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Epstein Release Interview Victim Statements Evidence Maxwell
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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 MOTION IN LIMINE ON DEFENDANT/COUNTER-PLAINTIFFS NEWLY DISCLOSED TRIAL EXHIBITS AND TO EXCLUDE DEPOSITION TESTIMONY OF WITNESSES WHO WERE NOT DEPOSED IN THIS MATTER Plaintiff/Counter-Defendant Jeffrey Epstein Epstein files this Motion in Limine directed at the newly disclosed exhibits on Defendant/Counter-Plaintiff Bradley Edwards December Second Amended Exhibit List D.E and to exclude certain witnesses disclosed on Edwards November Seventh Amended Witness List D.E to testify by deposition and states PRELIMINARY STATEMENT Original Timely Exhibits and Rulings On November Edwards filed his Amended Exhibit List identifying exhibits D.E Exhibit A 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 asked the Court to sustain those objections D.E The FILED PALM BEACH COUNTY FL SHARON BOCK CLERK PM Court heard extensive arguments on Epsteins objections at special set hearings on November and December and made specific findings Tr Tr Exhibit On January the Court memorialized those findings in an Order D.E Exhibit Edwards New Untimely Exhibits This Motion addresses new exhibits revealed by Edwards on December with the filing of Edwards Second Amended Exhibit List identifying exhibits which modified some of his earlier disclosed exhibits and identified new items Exhibit At no time during the special set hearings did Edwards counsel advise the Court that he planned to amend the Exhibit List or that the parties and Court were working from an incorrect list Epstein filed his written objections to Edwards Second Amended Exhibit List on December D.E Exhibit Epstein incorporates the introduction and background sections of his November Revised Omnibus Motion in Limine D.E and for brevity purposes has not restated those sections here THE COURTS RULINGS At the November and December hearings this Court made clear that it would not allow the parties to stray too far afield from the malicious prosecution claim Tr The Court is not going to allow the parties to try a child molestation case Tr The Court is also not going to allow the introduction of tangential matters into this case which would either directly or indirectly inflame the jury Tr While Edwards produced many of the new exhibits on November he never identified them as trial exhibits on his November Exhibit List and Epstein was not aware that he intended to rely on them at trial at the time of filing his Revised Omnibus Motion in Limine The relationship between the value weak allegation of Edwards three clients claims L.M E.W and Jane Doe and Epsteins claimed probable cause will be permitted in a manner that benefits the dignity of the courtroom without pejorative commentary Tr Edwards is going to be allowed to provide testimony and speak generically about the evidence that relates to his three clients or as it relates to his preparation and evaluation of their cases Otherwise the Court sustained many of Epsteins objections based on relevance and because the exhibits probative value was substantially outweighed by the danger of unfair prejudice under section Florida Statutes The Court indicated that before certain exhibits could be referenced or allowed at trial they would need to be discussed outside the presence of the jury Tr The Court also deferred ruling on Epsteins objections concerning exhibits identified to support Edwards punitive damages claim Tr While the Court will allow Edwards to speak generically about claims of plaintiffs he did not represent he may not go into detail about those cases Tr Finally the Court ordered Edwards to produce those exhibits already listed but that had not already been produced by December Tr THE NEWLY IDENTIFIED EXHIBITS Edwards newly identified exhibits can be grouped into several categories A Virginia Giuffre a/k/a Virginia Roberts Edwards identified thirty-one new exhibits specifically referencing or relating to Virginia Giuffre a/k/a Virginia Roberts who was not one of Edwards three clients For instance Edwards has listed Ms Roberts medical records Ex twenty-three photographs in which Ms Roberts appeared Exs travel related documents Exs an FBI interview form for Ms Roberts Ex the docket of Ms Roberts lawsuit against Epstein Ex and an application for her passport Ex The Court has already determined that Edwards may discuss his three clients claims but other than discussing the general number of claims of other individuals he did not represent specific information about those other claims will not be allowed Tr In addition the Court has already sustained Epsteins relevancy objection as to a photo depicting Ms Roberts with Ghislaine Maxwell and Prince Andrew Ex and will only allow such exhibits if the context comes up and only after it is discussed outside the presence of the jury Epstein requests his objections to these thirty-one newly disclosed exhibits concerning Ms Roberts also be sustained Travel and Airplane Related Exhibits Although Edwards has conceded that his three clients never traveled with Epstein he has listed exhibits relating to travel airport codes Ex and a brochure for a Boeing Super Ex The Court has already sustained Epsteins objections to passenger manifests and flight logs Ex recognizing that they bear no relevance to the malicious prosecution action Tr These new trial related documents similarly have no place at the trial of Edwards malicious prosecution Counterclaim and Epsteins objections should be sustained Phone Records Edwards has identified Sara Kellens cellular phone records Exs Ms Kellen is not a party to this lawsuit and the Court has already sustained Epsteins objection as to Edwards Trial Exhibit No which identified Ms Kellens phone records Tr The Court should uphold the same ruling as to these exhibits Photographs Edwards has identified nineteen other photographs scenic various individuals Epstein properties Exs and While Ms Roberts is not depicted in these photographs Epstein assumes Edwards intends to use many of them with that witness With the exception of Exhibit No which Edwards may claim relates to his punitive damages claim and which the Court has earlier deferred ruling on such items the photographs have no bearing on the issues of this malicious prosecution action and Epsteins objections should be sustained Other Individuals Edwards has identified exhibits relating to Epsteins alleged former housemen Alfredo Rodriguez and Juan Alessi Alfredo Rodriguez sentencing transcript criminal complaint and plea agreement Exs and Juan Alessis sworn statement and deposition transcripts Exs He has also identified deposition transcripts relating to Ghislaine Maxwell Ex and Epsteins brother Ex None of this testimony was given in this case or relates specifically to Edwards three clients and therefore cannot be used at trial as set forth more fully below Edwards has also identified a typed list of victims/co-conspirators unique to the investigation of Jeffrey Epstein Ex Many of the names on this list are alleged victims who were minors at the time they filed suit and it is unknown if they have given up their right to remain anonymous Furthermore the Court has already ruled that while the number of claims can be discussed the specific nature of the claims of individuals not represented by Edwards cannot be discussed in detail Tr Criminal Records Edwards has identified a number of criminal records involving Epstein March Summary of the Case from the Assistant U.S Attorney Ex a Statement from an unidentified victim Ex Santa Monica Police Report from Ex Epsteins Guilty Plea Ex Palm Beach County State Attorneys file Ex and Palm Beach County Incident Reports Exs and The Court has already deferred ruling on plea related documents but it has sustained Epsteins objections to criminal type records on the basis of relevancy and section prejudice and has only allowed them to be introduced if the context comes up outside the presence of the jury i.e Exs Tr Epstein respectfully requests that these exhibits be treated in the same way Punitive Damages Based on the Courts earlier rulings Epstein anticipates the Court will defer ruling on three exhibits which Edwards may claim support his punitive damages claim as follows video of Epsteins property inspection Ex DVD of search warrant walk through of Epsteins home Ex and folder titled planes Ex Other Records Edwards has identified a number of other exhibits including a hand drawing of Bart Simpson Ex a proposed joint letter to the Special Master Ex a March newspaper article Ex evidence of Epsteins donations to law enforcement Ex a checking account ledger for November Ex and house information Ex which in no way relate to Edwards malicious prosecution Counterclaim Furthermore the Court has already sustained Epsteins objections to similar items i.e donations to law enforcement Ex Epsteins house contacts Ex Epstein requests that the Court sustain his objections to these new exhibits EPSTEINS OBJECTIONS TO UNTIMELY NEW EXHIBITS Epstein has raised the following objections to Edwards untimely identified new exhibits No LEGEND FOR EPSTEINS OBJECTIONS 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 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 Edwards Exhibit Description Epsteins Objections Video of Epstein Property Inspection Palm Beach Police Department Incident Report dated unredacted Palm Beach Police Department Incident Report dated redacted 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 No Edwards Exhibit Description Epsteins Objections 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 Virginia Roberts standing against rocks red coat far with back photo white back date Virginia Roberts 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 Scenic photo with back photo white No Edwards Exhibit Description Epsteins Objections 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 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 Warrant Walk only photo Through DVD Audio from Cassettes Part of DVDs provided Alex Hall Redacted Transcript taken by Detective Joe Recarey and Detective Dawson with Exhibits No Edwards Exhibit Description Epsteins Objections 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 Information relating to Epsteins planes/aircrafts collected by the State Attorneys Office unique to the investigation of Jeffrey Epstein 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 ARGUMENT The New Exhibits are Untimely Pursuant to this Courts Order At Edwards urging this Court declined to extend any of the original pretrial deadlines D.E D.E Although Epstein requested the recalculation of pretrial deadlines based on the trial continuance from December to March Edwards objected to any effort to expand existing deadlines Id On November this Court agreed with Edwards and granted Edwards Motion to Reconfirm Existing Pretrial Deadlines finding that to the extent that wholesale additional discovery will not be permitted but individual discovery requests may be allowed on a matter by matter basis only if the discovery requests are impacted by the Courts ruling on motions currently pending to be heard D.E e.s The new exhibits were a result of Edwards lack of diligence not any ruling of this Court Exhibit Lists were due on October Epstein takes no issue with the timeliness of Edwards October Revised Exhibit List D.E Edwards November Amended Exhibit List D.E and Edwards November Amended Exhibit List D.E which were filed before Epstein spent substantial time preparing a Motion in Limine to address those exhibits and the parties spent days arguing Epsteins objections before the Court The timing of Edwards December Second Amended Exhibit List after the Court finished hearing argument on Epsteins objections should not be allowed because the Exhibit List is untimely The Newly Identified Exhibits Must be Excluded Pursuant to Sections and Florida Statutes All of the newly identified exhibits on Edwards December Second Amended Exhibit List D.E must be excluded because they are irrelevant by neither tending to prove or disprove any material fact in this malicious prosecution action See Fla Stat To the extent Edwards could argue that any of the exhibits are relevant any alleged probative value is substantially outweighed by the danger of unfair prejudice confusion of issues misleading the jury or needless presentation of cumulative evidence Fla Stat Dailey Multicon Dev Inc So 2d Fla 4th DCA Unfair prejudice has been described as an undue tendency to suggest decision on an improper basis commonly though not necessarily an emotional one This rule of exclusion is directed at evidence which inflames the jury or appeals improperly to the jurys emotions Wright State So 3d Fla Byrd BT Foods Inc So 2d Fla 4th DCA See also Canales Compania De Vapores Realma S.A So 2d Fla 3d DCA holding any probative value of testimony about marriage proposal plaintiff purportedly made offering money to woman to marry him so that he could avoid deportation on issue of plaintiffs credibility was far outweighed by its prejudicial effect DeSantis Acevedo So 2d Fla 3d DCA finding probative value of the defendants cross-examination of the plaintiff and his main witness about prior unrelated incidents that insinuated that both the plaintiff and the witness had been dishonest was outweighed by prejudicial nature of questions Edwards inclusion of the newly identified exhibits on his Second Amended Exhibit List further demonstrates that Edwards intends to inject and focus on prejudicial and inflammatory allegations and evidence that have no bearing on the malicious prosecution Counterclaim Epstein requests that this Court remain consistent in its rulings and sustain his objections to the additional exhibits The newly disclosed exhibits have no bearing on any material issue in this lawsuit and only serve to mislead the jury from Edwards burden of proving Epstein lacked probable cause by moving the focus to matters relating to settled claims or concluded lawsuits Exhibits Relating to Prior Convictions and Criminal Matters Must Also Be Excluded Certain exhibits on Edwards Second Amended Exhibit List D.E must also be excluded based on well-settled law that evidence of prior convictions acquittals or arrests is irrelevant in a civil action and thus inadmissible Eggers Phillips Hardware Co So 2d Fla Kelley Mutnich So 2d Fla 4th DCA As such Epsteins conviction as well as any testimony or evidence of any other criminal investigation is inadmissible This includes for example documents relating to a Santa Monica Police Report Ex Epsteins Guilty Plea Ex the Palm Beach County State Attorneys file Ex and other newly identified exhibits on Edwards Second Amended Exhibit List that relate to the criminal investigation and proceedings At the December hearing the Court deferred ruling on these type of documents No Edwards Exhibit Description Epsteins Courts Ruling Objections All probable cause affidavits related to Tr criminal investigation of Jeffrey Epstein Deferred The Court recognizes that this exhibit is more specific and it is potentially critical to the analysis as it relates to the strength of the cases that are involved The Palm Beach State Attorneys Criminal Tr file against Jeffrey Epstein Sustained in part and overruled 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 individual pages are not subject to admission and would need to be discussed outside the presence of the jury No Edwards Exhibit Description Epsteins Courts Ruling Objections All documents related to Jeffrey Epsteins Tr conviction Deferred Because of the uncertainty the Court defers ruling until further information is developed in order to make a cogent and knowledgeable decision Jeffrey Epsteins criminal plea colloquy Tr Deferred Because of the