IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA JEFFREY EPSTEIN Plaintiff Complex Litigation Fla Civ Pro Case No CA vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually Defendants I PLAINTIFF JEFFREY EPSTEINS WITNESS AND EXHIBIT LIST i ZS U1 a JC Plaintiff JEFFREY EPSTEIN by and through undersigned counsel and in accordance with this Courts Order Setting Pretrial Procedures hereby files his Witness and Exhibit Lists as follows WITNESSES Scott Rothstein Esq Rothstein Rosenfeldt Adler Bradley Edwards Esq Former Employee of Rothstein Rosenfeldt Adler c/o Farmer Jaffe Weissing Edwards Fistos Lehrman Andrews Avenue Suite Fort Lauderdale FL William Berger Esq Former Employee of Rothstein Rosenfeldt Adler Address to be provided Russell Adler Esq Rothstein Rosenfeldt Adler Address to be provided Mike Fisten investigator 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 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9_ qr qr YY D.X 7s F??Y bc3_c iH CTX CTX A qr 10Cy YY EMq 7H AY mK9Z BY A2 P6L N7 CTX CTX a I I i qr rC CTX CTX 7O I FMM qr qr i I I3 CTX Z6 I L(K4 P:u Z6P CTX y8 Case No AG Former Employee of Rothstein Rosenfeldt Adler c/o Farmer Jaffe Weissing Eswards Fistos Lehrman P.L Andrews Avenue Suite Fort Lauderdale FL Kenneth Jenne Esq Former Employee of Rothstein Rosenfeldt Adler Address unknown at this time Patrick Roberts investigator Former Employee of Rothstein Rosenfeldt Adler Address unknown at this time Richard Fandrey investigator Former Employee of Rothstein Rosenfeldt Adler Address unknown at this time David Bodden Esq Former Employee of Rothstein Rosenfeldt Adler Address unknown at this time Deborah Villegas Chief Operating Officer Former Employee of Rothstein Rosenfeldt Adler Address unknown at this time Andrew Barnett Director of Corporate Development Former Employee of Rothstein Rosenfeldt Adler Address unknown at this time Christina Kitterman Esq Former Employee of Rothstein Rosenfeldt Adler Address unknown at this time Bill Brock a/k/a Uncle Bill Rothstein Rosenfeldt Adler Address unknown at this time Mark Nurik Esq Former Employee of Rothstein Rosenfeldt Adler One East Broward Blvd Suite Fort Lauderdale FL Alan Sakowitz Rothstein Rosenfeldt Adler Address unknown at this time Frank Preve Esq Case No AG Occupied an office at Rothstein Rosenfeldt Adler Address unknown at this time Corporate Representative Q-Task Address unknown at this time Mr Howell Atty in Jacksonville who referred Plaintiff E.W to Edwards Address unknown at this time Paul Cassell Esq Attorney in Utah who handles appellate issues for Edwards Address unknown at this time Maria Villafona U.S Attorneys Office Address unknown at this time Dexter Lee U.S Attorneys Office Address unknown at this time Agent Nebit Kirkendahl Federal Bureau of Investigations Address unknown at this time Agent Jason Richard Federal Bureau of Investigations Address unknown at this time Barry Bekkadan Address unknown at this time A.J Discala Case No AG Address unknown at this time Michael Szafranski Address unknown at this time Shimone Levy Address unknown at this time Obidia Levy Address unknown at this time Daniel Minkowitz Address unknown at this time George Levin Address unknown at this time Dean Kretchmar Address unknown at this time Doug Van Allman Address unknown at this time Barry Stone Address unknown at this time Richard Pearson Address unknown at this time Steven Levin Address unknown at this time Ira Sochet Address unknown at this time Mark Melvin Address unknown at this time Jack Samoney Address unknown at this time Lawrence King Case No AG Address unknown at this time Steve Jackel Address unknown at this time Michael Legamar Address unknown at this time Kevin Draher Address unknown at this time Rob Busche Address unknown at this time Records Custodian and/or Corporate Representative and/or PWMK of Operations Clockwork Capital Advisers Address unknown at this time Records Custodian and/or Corporate Representative and/or PWMK of Operations Razorback Funding Address unknown at this time Records Custodian and/or Corporate Representative and/or PWMK of Operations Fortress Investments Address unknown at this time Records Custodian and/or Corporate Representative and/or PWMK of Operations Fortress Capital Address unknown at this time Records Custodian and/or Corporate Representative and/or PWMK of Operations Drawbridge Capital Address unknown at this time Records Custodian and/or Corporate Representative and/or PWMK Drawbridge Funding Case No AG Address unknown at this time Records Custodian and/or Corporate Representative and/or PWMK of Operations Banyan Investment Fund Address unknown at this time Records Custodian and/or Corporate Representative and/or PWMK of Operations Centurion Credit Fund Address unknown at this time Records Custodian and/or Corporate Representative and/or PWMK of Operations Platinum Management Fund Address unknown at this time Each investor and potential investor who reviewed the approximate ten boxes of cases real or fabricated against Jeffrey Epstein shown by Scott Rothstein to solicit third party investments Edward Morse Address unknown at this time Carol Morse Address unknown at this time Ted Morse Address unknown at this time Patricia A Morse Address unknown at this time Records Custodian and/or Corporate Representative and/or PWMK of Operations Morse Operations Inc Address unknown at this time The names of the investors are unknown to Plaintiff at this time and will be provided upon receipt and review of the discovery pertaining to the investors and potential investors Case No AG Records Custodian and/or Corporate Representative and/or PWMK of Operation Blue Line Research Development LLC Address unknown at this time Jeffrey Epstein c/o Fowler White Burnett Flagler Drive Phillips Point West West Palm Beach FL Any and all witnesses identified in depositions Any and all witnesses identified in Interrogatories and responses thereto Any and all witnesses