epsteins Courts Ruling Obiections No Contact Orders entered against Jeffrey Epstein Tr I Sustained Criminal Score Sheet regarding Jeffrey Epstein Tr I Sustained Documents evidencing Jeffrey Epsteins Tr I Community Control and Probation Sustained Jeffrey Epsteins Sex Offender Registrations Tr from various states Deferred Jeffrey Epsteins Booking photograph Tr Document says Deferred cannot rely on this for legal action CAD calls to EL BRILLO WAY PALM Tr BEACH FL Sustained List of Jeffrey Epsteins House contacts Tr document Sustained provided is not reflective of descriotion Documents related to Jeffrey Epsteins Tr investments Deferred Letter from Chief Michael Reiter to Barry Tr I Krischler Sustained List of planes owned by Jeffrey Epstein Tr document Deferred provided does not match description Letter from Guy Fronstin to Assistant State IO Tr Attorney dated Sustained Letter from Guy Fronstin to Assistant State Tr Attorney dated Sustained Letter from Guy Fronstin to Assistant State I Tr Attorney dated Sustained Letter from Guy Fronstin to Assistant State IO Tr Attorney dated Sustained In his December Second Amended Exhibit List Edwards changed the description of this exhibit to Palm Beach Police Department Incident Report dated I unredacted This Order does not make any rulings on the new description and may be subject to a new Motion in Limine as Epstein deems 267appropriate No Edwards Exhibit Description Epsteins Courts Ruling Objections Letter from Guy Fronstin to Assistant State Tr Attorney dated Sustained Letter from Goldberger dated Tr I Sustained All subpoenas issued to State Grand Jury Tr Sustained in part and overruled in part If Edwards had access to fonnulate his positions as to the legitimacy of his three clients claims these documents may come into play The sheer amount of the criminal file would also be relevant to Mr Epsteins state of mind at the time he filed the underlying Complaint The individual pages are not subject to admission and would need to be discussed outside the presence of the iurv Documents related to the rental of a vehicle for Tr Vanessa Zalis document Sustained produced contains other items not identified on list Teds Sheds Documents Tr document Sustained produced contains other items not identified on list Documents related to property searches of Jeffrey Tr Epsteins properties Deferred Arrest Warrant of Sarah Kellen Tr Sustained Police report regarding Alexandra Hall picking up Tr money dated Sustained List of Trilateral Commission Members Tr Sustained Alan Dershowitz Letter dated and Statute Tr Not Produced Deferred Guy Fronstin letter dated Tr Sustained Jeffrey Epstein Account Information Tr Deferred No Edwards Exhibit Description Epsteins Courts Ruling Obiections Jeffrey Epstein Criminal Closeout Sheet Tr Sustained JEGE Inc Passenger Manifest Tr Sustained Hyperion Air Passenger Manifest I Tr Sustained Flight information for Dana Bums II Tr Sustained Passenger List Palm Beach flights I I Tr Sustained Jeffrey Epstein notepad notes.re Maria Tr Sustained Pleadings of Jane Doe I and US case document Tr provided is not Deferred what is identified on list Jeffrey Epstein th Amendment Speech Tr Deferred References to deposition excerpts not ruled upon fully subject to specific line reference rulings which will be subject to a seoarate order Reiter letter to Krisher dated Tr Not produced Deferred Alexandra Hall Police Repo11 dated Tr Sustained Victims school records and transcripts Tr Sustained Victim Notification letter Tr Sustained Police report of Juan Alessi theft at Jeffrey Tr Epsteins home Sustained Victims Medical Records from Dr Randee Tr Speciale Sustained All surveillance conducted by law enforcement on Tr Jeffrey Epsteins home Sustained IOI Emails received from Palm Beach Records related Tr to Jeffrey Epstein Sustained In his December Second Amended Exhibit List Edwards modified this exhibit to include additional descriptive language to Virginia Roberts The Court finds that this language does not substantially change the exhibit and thus the Courts ruling holds I I No Edwards Exhibit Description Epsteins Courts Ruling Ob_jections All items listed on the Palm Beach Police Property Tr Report Lists items not Sustained provided All copies of convictions related to Jeffrey Tr Epstein Sustained Jeffrey Epstein criminal records Tr Sustained All documents produced by Palm Beach Police II Tr Department prior to the deposition of Detective Sustained Recarev Statements deposition transcripts videotaped Tr depositions and transcripts taken in connection No ruling catch all with this and all related cases and exhibits thereto Any and all expert witness reports and/or records Not addressed at hearing catch generated in preparation for this litigation by any all tiartv to this cause Demonstrative aids and exhibits including but Not addressed at hearing catch not limited to charts diagrams and models all surveys photographs and similar material including blow-ups of the listed items/exhibits Edwards reserves all objections to Epsteins Not an exhibit Not an exhibit Exhibits