uncertainty the Court defers ruling until further information is developed in order to make a cogent and knowledgeable decision If the exhibit does not have anything to do with Edwards three clients the Court is inclined to sustain the objection Probable Cause Affidavits prepared against Tr Jeffrey Epstein and Sarah Kellen Deferred If the Affidavit was prepared against Epstein himself then it is relevant unless it relates to any issues of Mr Edwards knowledge and his diligence and the like relating to his preparation of the cases on behalf of his three clients Jeffrey Epsteins Booking photograph Tr Document says Deferred cannot rely on this for legal action Because none of these documents relate to Edwards three clients Epstein respectfully requests that the Court sustain his objections to these exhibits Other Exhibits Must be Excluded as Inadmissible Hearsay In addition to being irrelevant all of the newly identified exhibits are inadmissible hearsay Hearsay is a statement other than one made by the declarant while testifying at the trial or hearing offered in evidence to prove the truth of the matter asserted Fla Stat In fact many of these documents contain double hearsay so that even if Edwards could establish an exception for the first layer of hearsay the documents still contain inadmissible hearsay Many of these documents contain contents that are entirely based upon prior statements made by individuals and other extrinsic documents all of which undeniably do not fall into an exception See Reichenberg Davis So 2d Fla 5th DCA The problem here is that in both reports the authors simply related the substance of what the witnesses had told the authors These witnes statements even though contained within the business records do not fall within the exception because they were not based upon the personal knowledge of an agent of the business Id at see also Harris Game and Fresh Water Fish Com So 2d Fla 1st DCA Van Zant State So 2d Fla 1st DCA Accordingly any hearsay documents and any reference or testimony related thereto must be excluded Certain Exhibits Should be Excluded as Inadmissible Opinion Testimony Other documents on Edwards Second Amended Exhibit List D.E identified by the number in the objections column irrefutably contain opinion statements about Epstein who is party to and possible witness in this case rendering it improper opinion testimony about the credibility of a witness Alvarado State So 2d Fla 3d DCA In Childers State So 2d Fla 1st DCA the court was faced with a similar issue and in denying the admission of the information/documents avowed admission of the notice would have been similar to admitting an opinion by the State concerning Juniors character truthfulness and credibly Such opinion testimony regarding a witness reputation for truthfulness us clearly inadmissible See Antone State So.2d Fla holding improper a question of a witness which sought to elicit the individual and personal view of the witness Hernandez State So.2d Fla 4th DCA holding that it was reversible error to admit testimony of police officers and teacher that sexual abuse victim was truthful A witness invades the jurys exclusive province when that witness gives his or her personal views of the credibility of another witness Alvarado State So.2d Fla 3d DCA holding that an opinion of a witness concerning his or her belief as to the truthfulness of another witness clearly inadmissible Morrison State So.2d Fla holding that it was improper to allow personal opinion to establish reputation for truthfulness without laying a foundation based on knowledge of the witness reputation in community for truthfulness Wyatt State So.2d Fla 3d DCA holding that section Florida Statutes does not permit opinion testimony regarding evidence of character Ehrhardt Florida Evidence at Opinion testimony concerning a persons character has traditionally been inadmissible on the basis that it is too unreliable it will be tainted by the underlying prejudice and bias of the person expressing the opinion on expressing the opinion Id at Exhibits Should be Excluded for Other Reasons as Well Other exhibits are overbroad and vague so that they should also be excluded as identified by an in the objection column The Deposition Transcripts and Witnesses Presented Through Deposition Testimony Should Not be Allowed On his November Seventh Amended Witness List D.E Edwards identified four nonparties whom he intends to call as witnesses through deposition testimony Mark Epstein Adriana Ross Adriana Mucinska Louella Rabuyo Alfredo Rodriguez D.E Exhibit Edwards has not filed deposition designations for these individuals or specified the transcripts on which he intends to rely Furthermore none of these witnesses depositions have been taken in this matter and thus Epsteins counsel has not had an opportunity to cross exam them on the issues presented in this case Furthermore on his December Second Amended Exhibit List Edwards has identified transcripts for some of these witnesses and for other individuals Statements deposition transcripts videotaped depositions and transcripts taken in connection with this and all related cases and exhibits thereto Ghislaine Maxwell deposition Mark Epstein deposition Juan Alessi deposition Vol I Juan Alessi deposition Vol II Sentencing Transcript Alfredo Rodriguez D.E Exhibit a Not Provided Testimony in this Action Edwards can only present depositions taken in this matter because no prior litigation involving Epstein pertained to the malicious prosecutions essential elements of probable cause and malice It is error to allow the admission at trial of the other lawsuits discovery depositions of nonparty witnesses as substantive evidence We hold that the admissibility of a discovery deposition of a nonparty witness as substantive evidence continues to be governed by rule a We reach this conclusion for two reasons First rule a has not been amended and continues to require certain prerequisites before the deposition of a nonparty is admissible at trial Second section former testimony requires that the party against whom the testimony is now offered had an opportunity and similar motive to develop the testimony by direct cross or redirect examination Emphasis added An attorney taking a discovery deposition does not approach the examination of a witness with the same motive as one taking a deposition for the purpose of presenting testimony at trial it was error to allow the presentation of a deposition of a nonparty witness as substantive evidence Friedman Friedman So 2d Fla 2d DCA emphasis added None of the individuals identified on Edwards Seventh Amended Witness List Nos or identified through transcripts on Edwards Second Amended Exhibit List Nos have provided deposition testimony in this case and it is improper to allow their depositions to be used at the trial in this matter Mark Epstein is Epsteins brother and resides in New York His deposition has not been taken in this case Edwards has identified on his Exhibit List the September transcript of Mark Epsteins deposition taken in the matter of Jane Doe Jeffrey Epstein U.S District Court Southern District of Florida Case No Ex Edwards represented Jane Doe in that action and conducted the deposition however he did not ask any specific questions about his three clients Furthermore Mark Epstein testified that he never visited Epstein during the alleged periods of time in Edwards clients Complaints Also while Epsteins counsel was present at this deposition he did not have the opportunity to question the witness about the motives and issues in this malicious prosecution action Adriana Ross Adriana Mucinska is an alleged former assistant of Epstein who resides in Miami Beach Florida Her deposition was not taken in this matter and Edwards has not identified or produced a transcript on which he intends to rely Louella Rabuyo is alleged to be Epsteins former housekeeper and resides in Palm Beach County Her deposition has not been taken in this matter and Edwards has not identified or produced a transcript on which he intends to rely Alfredo Rodriguez is alleged to be Epsteins former houseman who was incarcerated but is now deceased His deposition was not taken in this matter and Edwards has not identified or produced a deposition transcript on which he intends to rely Ghislaine Maxwell is alleged to be Epsteins former girlfriend and assistant Her deposition has not been taken in this matter Edwards has identified on his Exhibit List the transcript of Ms Maxwells confidential deposition taken in the matter of Virginia Giuffre Ghislaine Maxwell U.S District Court Southern District of New York Case No Ex Epstein was not even a party to that action and thus his counsel did not attend or question the witness It is further unclear if Edwards has obtained the permission from the parties in that mater to disclose confidential testimony in this action Juan Alessi is alleged to be Epsteins former houseman who resides in West Palm Beach His deposition has not been taken in this case Edwards has identified on his Exhibit List the transcript of Mr Alessis September deposition taken in the matter of Jane Doe No Jeffrey Epstein U.S District Court Southern District of Florida Case No Exs Edwards was not counsel ofrecord in that matter and the transcript produced does not reflect that he was even at the deposition or that the questions relate to his clients This deposition testimony is obviously intended to do little more than unfairly inflame and prejudice the jury with irrelevant information from Epsteins criminal case and prior civil cases which have settled or are concluded Moreover the above-mentioned witnesses do not have personal knowledge of this matter as required by section Florida Statutes which states in pertinent part that a witness may not testify to a matter unless evidence is introduced which is sufficient to support a finding that the witness has personal knowledge of the matter Fla Stat Likewise the collateral matter rule states that litigation of purely collateral matters for the sole purpose of impeaching a party or witness is improper Dempsey Shell Oil Co So 2d Fla th DCA A matter is considered collateral if it is not material and would not be admitted for any purpose other than the contradiction Id Thus unless these witnesses have knowledge and can speak to what Epstein believed when he filed suit against Edwards their testimony would be irrelevant and collateral and their deposition testimony should not be allowed Florida Rule of Civil Procedure provides a Use of Depositions At the trial or upon the hearing of a motion or an interlocutory proceeding any part or all of a deposition may be used against any party who was present or represented at the taking of the deposition or who had reasonable notice of it so far as admissible under the rules of evidence applied as though the witness were then present and testifying in accordance with any of the following provisions The deposition of a witness whether or not a party may be used by any party for any purpose if the court finds A that the witness is dead that the witness is at a greater distance than miles from the place of trial or hearing or is out of the state unless it appears that the absence of the witness was procured by the party offering the deposition that the witness is unable to attend or testify because of age illness infirmity or imprisonment that the party offering the deposition has been unable to procure the attendance of the witness by subpoena upon application and notice that such exceptional circumstances exist as to make it desirable in the interest of justice and with due regard to the importance of presenting the testimony of witnesses orally in open court to allow the deposition to be used or the witness is an expert or skilled witness Objections to Admissibility Subject to the provisions of rule and subdivision of this rule objection may be made at the trial or hearing to receiving in evidence any deposition or part of it for any reason that would require the exclusion of the evidence if the witness were then present and testifying While deposition testimony from a different proceeding may be admissible if the party to whom it is offered was provided with an opportunity to examine the deponent because Epstein did not have the opportunity to develop the testimony based on the issues in this litigation Edwards malicious prosecution Counterclaim it would be error to allow the deposition testimony relating to issues not relevant in this litigation Accordingly Epstein seeks to exclude Edwards use of deposition testimony from Mark Epstein Adriana Ross Adriana Mucinska Louella Rabuyo Alfredo Rodriguez Ghislaine Maxwell Juan Alessi and any other witness whose testimony was taken in other cases because such testimony is irrelevant misleading confusing and prejudicial and the witnesses lack any knowledge regarding the issue at hand in this matter CONCLUSION For the reasons stated above and in reliance upon the applicable law cited herein Epstein respectfully requests that this Court enter an Order in Limine precluding Edwards his counsel and his witnesses from making any argument statement evidence or comment as well as precluding from use at trial the exhibits listed above and deposition testimony from other matters CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on February 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 Searcy Denny Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach FL mep searcylaw.com jsx searcylaw.com scarolateam searcylaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Bradley Edwards Edwards Pottinger LLC Andrews Avenue Suite Ft Lauderdale FL brad epllc.com staff.efile pathtojustice.com 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 Nichole Segal Burlington Rockenbach P.A Courthouse Commons Suite West Railroad A venue West Palm Beach FL njs FLAppellateLaw.com kbt FLAppellateLaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Marc Nurik Law Offices of Marc Nurik One Broward Boulevard Suite Ft Lauderdale FL marc nuriklaw.com Counsel for Defendant Scott Rothstein EXHIBIT A Filing E-Filed PM 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 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 lITelevant 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 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 confinnation 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 Search Warrant of Jeffrey Epsteins home being executed Application for Search Warrant of Jeffrey Epsteins home Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Amended Exhibit List Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Amended Exhibit List Counter-Plaintiff No Description of Exhibit 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 airnnt on Jeffrey Epsteins home 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 Marked Marked for Objection in Evidence Identification Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Amended Exhibit List Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Amended Exhibit List Counter-Plaintiff No Description of Exhibit List of prope1iies and vehicles in Larry Visoskis name All of Jeffrey Epsteins Responses to Requests for Production Requests for Admission Answers to Inte1rngatories 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 a defendant 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 Marked Marked for Objection in Evidence Identification Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Amended Exhibit List Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Amended Exhibit List Counter-Plaintiff No Description of Exhibit Any and all newspaper articles online aicles 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 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 Victim 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 Marked Marked for Objection in