identified in Requests for Production and responses thereto Any and all witnesses identified in Requests for Admissions and responses thereto Plaintiff reserves his right to supplement and/or amend this list of witnesses during the course of discovery EXHIBITS Any and all documents including but not limited to emails correspondence and settlement agreements between or on behalf of RRA its employees agents or clients and any third party regarding a purported settlement of any litigation between Jeffrey Epstein and a RRA client or the financing of any litigation between Jeffrey Epstein and a RRA client Any and all documents including but not limited to emails correspondence and written agreements between or on behalf of RRA its employees agents or clients and any third party regarding the solicitation and/or receipt of money in return for settlement funds allegedly paid or to be paid by Jeffrey Epstein Any and all documents including but not limited to emails correspondence and written agreements between or on behalf of RRA its employees agents or clients and any third party regarding the solicitation of money to help finance ongoing litigation against Jeffrey Epstein Any and all documents including but not limited to emails correspondence and written agreements between or on behalf of RRA its employees agents or clients and any third party regarding the solicitation of money to be given to or used on behalf of the Plaintiffs in litigation against Jeffrey Epstein Case No AG Any and all documents including but not limited to emails correspondence and written agreements between or on behalf of RRA its employees agents or clients and any third party regarding communication between third party investors or potential investors and the Plaintiffs or their attorneys involved in litigation against Jeffrey Epstein Any and all documents including but not limited to emails correspondence canceled checks bank statements and written agreements between or on behalf of RRA its employees agents or clients and any third party regarding payments made to RRA to or on behalf of any investor for settlement of any litigation involving Jeffrey Epstein Any and all documents including but not limited to emails data correspondence memos or similar documents between Bradley Edwards and any investor or third party person or entity regarding Jeffrey Epstein or which mentions Jeffrey Epstein as it relates to any purported investment pertaining to litigation involving Jeffrey Epstein Any and all documents including but not limited to emails data correspondence memos or similar documents between Scott Rothstein and any investor or third party person or entity regarding Jeffrey Epstein or which mentions Jeffrey Epstein as it relates to any purported investment pertaining to litigation involving Jeffrey Epstein Any and all documents including but not limited to emails data correspondence memos or similar documents between William Berger and any investor or third party person or entity regarding Jeffrey Epstein or which mentions Jeffrey Epstein as it relates to any purported investment pertaining to litigation involving Jeffrey Epstein Any and all documents including but not limited to emails data correspondence memos or similar documents between Russell Adler and any investor or third party person or entity regarding Jeffrey Epstein or which mentions Jeffrey Epstein as it relates to any purported investment pertaining to litigation involving Jeffrey Epstein Any and all documents including but not limited to emails data correspondence written agreements or memos between Bradley Edwards and any other attorney employee or agent of RRA regarding Jeffrey Epstein relating to any investment or potential investment in any case involving Jeffrey Epstein Any and all documents including but not limited to emails data correspondence written agreements or memos between Scott Rothstein and any other attorney employee or agent of RRA regarding Jeffrey Epstein relating to any investment or potential investment in any case involving Jeffrey Epstein Any and all documents including but not limited to emails data correspondence written Case No AG agreements or memos between and any other attorney employee or agent ofRRA regarding Jeffrey Epstein relating to any investment or potential investment in any case involving Jeffrey Epstein Any and all agreements or documents including but not limited to emails correspondence and memos which were provided to or received from an investor or potential investor relating to any case real or fabricated involving Jeffrey Epstein and Scott Rothstein Any and all agreements or documents including but not limited to emails correspondence and memos which were provided to or received from an investor or potential investor relating to any case real or fabricated involving Jeffrey Epstein and Bradley Edwards Any and all agreements or documents including but not limited to emails correspondence and memos which were provided to or received from an investor or potential investor relating to any case real or fabricated involving Jeffrey Epstein and any employee agent or attorney with RRA Any and all documents which were shown to or received by any investors potential investors attorneys and those related persons purporting to relate to cases pending or contemplated involving Jeffrey Epstein Any and all agreements or documents including but not limited to emails correspondence and memos which were provided to or received from an investor or potential investor relating to any case real or fabricated involving Jeffrey Epstein and any employee agent member or officer of any entity formed by Bradley Edwards to create investment opportunities for third party investors to invest in any plaintiffs case against Jeffrey Epstein Any and all documents made available to any investor or potential investor by Bradley Edwards to solicit investors for any case involving Jeffrey Epstein Any and all