Edwards reserves the right to supplement and/or Not an exhibit Not an exhibit amend his Exhibit List By listing an Exhibit Edwards is not waiving his Not an exhibit Not an exhibit right to 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 Not addressed at hearing catch objections all All pleadings and attachments in the action under Tr the Crime Victims Rights Act prosecuted by Sustained because of breadth Bradley Edwards on behalf of victims of lack of specificity without Epsteins criminal molestations prejudice to specific documents being produced as set forth above Specific documents must be culled out all documents on the docket may not be identified Edwards must narrow scope Edwards Motions for Summary Judgment all Tr attachments thereto and all Undisputed Facts Overruled In his December Second Amended Exhibit List Edwards modified this exhibit to include additional descriptive language and/or Property Receipts The Court finds that this language does not substantially change the exhibit and thus the Courts ruling holds No Edwards Exhibit Description Epsteins Courts Ruling Ob_jections All time records and hourly billing documentation Tr produced in discovery Overruled Edwards is ordered to produce/cull out within days if the documents have not already been produced All deposition testimony and discovery responses Not addressed at hearing catch by Epstein submitted in this action all All pleadings filed by Epstein in the Rothstein Tr bankruptcy proceeding Deferred All submissions by Epstein in connection with the Tr Rothstein deposition Deferred All Settlement Agreements between Epstein and Tr victims of his sexual molestations Deferred Phone Journal taken from Epsteins home and Tr produced to the FBI by Alfredo Rodriguez duplicative of Deferred Not to be mentioned Exhibit No during opening statement Photo depicting Virginia Roberts Ghislaine Tr Maxwell and Prince Andrew Sustained All flight logs for any Epstein owned or Tr controlled aircraft Sustained All emails produced by Defendant and/or all Not addressed at hearing emails produced by Plaintiff in this case Evidence of contributions to the Palm Beach Tr Police Dept duplicative of Deferred Dr Bernard Jansen Expert Report Attachments Not addressed at hearing and Back-up Documents October Jeffrey Epstein vs Scott Rothstein Bradley Not addressed at hearing Edwards and L.M Complaint December Jeffrey Epstein vs Scott Rothstein Bradley Not addressed at hearing Edwards and L.M Fourth Amended Counterclaim January Jeffrey Epstein vs Scott Rothstein Bradley Not addressed at hearing Edwards and L.M Plaintiff/Counter-Defendant Jeffrey Epsteins Answer and Affinnative Defenses to Defendant/Counter-Plaintiff Bradley Edwardss Fourth Amended Counterclaim February Jeffrey Epstein vs Scott Rothstein Bradley Not addressed at hearing no Edwards and L.M Notice of Voluntary objections Dismissal August Brad Edwards sic Times Records and Billing Not specifically addressed at Records related to this matter hearing but duplicative to Exhibit No and those rulings are incorporated herein No Edwards Exhibit Description Epsteins Objections Jeffrey Epsteins NY State Online Sex Offender Registry Profile New York Post article Billionaire Jeffrey Epstein Im a sex offender not a predator Februarv 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 DONE AND ORDERED in West Palm Beach Palm Beach day of January THE HONOR CIRCUIT CO Courts Ruling Not specifically addressed at hearing but deferred with Exhibit Tr Deferred Not addressed at hearing catch all Not addressed at hearing catch all Not addressed at hearing catch all Not addressed at hearing catch all Not addressed at hearing catch all Not addressed at hearing catch all Not addressed at hearing catch all Not addressed at hearing catch all Not addressed at hearing catch all Not addressed at hearing catch all In his December Second Amended Exhibit List Edwards has shifted Exhibit Nos through to Exhibit Nos through Edwards has also identified new exhibits at Exhibit Nos through This Order does not make any rulings on the new exhibits which may be subject to a new Motion in Limine as Epstein deems appropriate Copies provided to 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 Avenue mep searcylaw.com West Palm Beach FL jsx searcylaw.com njs FLAppellateLaw.com scarolateam searcylaw.com kbt FLA ppe lateLa 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 Ft 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 Scott Link Atterbury Goldberger Weiss P.A Kara Berard Rockenbach Australian A venue Suite Angela Many West Palm Beach FL Link Rockenbach PA go ldberger agwpa.com Palm Beach Lakes Boulevard Suite I smahoney agwpa.com West Palm Beach FL Co-Counsel for Plaintiff/Counter-Defendant Scott linkrocklaw.com Jeffi Epstein Kara linkrocklaw.com Angela linkrocklaw.com Tina linkrocklaw.com Troy inkrocklaw.com Tanya linkrocklaw.com Eservice linkrocklaw.com Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein 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 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