Evidence Identification Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Amended Exhibit List Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Amended Exhibit List Counter-Plaintiff No Description of Exhibit 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 Massage Table 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 Marked Marked for Objection in Evidence Identification Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Amended Exhibit List Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Amended Exhibit List Counter-Plaintiff No Description of Exhibit Letter from Chief Michael Reiter to Barry Krischler List of planes owned by Jeffrey Epstein 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 Zalis Teds Sheds Documents Documents related to property searches of Jeffrey Epsteins properties Arrest Warrant of Sarah Kellen Police report regarding Alexandra Hall picking up money dated Marked Marked for Objection in Evidence Identification Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Amended Exhibit List Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Amended Exhibit List Counter-Plaintiff No Description of Exhibit List of Trilateral Commission Members of Alan Dershowitz Letter dated and Statute Guy Fronstin letter dated Jeffrey Epstein Account Info1mation 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.maria Pleadings of Jane Doe and US case Jeffrey Epstein 5th Amendment Speech Reiter letter to Krisher dated Alexandra Hall Police Report dated Victims school records and transcripts Victim Notification letter dated Police report of Juan Alessi theft at Jeffrey Epsteins home Victims Medical Records from Dr Randee Speciale Marked Marked for Objection in Evidence Identification Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Amended Exhibit List Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Amended Exhibit List Counter-Plaintiff No Description of Exhibit 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 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 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 Marked Marked for Objection in Evidence Identification Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Amended Exhibit List Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Amended Exhibit List Counter-Plaintiff No Description of Exhibit 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 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 Marked Marked for Objection in Evidence Identification Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Amended Exhibit List Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Amended Exhibit List Counter-Plaintiff No Description of Exhibit 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 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 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 August Brad Edwards Times Records and Billing Records related to this matter Jeffrey Epsteins NY State Online Sex Offender Registry Profile New York Post miicle Billionaire Jeffrey Epstein Im a sex offender not a predator February Marked Marked for Objection in Evidence Identification Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Amended Exhibit List Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Amended Exhibit List Counter-Plaintiff No Description of Exhibit 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 Marked Marked for Objection in Evidence Identification Jeffrey Epstein vs Scott Rothstein Bradley Edwards and L.M Case No Counter-Plaintiffs Bradley Edwards Amended Exhibit List 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 qr day of I Jack Scarol Florid No Mail jsx searcylaw.com and me earcylaw.corn Pri ary E-Mail scarolatearn 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 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 Amended Exhibit List Bradley Edwards Esquire staff.efile pathtojustice.com Farmer Jaffe Weissing Edwards Fistos Lelmnan 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 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 Defendants/Counter-Plaintiffs I TRANSCRIPT OF PROCEEDINGS DATE TAKEN TIME PLACE BEFORE Wednesday November 29th a.m p.m Dixie Highway Room l0C West Palm Beach Florida Donald Hafele Presiding Judge This cause came on to be heard at the time and place aforesaid when and where the following proceedings were reported by Sonja Hall Palm Beach Reporting Service Inc Palm Beach Lakes Boulevard Suite West Palm Beach FL PALM BEACH REPORTING SERVICE INC the flaw in the argument is what I perceive to be a lack of recognition of not only Mr Epsteins rationale for filing his suit but the focus or lack thereof on Mr Edwards responsibility and burden a strict one and a strong one according to onerous used by one of the cases in being able to prove probable cause here And Mr Scarola has used in his briefing this building-block approach And I think the same type of analogy or picture can be utilized here when speaking about the motive What was the probable cause in actuality from the counter-plaintiff Edwards standpoint for Epstein doing what he did As I indicated before but didnt use the analogy what you and Mr Link provided to the Court provides not only building blocks for potentially Mr Epsteins probable cause but likewise provides building blocks for Mr Edwards proving that he did not have probable cause And as far as the Court is concerned if the guilty plea came after he filed suit then there might be some reasonable argument to separate it out and say Judge he hadnt even filed suit the suit was filed strike that He hadnt pled guilty The guilty plea came three years after he filed this suit for malicious prosecution then it would probably be a relevancy argument that may or may not win the day But when looking at it from a building block type of analysis as I have in the most simplest terms in looking at it from both sides which I am incumbent to do as Mr Scarola alluded to this is but one item that could be argued to have fueled Mr Epstein to have filed this lawsuit thus making it relevant Now the fluidity issue that I spoke about is Im willing to look at it again if theres a case on point that specifically says otherwise But for purposes of this particular matter the Court would find absent the production of a case that would say otherwise that Mr Epsteins guilty pleas I understand its combined so Im not suggesting there were more than one combined plea would be relevant that it would be relevant to the issue of probable cause and it would be relevant potentially to the issue of malice And that again with the Court looking at it from both sides and analyzing it from both sides it could be used by Mr Epstein It could be used by Mr Edwards But it provides at least some relevancy defined again as proving or tending to prove or disprove a material fact The material fact is the element of probable cause and perhaps malice So again I am going to rule that they would be admissible Next issue please But again we are going to completely and entirely stay away from any type of pejorative comments I understand that sometimes things are said in the heat of deposition that would never be repeated at trial Again Im certainly ordering that that not take place All right We want to go back to some of these in the time that we have left lets go back to some of these exhibits and see if we can work through them MS ROCKENBACH Thank you Your Honor We had identified and have highlighted starting with number three photographs and information of Mr Epsteins homes planes automobiles Im not sure what relevance that would have as to why he filed a malicious prosecution action THE COURT Lets take them one at a time Mr Scarola whats your position MR SCAROLA His homes and his automobiles are evidence with respect to his pecuniary circumstances obviously a relevant matter when we are talking about a punitive damage claim THE COURT Typically though net worth is what is considered not necessarily unless its impeachment i.e youll have a picture of a home that he owns in the US Virgin Islands I think that he has some connection with one of those islands And Im not trying to Palm Beach Reporting Service Inc suggest anything as far as anything inappropriate But I can conceive of this situation that if Mr Epstein testifies that his net worth is comprised of A Band in large part but you find an asset that he has not taken into account thats worth twice as much of his claimed net worth MR SCAROLA I know he has a minimum net worth of I dont mean to interrupt Your Honor but Mr Epstein refuses to provide any evidence with regard to his net worth so we are obliged to offer circumstantial evidence of his net worth unless and until those objections based on Fifth Amendment grounds are overruled on the basis that they are non-testimonial THE COURT I think thats a subject for another motion MS ROCKENBACH It is Your Honor MR SCAROLA It is But Your Honor should not be deciding this issue on the basis of the premise that we are going to get evidence from Mr Epstein as to what Mr Epsteins net worth is THE COURT Agreed MR SCAROLA All he has told us is hes willing to stipulate to a net worth in excess of million Well it makes a difference as to whether its million million or a thousand million that is a billion dollars or billion So even if were left with a Fifth Amendment assertion we are back to the same issue that was raised by the defense and that is there needs to be some evidence independent of the Fifth Amendment assertion that would allow the inference to be THE COURT Im going to cut you off Im going to defer on number three Number four is the Amazon receipt for the 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 MR SCAROLA I never read it Your Honor if I might MS ROCKENBACH It has no relevance Your Honor Prejudicial Should not be discussed referenced admitted I think its also a receipt from Amazon for the book by the way Its an order confirmation If my memory serves correct its a receipt for the purchase of a book It has nothing to do with malicious prosecution THE COURT Mr Scarola MR SCAROLA In fact it does I might explain to Your Honor that many of the items that are on this list that are being challenged a vast majority of them were part of an appendix to the motion for summary judgment that was not defended against by Mr Epstein THE COURT Let me ask you this Was this particular exhibit located prior to the suit being filed by Mr Epstein MR SCAROLA Yes sir MS ROCKENBACH Its the receipt located by whom THE COURT By anybody For the purposes of this case MR SCAROLA These are items THE COURT In other words was it discovered in a lawsuit that was filed prior to Mr Epstein filing this suit MR SCAROLA No sir It was discovered when a search warrant was executed by law enforcement shortly after the criminal allegations were made against Mr Epstein before any of the civil lawsuits were filed So law enforcement gets probable cause to execute a search warrant on Mr Epsteins home And one of the things that is found or many of the things that are described here are found during the course of the execution of that search warrant and formed probable cause for the criminal charges against Mr Epstein Even more significantly they formed the basis for the civil lawsuits that were filed on behalf of L.M E.W and Jane Doe that is this is all evidence taken into account in substantiating the validity of the claims of these three particular victims of Mr Epstein And all of these things are delineated in the motion for summary judgment that Palm Beach Reporting Service Inc Mr Epstein does not defend against and voluntarily dismisses his case on the eve of the hearing Your Honor is well aware of procedurally he would have been obliged well in advance of the hearing to file his opposition to the motion for summary judgment He doesnt do that Why is that significant in the context of this case Because as we have heard from the defense they are going to challenge whether there is a bona fide termination of the claim against Mr Edwards in favor of Mr Edwards Was the abuse of process claim terminated under such circumstances as to indicate a bona fide termination How do we make that decision Well the only way to make that decision is to talk about the motion for summary judgment what supported the motion for summary judgment and the fact that the motion for summary judgment was not opposed A voluntary dismissal was taken and the statute of limitations permitted to expire without ever refiling those claims So as long as bona fide termination remains an issue the motion for summary judgment is clearly relevant and material And this is all part of the motion for summary judgment Many of these things in addition to that forms the basis for the explanation of Mr Edwards conduct when he was a member of RRA and demonstrate that he wasnt abusing the process in any respect at all while he was prosecuting these claims He was pursuing very relevant and material avenues of discovery reasonably calculated to lead to admissible evidence So thats my full response to this THE COURT The objection is sustained on two grounds on relevancy and also analysis I will entertain the introduction outside the presence of the jury if it becomes necessary The other concern I have is that at best it appears to sound like it may be impeachment on a collateral matter collateral to the summary judgment the summary judgment motion was made and then not challenged For those reasons Im going to sustain the objection at this time again subject to context for being able to readdress it if necessary MR SCAROLA Number four is sustained THE COURT Yes sir for the reasons stated in the record MR SCAROLA Understood THE COURT The NPA I have already indicated that the inclination would be if properly predicated would be allowed The Jane Doe one of two complainants I dont see any what would be the grounds for objecting to that MS ROCKENBACH Im not sure what the relevance is Im not the proponent of the evidence but I dont see what relevance there would be of Jane Does complaint The relevance in this malicious prosecution action might be the allegations of this complaint this action But when we start bringing in other complaints as exhibits for a jury to read I think that goes far afield from THE COURT This is the same Jane Doe or a different Jane Doe MR SCAROLA Same Jane Doe THE COURT Overruled Next issue MR SCAROLA Excuse me Your Honor There are two Jane Does This is Jane Doe Jane Doe was a Bob Josefsberg client And just so I orient Your Honor with regard to this matter under the terms of the non-prosecution agreement the federal court appointed Bob Josefsberg as counsel on behalf of all unrepresented victims to protect the interest of unrepresented victims turn the terms of the non-prosecution agreement One of those multiple victims being represented by Mr Josefsberg was an individual identified as Jane Doe She has since been publicly identified as Virginia Roberts/Virginia Giuffre And the specific allegations in this Palm Beach Reporting Service Inc complaint include the transport of Jane Doe Number on Mr Epsteins private jets to various homes owned by Mr Epstein in various locations inside and outside the United States THE COURT Shes expected to be a witness MR SCAROLA Yes sir THE COURT Live witness MR SCAROLA Live THE COURT At this point Im going to find that if in fact she is a witness that it would be cumulative and hence I am going to sustain the objection on those grounds MR SCAROLA May I just finish my argument as to why this complaint was of significance Because she does she does allege in the complaint that she was molested onboard the airplane and that she was prostituted out to third parties onboard the airplane which provided the basis for Mr Edwards seeking airplane logs and the testimony of pilots and the testimony of others identified in the flight logs as being present on