documents made available to any investor or potential investor by Scott Rothstein to solicit investors for any case involving Jeffrey Epstein Any and all documents made available to any investor or potential investor by any employee attorney or agent of RRA to solicit investors for any case involving Jeffrey Epstein Any and all documents made available to any investor or potential investor by any employee attorney or agent of any entity owned by Scott Rothstein to solicit investors for any case involving Jeffrey Epstein Any and all documents reflecting the names and addresses of all individuals or entities who invested or purported to invest in any aspect of any case against Jeffrey Epstein Any and all documents which purport to evidence any transfer of funds or property to Case No AG investors from Jeffrey Epstein by way of RRA for the settlement of any case real or fabricated against Jeffrey Epstein Any and all documents which purport to evidence any transfer of funds or property to investors from Jeffrey Epstein by way of Scott Rothstein for the settlement of any case real or fabricated against Jeffrey Epstein Any and all documents which purport to evidence any transfer of funds or property to investors from Jeffrey Epstein by way of any entity owned by Scott Rothstein for the settlement of any case real or fabricated against Jeffrey Epstein Any and all documents relating to any investment joint-venture or business enterprise involving RRA that reference any claim real or fabricated against Jeffrey Epstein The entire bankruptcy file In Re Rothstein Rosenfeldt Adler P.A All files pertaining to cases real or fabricated against Jeffrey Epstein which were shown to any investors or potential investors to solicit investment opportunities for third party investors to invest in any plaintiffs case against Jeffrey Epstein All Q-Task Projects that refer to Jeffrey Epstein All Q-Task Projects that refer to L.M E.W or Jane Doe Any employment agreements and correspondence describing compensation benefits for Bradley Edwards during his employment with RRA All documents from the Fortress software program that refer or relate to Jeffrey Epstein All documents from the Fortress software program that refer or relate to L.M E.W or Jane Doe Any agreements and contracts between Mr Howell and Bradley Edwards relating to the referral of Plaintiff E.W and any other cases pending or contemplated purporting to relate to Jeffrey Epstein Any agreements and contracts between Mr Howell and RRA relating to the referral of Plaintiff E.W and any other cases pending or contemplated purporting to relate to Jeffrey Epstein Any agreements and contracts between Paul Cassell and Bradley Edwards relating to the referral of any cases pending or contemplated purporting to relate to Jeffrey Epstein IO Case No AG Any agreements and contracts between Paul Cassell and RRA relating to the referral of any cases pending or contemplated purporting to relate to Jeffrey Epstein Any and all documents of Blue Line Research Development LLC relating to the referral of any cases pending or contemplated purporting to relate to Jeffrey Epstein Any and all documents of Clockwork Capital Advisers pertaining to any investments relating to any purported litigation pending or contemplated involving Jeffrey Epstein Any and all documents of Razorback Funding pertaining to any investments relating to any purported litigation pending or contemplated involving Jeffrey Epstein Any and all documents of Fortress Investments pertaining to any investments relating to any purported litigation pending or contemplated involving Jeffrey Epstein Any and all documents of Fortress Capital pertaining to any investments relating to any purported litigation pending or contemplated involving Jeffrey Epstein Any and all documents of Drawbridge Capital pertaining to any investments relating to any purported litigation pending or contemplated involving Jeffrey Epstein Any and all documents of Drawbridge Funding pertaining to any investments relating to any purported litigation pending or contemplated involving Jeffrey Epstein Any and all documents of Banyan Investment Fund pertaining to any investment relating to any purported litigation pending or contemplated involving Jeffrey Epstein Any and all documents of Centurion Credit Fund pertaining to any investment relating to any purported litigation pending or contemplated involving Jeffrey Epstein Any and all documents of Platinum Management Fund pertaining to any investment relating to any purported litigation pending or contemplated involving Jeffrey Epstein The deposition of Jeffrey Epstein taken on March The deposition including all exhibits of Bradley Edwards taken on March All interrogatories served on Bradley Edwards and responses thereto All Requests for Admissions served on Bradley Edwards and responses thereto All Requests for Admissions served on Bradley Edwards and responses thereto Case No AG All documents produced by Bradley Edwards in response to Requests for Production All documents and emails produced by the bankruptcy trustee In Re Rothstein Rosenfeldt Adler All Interrogatories served on Scott Rothstein and responses thereto All Requests for Admissions served on Scott Rothstein and responses thereto All Requests for Production served on Scott Rothstein and responses thereto Plaintiff reserves his right to supplement this list of exhibits CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was mailed this z3 Id of August to Gary Farmer Jr Esq Farmer Jaffe Weissing Edwards Fistos Lehrman PL Andrews Avenue Suite Fort Lauderdale FL Jack Scarola Esq Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Blvd West Palm Beach FL Jack A Goldberger Esq Atterbury Goldberger Weiss P.A Australian A venue South Suite West Palm Beach FL Marc Nurik Esq Law Offices of Marc Nurik One Broward Blvd Suite Ft Lauderdale FL AG Li ly Ann Sanchez Fla Bar No Joseph Ackerman Jr Esq Fla Bar No FOWLER WHITE