the plane THE COURT Thats fine I dont have a problem with Mr Edwards testifying If it becomes an issue in terms of credibility or whatever it might be then I will take another look at it But on the basis of the arguments that I have heard the objection is sustained for the reasons that I provided MR SCAROLA Understood Thank you sir MS ROCKENBACH Your Honor before we leave based on Your Honors ruling I would make an ore tenus motion for leave to depose Virginia Roberts because now it has become clear that she is going to be testifying based on Mr Scarolas statement and Your Honors ruling THE COURT Wasnt she scheduled to come to court from Australia Wasnt that the lady MR SCAROLA Thats where shes living She was scheduled to come to court She was available to be deposed previously They chose not to take her deposition She has been listed as a witness for years in this matter THE COURT Youll have to do a written motion But I want to be consistent with what I said recently and that is that its not the continuance is not and I emphasize not designed to be a wholesale reopening of discovery that the Court would take that up on an issue-by-issue basis but without pre-deciding anything unless it can be demonstrated to the Court that there was unavailability that there was a late filing that there was some type of inability of a witness to testify something along those lines These witnesses have been listed for a lengthy period of time Again this was not the purpose of the motion that was filed and it was not the import of the order of the Court Lets talk about number seven MS ROCKENBACH Messages taken from message pads found at Mr Epsteins home THE COURT What do the messages say MR SCAROLA They relate to arranging sexual massages with minors I cant tell you from memory but Mr Edwards may be able to whether there are specific references to our three clients THE COURT Not to be overly technical or hypertechnical here is Mr Edwards serving as co-counsel MR SCAROLA Yes Your Honor I think Ive told Your Honor before we dont anticipate him taking an active role in the trial but he remains as co-counsel of record in this case THE COURT Fair enough Mr Edwards would you like to comment on that MR EDWARDS Sure Your Honor The message pads include the names of many of the underaged females that visited and set up appointments at Mr Epsteins home including L.M E.W and Jane Doe THE COURT Have they been authenticated by Mr Epstein Or did he take the Fifth on that MR EDWARDS He has taken the Fifth on questions related to that They have been Palm Beach Reporting Service Inc authenticated in other depositions by Detective Vicari although those were taken in other cases But hes an available witness who could testify as to the chain of custody where he found the message where he found the messages and how he gathered them during the search warrant THE COURT The relevancy Mr Scarola MR SCAROLA They clearly relate to the validity of the claims on behalf of these three victims of Mr Epstein They corroborate that these young women were there at his home on many occasions and along with a large number of other underaged females who were being routinely molested by Mr Epstein MS ROCKENBACH Your Honor may I reply This is inflammatory These message pads may be relevant had Mr Edwards not settled the three lawsuits in which he represented those three women But they are not relevant in the malicious prosecution case whether my client had probable cause to file this action or not Or malice We are definitely getting far afield in terms of the exhibits And it looks like and I understand why Mr Edwards would want to try exhibits that were relevant to his clients action because the exhibits that should be relevant in the malicious prosecution case are the facts and circumstance or the lack of facts and circumstances on which my client relied in filing this lawsuit the civil action the civil proceeding Message pads regarding these appointments are absolutely prejudicial and not which prejudicial effect clearly outweighs any remote probative value in this action MR SCAROLA It seems to me that we are going unfortunately around the same mulberry bush The validity of the claims is an issue In addition to that the viability of the claims against Mr Epstein from a criminal perspective is part of why he was so concerned about this non-prosecution agreement being set aside He knew that there was a mountain of evidence that would prove that he was a serial child molester that there were dozens and dozens of victims of his molestations which were occurring multiple times a day day after day after day And the only way he could foresee at this point in escaping the criminal exposure that was clearly going to result in convictions because of this mountain of evidence available was to scare off the one person who was challenging that non-prosecution agreement through the Crime Victims Rights Act case THE COURT Im going to defer on ruling on this But it is not to be mentioned during opening statements And it is going to be determined by the Court in the context in which I believe it would be necessary And Im concerned about first as I mentioned earlier on in another exhibit that this is collateral That it would constitute impeachment on a collateral matter Again I dont want to get back into serial child molestation I believe words to that effect were just utilized so thats the reason for the ruling I think that right now based upon what Im looking at which is not the actual messages but just the recitation of an exhibit would be that there that any probative value would be materially outweighed by the prejudice MS ROCKENBACH Thank you Your Honor We are working off of Mr Edwards exhibit list And the next one is eight documents related to Mr Epstein produced by Alfredo Rodriguez THE COURT Alfredo Rodriguez was the houseperson if Im understanding MS ROCKENBACH Yes Your Honor THE COURT I dont know what that means What specifically are we talking about MR SCAROLA Were talking about a book that contains a list of Jeffrey Epsteins victims their names and telephone numbers as well as a number of other contacts that Jeffrey Epstein has who Palm Beach Reporting Service Inc through other evidence were established to be regular guests in his home These provided corroboration of the testimony of L.M E.W and Jane Doe They provided evidence of the extent of Mr Epsteins molestation of children which obviously supports the magnitude of the wrong in which he was engaged which goes directly to the punitive value of the claims brought by L.M E.W and Jane Doe that is a jury faced with the task of making a determination as to the appropriate amount of punitive damages is instructed that they shall take into consideration the magnitude of the wrong and that includes the total number of victims involved in the offenders wrongdoing THE COURT I presume that by the time the case was settled that I or a predecessor judge in that division had found a valid claim for punitive damages in terms of those cases that we are dealing with here MR SCAROLA Yes There were multiple punitive damages claims pending THE COURT I would have expected so I just didnt know the timing MR SCAROLA Yes MS ROCKENBACH Your Honors question got us directly to the point This is relevant evidence for punitive damages in Mr Edwards clients cases not in this case THE COURT My concerns are again that we are going too far afield And again my best efforts are to try to keep this as a level playing field when it comes to focusing on the claims that are made in this particular case that being the malicious prosecution case And while I know and I have already indicated and I believe Epsteins counsel has conceded that it cannot be sanitized and will not be sanitized because it goes to many of the issues that are involved here and by way of Mr Edwards recitations through Mr Scarola the motives that Mr Epstein may have had to file the action at bar But at the same time I am going to rule in the same way as I did as to number seven and that is that I find that under that the probative value any probative value is materially outweighed by the prejudice involved MR SCAROLA May I ask a rhetorical question Your Honor THE COURT Sure MR SCAROLA When Mr Epstein alleges that these cases were ginned up when he alleges that asking in the complaint for million sic was totally out of line and supportive of his conclusions that this was a fabricated claim constructed solely for the purposes of supporting knowingly supporting a Ponzi scheme when he alleges that these cases really had no significant value how can we not talk about what the punitive damage value of the cases were and why they had enormous punitive damage value when they are claims relating to a vast number of molestations by a billionaire THE COURT Because we are dealing with the three cases that Mr Edwards represented these three individuals And to allow records information about anybody else at this juncture would in my view be collateral to the allegations made by Epstein in his claim And theres no contention here that Mr Edwards for whatever reason went on some type of organized witch hunt so as to persecute or threaten Mr Epstein with proof of other cases proof of other alleged molestations documents that are at issue or anything of that nature MR SCAROLA Thats exactly what was alleged sir It was alleged that Bradley Edwards was pursuing discovery with regard to molestations of other children that took place on an airline when none of Brad Edwards clients were ever molested on the airplane that he had no reasonable basis for doing that THE COURT Now it seems to me were engaging in a negative proving up a negative MR SCAROLA You lost me THE COURT You understand what Im trying to say MR SCAROLA No Palm Beach Reporting Service Inc THE COURT If none of Mr Edwards clients were molested on an airplane then it seems to me to be conceding my point and that is then theres no reason for these other issues to be introduced because theres nobody that Mr Edwards represented that was molested on an airplane MR SCAROLA Thats exactly my point sir Thats the defense argument THE COURT Show me where thats MR SCAROLA Thats the defense argument that this was irrelevant discovery THE COURT Show me where thats in the complaint about the other alleged victims MR SCAROLA Well have that for you in just a moment Your Honor THE COURT Let me take a look at that and see how it may or may not be conjecture MR SCAROLA While we are finding that we will have that for you in just a moment Your Honor may recall that I referenced earlier and I have unfortunately misplaced the copy of the federal statute I should have it I should have it in just a moment THE COURT I mean Im looking at paragraphs and for example where Mr Epstein alleges while relative to this action Epstein is currently named as defendant in three civil actions alleging sexual assault and battery that were handled by RRA and his attorneys including Edwards prior to its implosion presuming he means RRAs and not Mr Edwards implosion one of which was filed in federal court and the two in state court that I have already identified The civil actions were filed in August and September of Paragraph then says quote What is clear is a fraudulent and improper investment of a Ponzi scheme was in fact conducted and operated by RRA and certain of the named defendants which scheme directly impacted Epstein as a named defendant in these civil actions referencing the three at issue MS ROCKENBACH Correct THE COURT Where is MR SCAROLA Paragraphs and THE COURT Lets take a look at those Paragraph states quote For instance the litigation team relentlessly and knowingly pursued flight data and passenger manifests regarding flights Epstein took with these famous individuals knowing full well that no underaged women were on board and no illicit activities took place Rothstein and the litigation team also inappropriately attempted to take the depositions of these celebrities in a calculated effort to bolster the marketing scam that was taking place end quote Next paragraph MR SCAROLA Next paragraph THE COURT Quote One of the plaintiffs counsel strike that One of plaintiffs counsel Edwards deposed three of Epsteins pilots and sought the deposition of a fourth pilot currently serving in Iraq The pilots were deposed by Edwards for over hours and Edwards never asked one question relating to or about L.M E.W and Jane Doe RRAs clients as it related to transportation on flights of RRA clients on any of Epsteins planes But Edwards asked many inflammatory leading and irrelevant questions about the pilots thoughts and beliefs which will never be admissible at trial which could only have been asked for the purpose of pumping the cases and thus by using the deposition to sell the cases or a part of them to third parties End quote Anything else MR SCAROLA Those are two obvious references in the complaint to conduct on the part of Brad Edwards alleged to have been improper and forming part of the basis for abuse of process claims THE COURT The Courts ruling remains the same MR SCAROLA I never like to argue after the Court has already ruled but there is one additional point that I want to make THE COURT Sure MR SCAROLA Your Honor I have cited in we have cited in submissions to the Court specifically the motion in limine addressing the scope of admissible evidence Palm Beach Reporting Service Inc that we have filed We have cited the provisions of Florida statute subsection two commonly known as the Williams Rule statute which talks about evidence of other crimes We have also cited the Federal Rules of Evidence rule And that rule expressly permits the introduction in evidence of the molestation of other children in any federal action criminal or civil involving the molestation of a child Congress explained and quote That in the submission to the Court the reform effected by these rules is critical to the protection of the public from rapists and child molesters Its justified by the distinctive characteristics of the cases to which it applies In child molestation cases a history of similar acts tends to be exceptionally probative because it shows an unusual disposition of a defendant a sexual or pseudosexual interest in children that simply does not exist in ordinary people Moreover such cases require reliance on child victims whose credibility can readily be intact in the absence of substantial corroboration In such cases there is a compelling public interest in admitting all significant evidence that will shed some light on the credibility of the change excuse me of the charge and any denial by the defense So THE COURT And Mr Scarola if we were trying a sexual molestation case there may be a stronger argument But the very point that Im making is that were not trying a sexual molestation case per Now there may be elements and issues that may arise depending upon the nature of Mr Epsteins position relative to these matters However it does not change the Courts view that these messages taken from a message pad at Epsteins home relate to others and that the documents related to Epstein produced by his houseman Mr Rodriguez that relate to others remains irrelevant And any probative value if found to be relevant would be materially outweighed by the prejudice The Courts decision remains the same I think its bolstered by the fact that we are not trying the child molestation case And the significance of the collateral cases is not in my respectful view necessarily a touchstone of this particular case and this particular analysis We are going to have to call it a day I thank you very much again for your arguments and your input written and oral Thank you again Again thanks to our court reporter and our courtroom personnel also for their hard work and courtesies Have a good rest of the week We will see you back if not before on December 5th MR LINK Thank you for your time THE COURT We will take up the remaining issues of evidence first and then we will go back to the schedule which I very much appreciate you all providing We will adhere to that schedule as we continue on with the motions We will be in recess The above proceedings were concluded at p.m Palm Beach Reporting Service Inc IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Case No JEFFREY EPSTEIN Plaintiff/Counter-Defendant vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually Defendants/Counter-Plaintiff I VOLUME I TRANSCRIPT OF PROCEEDINGS DATE TAKEN TIME PLACE BEFORE Tuesday December 5th a.m p.m Dixie Highway Room l0C West Palm Beach Florida Donald Hafele Presiding Judge This cause came on to be heard at the time and place aforesaid when and where the following proceedings were reported by Sonja Hall Palm Beach Reporting Service Inc Palm Beach Lakes Boulevard Suite West Palm Beach FL Palm Beach Reporting Service Inc Court is thinking from that standpoint perhaps ruling at this point with the caveat that consistent with motions in limine and the recognition by the appellate courts much to my delight that there are often situations where situations will change and context is introduced to cause the Court to perhaps vary its decision in some regard But that is afforded to me once trial is underway MR LINK Your Honor before we start can I take you up on your three-minute break opportunity please THE COURT Sure Not a problem Take a few minutes Come on back in about five minutes please A recess was had a.m a.m MR SCAROLA May I make a procedural inquiry Your Honor THE COURT Yes MR SCAROLA I assume that we are starting on page of Jeffrey Epsteins revised omnibus motion in limine Is that correct THE COURT Thats what I am understanding Ms Rockenbach MR SCAROLA Thats where we left off MS ROCKENBACH Yes The exhibit section which should be letter MR SCAROLA Well the specific exhibits that you are objecting to are identified in this motion correct MS ROCKENBACH Actually we stopped we left off at Mr Edwards exhibit list and we are on number nine The revised omnibus motion in limine identified examples of the objections that we had And we have listed and filed our objections to the exhibit list THE COURT Where is the list of exhibits MR SCAROLA If you have an extra copy I need one also please I gave mine to Sonja at the end of the last hearing And I was assuming we were going to be basing this discussion on the motion MS ROCKENBACH Your Honor may I approach I have a copy for Mr Scarola It is Mr Edwards amended exhibit list that we were reviewing THE COURT I actually have it Thanks MS ROCKENBACH You do Okay Our objections were filed November Thats obviously a separate document THE COURT That I will take MR LINK Your Honor they are listed in the motion starting on page three THE COURT I thought those were just exemplars MR LINK In the omnibus motion in limine it actually lists I think every single one of the exhibits They are identified in here So they are in two places THE COURT Page three of the revised omnibus motion in limine MS ROCKENBACH Your Honor its the original omnibus THE COURT Is that part of the MR SCAROLA If we are working with the witness list I mean with the exhibit list we will just work with the exhibit list THE COURT Lets do that MR LINK That works for us Your Honor THE COURT Thanks MR SCAROLA So I assume we are going to take these one at a time THE COURT Yeah MS ROCKENBACH Your Honor the next one that we were on was number nine Mr Epsteins flight logs if I may approach I would like to give Your Honor what was provided to my office from Mr Scarola And it is a sampling because I think there were over pages for this particular exhibit Weve objected on the basis of relevance of judicial value And these are flight logs of my clients planes They have no relevance to what is being tried in this case which is malicious prosecution Mr Edwards testified that he knew that his clients were not on my clients plane so the flight logs are completely irrelevant Palm Beach Reporting Service Inc THE COURT Okay Mr Scarola MR SCAROLA Yes Your Honor one of the alleged bases for Jeffrey Epstein having concluded that Bradley Edwards was a knowing participant in the Rothstein Ponzi scheme is that the scope of the discovery that Bradley Edwards was seeking once he became a member of the Rothstein Rosenfeldt Adler firm expanded to include matters that he was not previously focusing on and which had no reasonable basis to lead to the discovery of admissible evidence So he alleged that the abusive discovery that Bradley Edwards engaged in gave him reason to believe that he was only doing these things because he was knowingly supporting the Ponzi scheme So Bradley Edwards obviously has an opportunity to explain what he did and why he did it Yes I was seeking discovery with regard to the airplane flight logs and who was on the airplane And the reason why I did that was because even though my own clients were not transported on the plane I know that other young women were transported on the plane for purposes of prostitution and sexual abuse And I can prove that through the flight logs that list the other occupants on the airplane including children who were being transported by Jeffrey Epstein Part of what makes this is a viable federal claim is the intrastate and international transportation of children for purposes of prostitution The federal law specifically Federal Rule excuse me and I referenced this in an earlier argument to the Court expressly allows the introduction into evidence in any case involving a sexual offense against a child the commission of any other sexual offense against a child So I was seeking evidence to prove a pattern of abuse of children including their transportation for purposes of prostitution And I was doing that through flight logs that identified these children flight logs that identified other witnesses taking the depositions of pilots And so all of this is information than rebuts the assertion by Jeffrey Epstein that this was an abusive discovery effort that supported my conclusion that Bradley Edwards was a knowing participant in the Ponzi scheme Thats what he alleges In fact portions of the deposition of Bradley Edwards have already been identified by the defense as theyre intending to introduce this in evidence before the jury I have some of those excerpts if you Your Honor needs to take a look at them They are offing that evidence with regard to these matters as part of their support for the lack of Bradley Edwards probable cause to conduct this discovery the assertion that this was an abuse of discovery process Now thats what they alleged in their complaint Those specific allegations are included in the complaint Those are false allegations THE COURT Show me those allegations that you are suggesting MR SCAROLA From the complaint Your Honor or from the deposition testimony THE COURT Either way or both MR SCAROLA Let me do both then THE COURT Thanks MR SCAROLA Its a little bit difficult for Your Honor to see on these copies what the defense has designated but on page it starts at line two and continues through it looks like the bottom of that page And then on and its most of all of those pages Then in the complaint the allegation in paragraph and I will pause if Your Honor would like me to do that while you are reading that THE COURT If you will take a moment please Thanks I dont see much as far as what is set forth in the latter pages of the deposition of Mr Edwards that even mentions the plane or its connection with the alleged underaged individuals on that plane Let me look at the complaint Paragraph MR SCAROLA Thirty-three Palm Beach Reporting Service Inc THE COURT Okay This is directed to primarily to Mr Rothstein It says and others But it says quote paragraph Upon information and belief Rothstein and others claimed their investigators discovered that there were high-profile individuals onboard Epsteins private jet where sexual assaults took place and showed and possibly others copies of a flight log purportedly containing names of celebrities dignitaries and international figures Remind me who is MS ROCKENBACH One of the investing companies that was being defrauded by Rothstein THE COURT Okay I have read those other ones Are there any other MR SCAROLA Paragraph Your Honor then specifically references the litigation team As you recall the litigation team is defined as including Bradley Edwards THE COURT Thirty-five For instance the litigation team relentlessly and knowingly pursued flight data and passenger manifests regarding flights Epstein took with famous individuals knowing full well that no underaged women were onboard and no illicit activities took place Rothstein and the litigation team also inappropriately attempted to take the depositions of these celebrities in a calculated effort to bolster the marketing scam that was taking place End quote Theres a 40-something that was mentioned MR SCAROLA I dont know if Your Honor took a look at but thats a specific reference to Mr Edwards and his conduct of the discovery and then THE COURT Thirty-six One of Plaintiffs counsel Edwards deposed three of Epsteins pilots and sought the deposition of a fourth pilot The pilots were deposed by Edwards for over hours and Edwards never asked one question relating to or about E.W L.M and Jane Doe as it related to transportation on flights of RRA clients on any of Epsteins planes But Edwards asked many inflammatory and leading irrelevant questions about the pilots thoughts and beliefs which could only have been asked for the purposes of pumping that word is used in quotes the cases and thus by using the depositions to sell the cases or a part of them to third parties end quote Told investigators as reported in an Associated Press article that celebrities and other famous people had flown on Epsteins plane when assaults took place Therefore even though none of RRAs clients claim they flew on Epsteins planes the litigation team sought pilot and flight logs Why Again to prime the investment pump enquote with new money without any relevance to the existing claims made by RRA the clients end quote MR SCAROLA Our position obviously is Your Honor that having made those specific allegations in the complaint specifically allegations that no assaults took place on the plane Mr Epstein knew that that was untrue He knew that children were being assaulted on the plane He knew that there were high-profile individuals who were present on the plane And Bradley Edwards had a reasonable basis to conduct this discovery pursuant to applicable Florida law and applicable federal law as well as because it was reasonably calculated to lead to the discovery of admissible evidence So the flight logs are clearly relevant and material for that purpose as is all of the evidence with regard to what Mr Epstein knew was occurring on those airplanes And that directly contradicts what is included in this complaint as a basis for his belief that Bradley Edwards was fabricating these claims THE COURT Thanks Mr Scarola MS ROCKENBACH Your Honor may I use the Elmo for a minute THE COURT Sure MS ROCKENBACH I really appreciated Mr Links presentation this morning based on the law because after the November 29th hearing I went back and I spent a good part of the weekend looking at malicious Palm Beach Reporting Service Inc prosecution cases because I thought I must have missed something I must have missed something because all I hear Mr Scarola in court saying is hes going to prove that the allegations in the original proceeding that my client filed are false And I never knew that to be a malicious prosecution action But my research yielded what Mr Link indicated this morning which is the Debrincat case is the blueprint for this trial The Debrincat case actually has the most guiding principle in it for this Court which is going to I think superimposes the entire exhibit list of Mr Scarolas as it relates to a lot of these exhibits that go to one of the other lawsuits whether its Mr Edwards lawsuits on behalf of the three women who sued Mr Epstein and was settled in that case is over or the exhibits go to one of the other lawsuits The statement in Debrincat thats so important is that Your Honor Mr Scarola and I parties and witnesses should be absolutely excepted from liability to an action for defamatory words published in the course of judicial proceedings So when Mr Scarola pulls out my complaint my clients original proceeding and wants to parse through independent allegations or paragraphs and say Im going to prove that that statement is false and you should never pled it thats not what the malicious prosecution law says Thats not what we are here to do We here for Your Honor to decide as a threshold matter whether the facts that my client reasonably relied on existed at the time he commenced the original proceeding And in fact thats the Liabos case that Your Honor discussed with us back on November 29th where theres a mixed question of fact of law Your Honor has to do that threshold determination of if theres any question or dispute of those facts that my client relied on were not in existence If the facts existed then you have to determine as the Court whether my client had sufficient probable cause So what are the facts that my client relied on They are not the flight logs Hes not relying on those flight logs Thats a complete red herring for the Court I see why its a focus though because Mr Scarola wants to try other cases This is not a sexual abuse case It is not a federal court action a Crime Victims Rights action Its not even a defamation case which Your Honor clearly stated this morning when denying the affirmative defenses related to defamation So to allow flight logs into this malicious prosecution case is completely irrelevant to the issue of whether the facts that my client relied on when he filed the original proceeding were in existence at the time that he filed it The facts are that there was a civil action forfeiture proceeding against Rothstein filed with the U.S Attorneys Office that the Rothsteins firm was dissolving that Mr Edwards held himself out as a partner in that firm that Mr Edwards had the three lawsuits which he even concedes in his most recent deposition were used by Mr Rothstein to fabricate and thats the word that Mr Edwards testified to under oath to fabricate and create a fantasy That was another word Mr Edwards used Those facts did they exist It sounds like were in agreement Those facts existed The Razorback lawsuit brought by Mr Bill Scherer down in Fort Lauderdale who was quoted in a newspaper article my client read and relied on that said Mr Rothstein was tricking investors He used Epsteins cases as a showpiece and bait Which Epstein cases The one that Edwards had So the flight logs are irrelevant They are far astray from what we are here to try And they are an attempt to open up some other lawsuit sexual By the way the three clients of Mr Edwards Mr Edwards concedes were not you never heard Mr Scarola deny that because Mr Edwards conceded they are not on my clients planes So this like many of the other Palm Beach Reporting Service Inc exhibits Your Honor must be precluded because they are wholly irrelevant And if there was any remote probative value they are prejudicial to talk about flight logs and celebrities who may have been on my clients planes THE COURT I think that the issue itself meaning the tangential allegations that were made that mentioned flight logs or mentioned the good faith discovery aspects of Mr Edwards plight relating to his three clients has some relevancy However the flight logs themselves would be subject to and the Court is sustaining at this juncture the relevancy objection and also a objection and that is that while mentioning the fact that Mr Edwards in good faith whatever the case may have been sought these flight logs as part of his discovery process representing the three young women at the same time the Court has expressly indicated its significant reservations And in fact its condemnation of trying either those cases in this courtroom as far as the malicious prosecution case is concerned or more importantly that we are going to potentially constructively try other either underaged or over the age of consent albeit potential sexual assault claims in this forum So again while it may become relevant as to why Mr Edwards went about his business in seeking out those flight logs in a matter of good faith discovery the flight logs themselves in this Courts respectful view based upon its ruling are irrelevant And if theres any probative value at all they would be materially outweighed by the prejudice of MR SCAROLA May I raise a question Your Honor THE COURT Briefly MR SCAROLA Thank you Do I understand the Courts ruling to be that Mr Edwards is going to be able to explain why he was seeking the discovery he was seeking why he was seeking the flight logs the fact that he did obtain flight logs that confirmed independent information about children being transported on the airplane THE COURT The latter is the one that will have to be discussed further again as I pointed out earlier when the context comes up and its introduced or attempted to be introduced outside the presence of the jury To the what I perceive to be three questions the two former questions the answer would be yes MR SCAROLA Will the Court take judicial notice of Florida Statute which is commonly referred to as the Williams Rule and Federal Rule which expressly permits the introduction of evidence with regard to other sexual assaults against children so that the jury is aware of the fact that Mr Edwards not only had a good faith basis to conduct this discovery but quite arguably would have been grossly negligent to have failed to pursue it THE COURT The only thing I would say to that Mr Scarola is I dont want to mix apples and oranges And that is I dont want to place the Courts incriminator on getting too far afield and turning this into a case about alleged sexual exploitation particularly of others outside of Mr Edwards representation That would serve only to inflame the jury and again would cause the playing field to become unleveled because the defense to the malicious prosecution claim i.e Epstein and his attorneys would have to be fighting claims that they may not even know about much much less the ones that they do So again I want to center on those three claims that were brought by Mr Edwards on behalf of his clients and center on those aspects that would be relevant to the malicious prosecution claim and the alleged ginning up of those claims the alleged attempt to align himself with Rothstein the alleged attempt to factor these cases potentially Mr Edwards conduct as it related to those factoring matters MR SCAROLA I am I am sorry I Palm Beach Reporting Service Inc didnt mean to interrupt THE COURT What Im trying to say is things like flight logs the danger of unfair prejudice And also in to answer your question regarding the cases that talk about the prior similar acts or perhaps even subsequent similar acts those cases are from the forum of which the actual criminal claim or perhaps even a civil claim that stems from the alleged assault is being heard Again what Im trying to emphasize is that I do not want to introduce tangential matters into this case which would either directly or indirectly whether purposefully or not inflame this jury So that is the ruling of the Court I want to move forward now on to the next issue thats being objected to that is what is generically listed as Jeffrey Epsteins phone records MS ROCKENBACH May I approach Your Honor And I can swap with the court Exhibits and the phone records that were produced to my office by Mr Scarola Your Honor the objection is identical to the last in that they are not relevant My clients phone records if there was any remote relevance as to who my client may have called on any given day I dont think thats going to be I think its prejudicial I think theres a danger of prejudicing this jury I am not quite sure what relevance Mr Scarola thinks that phone records have to the malicious prosecution action unless they think we may hear that there is going to be some attempt to prove the falsity of some individual allegation in the original proceeding which is not what we should be doing here in this action THE COURT Thank you MR SCAROLA I am I continue to be extremely puzzled by that statement that we are not here to prove the falsity of claims in the original complaint I would like some guidance from the Court THE COURT No need to be puzzled I think Ive already made myself abundantly clear and that is that the relationship between the legitimacy of the three claims L.M E.W and Jane Doe are going to be permitted in a manner that befits the dignity of the courtroom without pejorative commentary as to Mr Epstein nor obviously as to the three plaintiffs at issue And as conceded by Epstein in his papers once Mr Mr Link and Ms Rockenbach became involved to the matter and that is theres no conceivable way that those issues can be ignored because of the nature of Mr Epsteins announced defense as well as his deposition testimony to the extent that he testified And that is that these three cases were a part of some type of an elaborate scheme by Rothstein and others including the litigation team which is defined as including Edwards to somehow inflate gin up overexaggerate whatever the case may be the value of those cases to these investors whatever damage was caused to Epstein as a result thereof So thats the clear unadulterated ruling of the Court as to that issue MR SCAROLA And I understand that sir My question to you is if there is a specific allegation in the complaint THE COURT That was brought by Mr Epstein MR SCAROLA that was brought by Mr Epstein against Mr Edwards does Your Honors ruling contemplate that we get to prove that allegation is false Without getting into what exhibit we are going to use to prove its false is there any issue about the fact that if he alleged it in the complaint and its false we get to prove its false THE COURT Theres no issue as far as I am concerned MR SCAROLA Thank you sir I think that helps a great deal because I have been hearing something entirely different repeatedly from the other side I didnt understand how they can possibly be making that argument that we werent permitted to prove the falsity of every false allegation in the complaint Palm Beach Reporting Service Inc the three-filed cases were weak Lets just look at that statement They have the burden of proof and they come forward and I guess Mr Edwards gets on the stand and he says Jury these cases were strong They paid million MR SCAROLA million MR LINK million to settle them I am now going to come forward and put on an expert I am going to put someone on to say thats a small number for these cases These cases are weak because look L.M worked at a strip club She an admitted prostitute call girl All of these things come into factoring What Im asking Judge is if we are trying a probable cause/malicious prosecution case then I would suggest to you that none of the specific allegations can lead to a conclusion of probable cause or not The overall flavor of the case the overall complaint when fairly read absolutely comes into consideration It does Was there a reasonable basis to go forward with this lawsuit But cherrypicking a sentence or two in he complaint to prove its falsity doesnt help you or the jury determine probable cause THE COURT Again I dont know how we found ourselves here I just want to get back to the evidence Again I cant be making advisory opinions orders whatever the case might be I want to get back to the individual evidence provisions MR LINK Your Honor I thank you for allowing me to finish I appreciate it THE COURT We are back on the phone records MS ROCKENBACH Your Honor yes I think we are on number ten my clients phone records I believe Your Honor has THE COURT Yes You gave those to me MS ROCKENBACH I did indicate that they have nothing to do with what my client knew what information he relied upon when he instituted the original proceeding THE COURT Mr Scarola your position on the phone records please MR SCAROLA The same as my position with regard to these other exhibits I dont know what Mr Epstein is going to attempt to demonstrate with regard to these underlying claims If he is attempting to prove that they were fabricated if he is defending against the assertion that these were well-founded valuable claims then the phone records may very well become relevant and material because they include the names and telephone numbers of vast numbers of juveniles who were being sexually abused on a daily basis multiple times a day They include the names and telephone numbers of other witnesses to that abuse which form the basis for Mr Edwards seeking to take their depositions because Mr Epstein in the underlying cases as he has in this case asserted the Fifth Amendment privilege was not responding to questions And so we needed to rely upon the testimony of third parties in order to establish the claims The telephone records were part of the basis for identifying the third parties who we sought to take discovery from So again I really think that I havent offered these I dont know if Im going to offer them I wont talk about them unless and until I believe that a reasonable basis exists for me to do that and then I will address that outside the presence of the jury I dont know what else I can say with regard to this and all these other matters We are going through this and Im going to say the same thing over again So for purposes of brevity I will tell Your Honor that for future reference I will simply say same argument And now you know what it is I am adopting as the same argument THE COURT I rarely see you frustrated Im glad youre human like the rest of us MR SCAROLA I clearly am Your Honor And Im sorry theres frustration coming through in my voice but there is frustration in my heart and in my mind Palm Beach Reporting Service Inc THE COURT Not a problem It is the same ruling Again if the issue is one of reasonable discovery and why and if Mr Epstein is going to claim that somehow Mr Edwards was off on a wild goose chase then clearly the fact that he was seeking to discover these phone records and the purpose for the discovery would be appropriate However at this juncture as an exhibit that is the guts of the phone records as a matter of relevancy as a matter of privacy and I dont see anything in here with names they are just numbers MS ROCKENBACH Correct Thats correct THE COURT So Im going to make the same ruling as I did on number nine MS ROCKENBACH Thank you Your Honor The same argument for Sarah Kellens phone records which I can bring to the bench They do not have names They have numbers THE COURT Mr Scarola has indicated that would be the same objection It would be the same ruling Jail visitation logs Same arguments same ruling Jeffrey Epsteins probation file Lets speak about that MS ROCKENBACH Your Honor this would also implicate a probation file would trigger part of the evidence code that Mr Scarola referenced earlier which was His probation file is akin to any visitation logs or any aspect of the criminal action which we are not trying in this case Similar fact evidence of other crimes wrongs or acts are inadmissible when the evidence is solely to prove bad character and propensity And thats Mr Scarola keeps referring to the second subsection of that evidence code which is subsection And it says in a criminal case in which a defendant is charged with a crime involving child molestation then this evidence becomes relevant Your Honor did actually already make a ruling or at least discussed that code section in relation to the federal code which isnt applicable This is not a molestation case The probable cause affidavits that related to the criminal investigation are absolutely irrelevant to this malicious prosecution case And if there was any remote relevant probative value to introducing them and parading them around the jury to tell the jury about what probable cause may have existed in these affidavits it would absolutely prejudice my client and he would not receive a fair trial in this action THE COURT Is there anything specific Mr Scarola that you can think of that would be in the probation file that the Court needs to know about now MR SCAROLA Nothing Your Honor needs to know about now Same argument THE COURT Okay Same argument Same ruling Again this would be akin to draw an analogy to in a personal injury action listing the plaintiffs employment file And that would carry with it the same general objection Now if there were certain things in the employment file that would relevant for example there may be something in an employment file that shows a pre-existing injury of some sort then that would be that may well be relevant But simply stating probation file without any specifics would be the same ruling I am sustaining the objection MS ROCKENBACH Thank you Your Honor Same argument for number the victims statements to the FBI THE COURT We are actually on MS ROCKENBACH All probable cause affidavits Yes I indicated that that would be the same argument because it relates to criminal investigation THE COURT Same argument MR SCAROLA I would only point out Your Honor that clearly to the extent that Bradley Edwards had that sworn testimony when he initiated both his civil lawsuit his civil lawsuits and when he relied upon that in pursuing discovery its obviously Palm Beach Reporting Service Inc relevant and material depending upon what Mr Epstein attempts to say so it is the same argument THE COURT I am going to defer on number I think that that is more specific I think it is potentially critical to the analysis as it relates to the strength of the cases that are involved I understand Mr Links argument regarding his position But I also understand Mr Scarolas argument regarding the fact that somehow they have to prove their probable cause case And its just not going to be Mr Epsteins objective position that needs to be heard All right Next is number Victims statements to the FBI related to the criminal investigation of Jeffrey Epstein MS ROCKENBACH Your Honor I have a copy of these if the Court would like to review them They were produced by Mr Scarola They are approximately six pages But they are absolutely irrelevant inflammatory prejudicial for my client in this action Victims statements And they relate to the criminal case THE COURT Off the record A discussion was held off the record MS ROCKENBACH Your Honor I quickly looked at the names on those particular victims statements and they do not relate to E.W L.M Jane Doe who were represented by Mr Edwards For that reason they were not relevant I know this Court has already said you were not going to allow or constructively try any of the sexual abuse/assault claims And that is what this will be pointing to THE COURT Okay I have read them It is the same argument same ruling that is that if it comes to a point where there is a contention by Mr Epstein that Mr Edwards acted in manner that was rash that was in a manner that was without forethought that he did not properly discover those issues that are that would form the basis of the claims that were brought on behalf of the three young women then again we will revisit Mr Scarola MR SCAROLA Yes Your Honor I just want to supplement my argument in this respect We have been focusing on in those comments in particular on the proprietary or reasonableness of Bradley Edwards conduct and whether Jeffrey Epstein was in a position to consider what was happening as contributing to a conclusion that Mr Edwards was a knowing participate in a Ponzi scheme and fabricating claims against him I think its important that we articulate what the probable cause standard is And I think that maybe I am in agreement with opposing counsel but I want to be sure that I have stated it in what I consider to be an appropriate fashion The issue is would an objectively reasonable and caution person thats the objective part of the formula knowing what Jeffrey Epstein knew thats the subjective portion of formula have probable cause to believe that Bradley Edwards fabricated the claims against Jeffrey Epstein and was a knowing participant in a massive Ponzi scheme So there is both an objective and a subjective component And when we talk about things like phone records and address book and appointment books and airplane logs Jeffrey Epstein knew about the existence of those phone records He knew about the address books He knew about the appointment books and the airplane logs showing that children were being transported on those jet planes He knew what was happening to those children on those jet planes He knew some children had reported virtually identical crimes to law enforcement So those are all things that he knew He knew that he was paying children a bounty to bring other children too He knew he paid the three victims that are named in Bradley Edwards complaints not only per sexual massage but also paid them or for each other child that they brought to him And he specified what it was he wanted and what would gather a premium and Palm Beach Reporting Service Inc what wouldnt gather a premium So when we talk about things like did he know these were strong claims independent of the parade of horribles that he lists there about these young girls incidentally the vast majority of which things if not all of them occurred after he abused these children As the sworn deposition of E.W indicates she was and I think I have already referenced this in prior argument to the Court She was a middle school student doing well She was doing well academically She was participating in extracurricular activities While she has a difficult home life it had not impacted upon her personal conduct in any way that brought her in contact the criminal law or in any way whatsoever that resulted in her engaging in the kind of conduct like stripping or anything else that she has alleged to have been involved in which all occurred after Jeffrey Epstein had abused her So these are things that Epstein knew I appreciate the Courts concern to keep this focused on the claims of E.W L.M and Jane Doe But that is focus of the claims on L.M E.W and Jane Doe Thats what Epstein knew about the strength of their claims This is not a single isolated incident This is not a single isolated victim These are not three isolated victims who were abused on a single occasion This was part of an extraordinary pattern of abuse And thats why I am suggesting too Your Honor that I simply need to adopt the same argument Im not going to offer any of this evidence unless and until I satisfy the Court that its relevant and material And thats all I can say THE COURT In this particular victim statement dated its from a Shana L.R who I dont believe has anything to do with this particular case these three cases that Im aware of And the point Im trying to make as it relates to these exhibits that are listed from seven down now to where we are and thats number is that while it is absolutely conceivable that this information some of this information may be relevant what Im trying to deal with here and distinguish is a discussion about what Mr Epstein may or may not have known and the actual introduction of the records which I dont believe have any real probative value themselves Thats a distinction I dont want a jury getting bound up in trying to locate six phone numbers that may be similar or six times an individual phone entry is listed and automatically assume that it may have something to do in particular with one of these three young ladies that Mr Edwards represented The same thing with the probation file or the visitation logs All of those things while they may have something to do with the competing claims of knowledge strength or weaknesses of the cases all of which again despite my disagreement at least in some regard with Mr Link and those things being relevant to discuss as far as what Mr Edwards had to sustain his claims the actual documents themselves unless theres an issue as to they dont exist or there never were any phone records or there never was a flight log thats a different story MR SCAROLA I take issue with none of what Your Honor said I am in absolute agreement I am not even going to offer them unless they fit that pattern They have been listed here because we are obliged to list them all exhibits that may reasonably become relevant and material THE COURT Fair enough And I think thats the value of the discussion that we are having here today that we can narrow some of issues narrow the intent of what these documents are sought for reasons for the reasons why theyre sought to be potentially introduced Again I dont think its I think its a good exercise So lets go ahead and proceed further MS ROCKENBACH Your Honor number Palm Beach Reporting Service Inc is the video of the search warrant of my clients home while being executed the search I dont have the video but I presume by that it wasnt produced but I presume by that description it is the same ruling THE COURT The same ruling as in the application for the search warrant is sustained MR SCAROLA Let me just point out to Your Honor that the reason why thats listed is because the victims including these three give detailed descriptions of where they were in the house and what the interior looked like And all of that is corroborated by the search warrant video THE COURT Again its with the proviso and caveat that I will re-examine each of these exhibits if need be when the context is pointed out But for now the same ruling is being issued MS ROCKENBACH Number actually Its identified on the exhibit list by Mr Edwards as the application for a search warrant of my clients home And its possible that by mistake Mr Scarolas office produced a different document because what was produced in this context was an order sealing affidavit and application for search warrant and related search warrant and inventory in return And attached to that were the subpoenas to the custodian of records for BellSouth T-Mobile and Cingular So it looks like phone records MR SCAROLA Sounds like the wrong exhibit MS ROCKENBACH Sounds like the wrong exhibit but we would object to on the same basis that the application for the search warrant of Mr Epsteins home would not be relevant would be prejudicial THE COURT I have already indicated the same as to number MS ROCKENBACH Eighteen Your Honor is the complaint THE COURT That again is typically a matter of judicial notice so we will deal with it if we need to at a later time All records of homes properties bank accounts and any/all records related to Jeffrey Epsteins assets MS ROCKENBACH That was not produced along with this passport Nineteen and have not been produced But I presume that this somehow relates to the punitive damages MR SCAROLA It does MS ROCKENBACH And there was a stipulation by my client in discovery I think it was discovery answers about net worth that was in excess THE COURT We talked about that Mr Scarola and understandably so is not going to accept that stipulation So eventually there is going to have to be further discussion I presume thats part of the motion to compel on Thursday MS ROCKENBACH Yes Your Honor MR SCAROLA It arises in the context of the Fifth Amendment assertion to requests for admission and our being able to draw adverse inferences from those requests It has to do with responses to questions during the course of deposition And yes theres a motion to compel because we believe that the Fifth Amendment assertion with regard to some aspects of what have been requested for example disclosures to banks would not be covered by the Fifth Amendment That would be a waiver with regard to anything that was disclosed to third parties Tax returns same thing Waiver THE COURT Deeds MR SCAROLA Deeds airplane registrations THE COURT Thats fine We will take them up if its necessary at the appropriate time Twenty is Mr Epsteins passport Again I think that has to do somewhat with the issues we discussed as to the flight logs Drivers license I dont know what that might be relevant to MR SCAROLA Same argument THE COURT Same ruling I will sustain the objection at this time List of corporations owned by Palm Beach Reporting Service Inc Mr Epstein I presume that has to do with number and the punitive damage claim MR SCAROLA It does Your Honor THE COURT We will deal with that at a later time MS ROCKENBACH Twenty-three through have not been produced And I presume well says its the yearbooks of Jane Doe But I presume that these other yearbooks would implicate I dont know who they would implicate actually Quite honestly they are vague And I cant see what relevance these vague yearbooks are going to have in the malicious prosecution action THE COURT Same argument MR SCAROLA These reflect the appearance of the victims at the time that Mr Epstein was abusing them Your Honor to the extent there might be any argument that he was unaware And that obviously is not a defense as a matter of law but it might be argued in litigation if he were to try to contend he may try to contend that his abuses of minors were inadvertent and therefore less culpable And we would show pictures of these victims from which the jury could draw their own conclusion as to whether this was inadvertent It is not a defense as a matter of law They were either of age or not of age And he was either specifically requesting children or not specifically requesting children But at any rate they could clearly have relevance in that regard And again Im not offering them at this point But they are there in the event this becomes an issue THE COURT I feel comfortable deferring on through Twenty-seven is the same MS ROCKENBACH As earlier as and THE COURT The same as actually MS ROCKENBACH Seventeen THE COURT So the same ruling MS ROCKENBACH Same ruling for which is sustained THE COURT Yes MS ROCKENBACH And through you are deferring Your Honor until you hear testimony And it sounds like the door would be that my client didnt know the age of the three clients of Mr Edwards THE COURT At this point yes MS ROCKENBACH Thank you Your Honor Number is similar to what you ruled upon the last hearing which was number messages taken from Mr Epsteins home This is notepads found in Mr Epsteins home and/or doing trash pulls outside of his home during the criminal investigation We are not in the criminal investigation We are not trying that case And notepads or trash pulled outside my clients home is irrelevant prejudicial and should not be introduced THE COURT Do you have any of those Have you received copies MS ROCKENBACH I did Yes I have a sampling I think it was a very large exhibit so and you will see that May I approach Your Honor THE COURT Sure Okay again I have reviewed these materials I am going to make the same finding I made earlier 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 these may be discussed The fact that he had these materials probably will be able to be discussed The actual documentation themselves though again I think would be excessive and would be getting into other matters that would not be germane to the three young women who were involved here So in essence its sustained in part overruled in part MS ROCKENBACH Number is the Palm Beach State Attorneys Criminal file Its over pages I have a sampling for Your Honor to look at if youre interested THE COURT No Same ruling And that is if it gets to the issue like we discussed Im going to repeat myself then the fact thats its a 2,0-page criminal investigation file that Mr Edwards Palm Beach Reporting Service Inc had some access to formulate his position as to the legitimacy of these three claims if those are called into question because there are that busy equivocation regarding the legitimacy of those claims then again it may come into play The fact that there was a criminal file prepared no surprise to anyone wont be a surprise to the jury But the individual pages therein would have to be further discussed at a later time Mr Scarola MR SCAROLA Your Honor this is one of the circumstances where the distinction that I referenced before probably becomes very clear That is during the course of a criminal prosecution these criminal files probably would not have been available to Bradley Edwards He may have had the same information from other sources But they obviously were entirely available to Jeffrey Epstein So these would have a significant impact on what Mr Epstein knew in order to make a determination as to what a reasonably objective person could or could not rely upon in forming probable cause THE COURT Again Im more concerned with the sanitizing it goes more to attempting to sanitize to the best of our ability and to carve out and distinguish between the three claims that are brought in the global investigation that was done And I think that it is pertinent to the analysis here So again the compilation of the file and if Mr Edwards had knowledge and the extent of the file even if he didnt have access to it which would be likely then that would be relevant as I said to Mr Edwards Also I agree with Mr Scarola that certainly the sheer amount of the file would have been known to Mr Epstein at least should have been known by Mr Epstein And that may be something you may or may not ask him But that should have been known to him at time he filed the lawsuit MS ROCKENBACH It was not Your Honor I have been informed it was not THE COURT Again we will have to figure that out as we go along But again the global ruling is the individual entries unless theres something that is brought to my attention would not be subject to admission But the likelihood that the significance if you will of the file the volume of a file would be particularly important as to Mr Epsteins knowledge prior to filing the suit MR SCAROLA Your Honor Im sure Ms Rockenbach wouldnt intentionally misrepresent any fact to the Court but could we know the basis for her claiming that Mr Epstein did not have discovery in the criminal case MS ROCKENBACH I dont think that my client would have access I could be wrong but I cannot imagine my client would have access to the Palm Beach County State Attorneys criminal file Im not sure how my client would get his hands on the State Attorneys file MR SCAROLA Well Im sure its a reflection of Ms Rockenbach not doing criminal practice But those of us who have engaged in criminal practice know that all evidence in the hands of the State Attorney is require to be turned over to the defense in the context of a criminal prosecution So if its simply a matter of Ms Rockenbach not being familiar with that procedure I understand that But I want the record reflect theres no basis in the record to suggest that Jeffrey Epstein did not have all of the discovery to which he was entitled in the criminal case THE COURT I think its more a matter of timing that I am concerned with And that is at the time he filed the suit versus whenever that information may have been turned over could be very distinct MR SCAROLA He was well into the defense of his criminal prosecution at the time THE COURT By December of MR SCAROLA Yes MS ROCKENBACH I do believe Your Honor though that we are getting very far astray from probable cause which I Palm Beach Reporting Service Inc appreciate Mr Scarolas assistance with the knowledge of the criminal because I have not practiced I did do some appellate criminal work when I clerked at the Fourth District Court of Appeals but that was a lifetime ago But the probable cause issue is not whether or not my client knew about the State Attorneys file or the documents It is whether my client had probable cause to institute the original proceeding based on a reasonable belief that Mr Edwards participated or had connection to Mr Rothsteins Ponzi scam And thats the defamation by way of the jury instruction for probable cause which is So Im not going anywhere outside of the Florida Supreme Court jury instruction definition and the case law But all of these exhibits that we are and the Court is incredibly patient with us going through relate to the criminal action and the criminal we are now on the Palm Beach County State Attorneys criminal file So I guess whether my client had it or not is really irrelevant It is an issue of what are we trying in this case and we are not trying he criminal action THE COURT I understand But it gets back to his knowledge his accountability his constructive knowledge of the ramifications or potential ramifications that could arise when he filed this lawsuit in the first place And those are all relevant as far as this Court is concerned unless I am shown something otherwise by way of the case law So lets move on I would rather go forward just to give you my thoughts on the subject Again I am always inviting anyone to bring cases to my attention that may serve to change my mind or at least influence the decisions that I am going to make MS ROCKENBACH Than you Your Honor It seemed Your Honor was sustaining but I want to make sure I understand THE COURT I have already explained it It is in the record MS ROCKENBACH Next are the documents related to Mr Epsteins conviction They werent produced I dont know what precise documents they were but I really dont think it matters because it relates to the criminal conviction and his plea colloquy that was heard before I believe it was Judge Debbie Pucillo on June This is not irrelevant under its prejudicial under and it also implicates the conviction of certain crimes of impeachment under We discussed this with Your Honor at a prior hearing on November 29th about a procedure to do that You can ask a witness on the stand Have you ever been convicted of a felony or a crime involving dishonesty If they say no then you can absolutely use documents to impeach their lying under oath THE COURT Remember we had that discussion between credibility and a factual issue that being relevancy whether or not something tends to prove or disprove a material fact Thats how we distinguished it the last time Mr Scarola MR SCAROLA I only wanted to point out to Your Honor that a comment was made by Mr Goldberger earlier today thats relevant to this discussion and that is he said that Jeffrey Epstein did not plead guilty to crimes involving these three victims I dont believe that that is supported by the record I think what the record reflects and Your Honor has a copy of the conviction so you might be able to correct me if Im wrong because its been a while since I saw them But I dont think that there is a victim named strangely in those pleas In fact when Mr Epstein was asked who did he plead guilty to prostituting or soliciting for prostitution his response was I dont remember I dont know who it was that I pled guilty to soliciting for prostitution THE COURT For reasons that may have to do with the minority status of the victims it states has Mr Epsteins Palm Beach Reporting Service Inc name guilty plea checked off by way of an two case numbers Charge felony solicitation of prostitution count one third degree felony procuring person under for prostitution second degree felony It goes on by indicating the presentence investigation PSI was not required or waived The sentencing credit for time served other comments or conditions including the registration and designation as a sexual offender presentation of DNA sample as is required in these types of pleas And no unsupervised contact with minors et cetera MR SCAROLA My recollection is THE COURT To my knowledge leafing through this there is no specific designation of the victim by name or initials Go ahead MR SCAROLA That is my understanding as well And the criminal complaints that resulted in those guilty pleas had to do I believe with a long list of individuals So when Mr Epstein pleads guilty and is unable to identify who it is that he pled guilty to molesting I suggest to Your Honor that that is clearly a probative fact that the jury can take into consideration in adjudging the strength of these three cases because he didnt say it wasnt one of these three individuals What he said was I dont remember who it was And that clearly is a statement from which the jury could conclude particularly in light of all the Fifth Amendment assertions from which adverse implication can be drawn when he refuses to acknowledge he even knew any of these three girls Those circumstances taken together clearly are relevant and material in making a determination as to the viability of these three claims MR LINK Your Honor if I may Mr Scarola is dead wrong He did not plead guilty to child molestation You have just seen the plea I know you have asked us not to do rhetoric That is pure rhetoric That is not the plea Second in the colloquy it identifies the minor victim Its AD It is not one of Mr Edwards clients During Judge Pucillos colloquy AD is the minor that relates to that one count But there is nothing in the record there that suggests child molestation or any plea to child molestation THE COURT It depends how you look at it When someone is pleading guilty and is convicted of procuring a person under for prostitution I am not certain thats not a form of child molestation But again I am not here to parse words The bottom line is that if it was a civil action directly related to the criminal prosecution again my global understanding is that the plea a certified copy of the plea would be introduced into evidence Here because of the uncertainty Im going to defer ruling on this particular issue until really further information is developed in order to make a cogent decision and a knowledgeable one for that matter Same thing with the plea column If it doesnt have anything to do with any of the three individuals that Mr Edwards represented the likelihood is I am going to sustain the objection MR SCAROLA For whatever assistance it may be to the Court I believe that AD is the child who introduced E.W to Jeffrey Epstein and was paid for bringing her to Jeffrey Epstein the first time THE COURT Again that may have everything to do with the case that was tried as to E.W.s case Again those tangential issues were something that were of extreme concern for the Court when it comes to this malicious prosecution claim and the continue concern about undue information and part of the reason why I am going to defer but also keeping that very much in the forefront of my consideration that being undue inflammatory information being imparted to the trier of fact Number is List of properties and vehicles in Larry Visoskis name Palm Beach Reporting Service Inc Hes one of the pilots MR LINK Yes sir THE COURT Relevancy MR SCAROLA Has to do with the transfer of assets out of Jeffrey Epsteins name Your Honor And again I dont know that thats going to become a matter that we need to deal with Its listed My argument is what my argument was THE COURT Thank you Again that would be deferred until it needs to be MR LINK Your Honor may I interrupt for one second Do you mind THE COURT Pardon me MR LINK Do you mind if I interrupt for one second I know we are getting passed where you told us we could be but I thought it might be helpful if I clarify I heard you say that we have been equivocating I dont think you mean our team but I think over the years equivocating and I would like to put that to rest if I can It might help us going forward if you give me two minutes I know we are wrapping up now anyway THE COURT Sure MR LINK If you dont mind THE COURT Not at all MR LINK So there is no equivocation about this And I want to say these words as carefully as I can Your Honor I can never speak in final draft like Mr Scarola does but I would try to get to at least a rough draft Here is what I mean The lawsuits filed by Mr Edwards were initiated in when he was a sole practitioner During that time period when he filed them is when Mr Epstein was serving time in jail and is subject to the non-prosecution agreement We have never taken we are not taking the position we are not taking the position for this trial that the filing of those three lawsuits were a fabrication During that time frame pursuant to the NPA Mr Epstein was not permitted to defend the merits he was allowed to challenge the amount of damages they were seeking but he was not allowed under the non-prosecution agreement essentially to challenge liability So there is nothing that were saying that took place between the filing in and when he joins Mr Rothsteins firm that we are calling into question as being fabricated That doesnt mean that Mr Epstein agreed with every single thing these folks said or that he thought the amount they were seeking was reasonable But I want it to be clear that we are not intending to introduce evidence that from when he was a sole practitioner that the three cases were fabricated or made up or that the values were fabricated or used as part of a Ponzi scheme All of the conduct that we have focused on takes place between April when Mr Edwards joins the Rothstein firm and when he leaves And one of the things this Court has said that I think is really important and I understand your ruling you and I have a little disagreement about the way we think it should go but that happens to be almost every day in the courtroom But you have made it really clear that we have to stand behind the allegations of the complaint And Im taking Your Honor as saying that literally that the plaintiff too doesnt get to come in and say words that arent in the complaint that they have to point to words where it says there was a fabrication and who made that fabrication The word that you pointed to was the word weak And were going to have a trial over whether the cases were weak or not weak to somebodys subjective level But I want to be sure that its really clear because all the things weve been talking about the criminal activity the arrest records the flight logs all of that relates to in my view none of the activity that is from April 9th backwards April backwards I may have misspoken I will clarify that in a second And what I mean by that is this The cases that were filed by Mr Edwards he had Palm Beach Reporting Service Inc probable cause to file them We are not saying that he didnt We are not challenging his bringing those cases and we are not going to complain about those cases So information that led up to an arrest for phone records wouldnt only come in if we were saying those three cases in were fabricated Were not saying that Were not saying that at all What Im hearing we are going to be doing in this trial is trying three molestation cases These three victims these three plaintiffs are going to get on the stand and we are going to try the molestation case Were they touched Where were they touched When were they touched How many times were they touched What did they look like Whats their emotional reaction to it Have they suffered damages Have they become strippers as a result of the touching Thats what were talking about trying in this malicious prosecution action THE COURT I am not sure we have been in the same courtroom Thats fine if you are under that impression Again I am not here to answer questions or to give advisory opinions or make advisory statements All Im trying to do here today is trying to slog through as much as this evidence as I can to determine whether or not at least on their faces it would be admissible it would be deferred admissible and granted in part is the objection sustained in part denied in part overruled in part whatever the case might be But I would like to get back to that and use the few more minutes to MR LINK Do you mind if I just see what I just misstated so I can fix it on the record if I need to It will take me seconds MR SCAROLA If Mr Link is offering a stipulation that allegations in the complaints on behalf of E.W L.M and Jane Doe as filed by Bradley Edwards were well-founded allegations I will accept that stipulation and that may help to abbreviate some of the issues that we have been facing THE COURT I think thats what Mr Link has offered MR SCAROLA I thought that thats what it was but I want that thats an important stipulation There ought not to be any ambiguity THE COURT Mr Link are you willing to stipulate that the actions brought by Mr Edwards on behalf of the three individuals that we have listed by way of either initials or Jane Dee that have been at center of this controversy were brought in good faith and that the allegations were well-founded MR LINK Theres a distinction and thats this Yes they were brought in good faith Can I say all of the allegations are true I cant say that Your Honor We never put them to the test because we couldnt I didnt represent Mr Epstein at that time so I think when you ask me would I say everything that was pled was true I cant say that THE COURT But you are saying youre willing to stipulate that they were all made in good faith MR LINK Yes sir absolutely THE COURT So stipulated Thank you That can be typed up and brought to the Courts attention if necessary during the pendency of litigation MR LINK Thank you Your Honor I hope my stipulation helped THE COURT All right we are up to number MS ROCKENBACH I think we were at I wish we were at THE COURT We did MS ROCKENBACH We did THE COURT I indicated that is the next highlighted one That again is a matter judicial notice and depending upon whatever evidentiary value it may have those are just answers in affirmative defenses in the civil cases against him MS ROCKENBACH Your Honor Im sorry I think we also objected to THE COURT I dont have it Palm Beach Reporting Service Inc highlighted MR SCAROLA I dont have it highlighted on mine either THE COURT Responses to requests for production requests for admission answers to interrogatories in this matter And then theres a list of about or so cases MS ROCKENBACH Those were not this case before you in division AG And this case number you can THE COURT Youre talking about AB MS ROCKENBACH Yes These are all cases cases I presume they are Your Honor perhaps Mr Scarola can tell us the relevance but they would not be relevant to this action Bringing in discovery from other lawsuits seems to be creating mini-trials again within this suit THE COURT Well depending upon the nature of the discovery and obviously depending upon its relevance to the lawsuit that we are dealing with here things like requests for admissions may be pursuant to the law transferable to a similar case Answers to interrogatories the same thing Those things that are stated under oath have a more concrete type of affect than those that are not stated under oath So whats your position Mr Scarola MR SCAROLA Let me just state broadly Your Honor that as has been acknowledged in earlier argument before the Court there is clearly an issue with regard to motive and intent on Jeffrey Epsteins part And it is our theory of the case that Jeffrey Epstein singled out Bradley Edwards because he was leading a joint prosecution effort that included a number of other lawyers prosecuting multiple other cases and that Brad was singled out not only because of his leadership role but because he faced a particular vulnerability And what Mr Epstein was attempting to do was to extort Bradley Edwards into either abandoning or compromising the interest of his clients and backing off on the prosecution of the Crime Victims Rights Act case which Mr Edwards was prosecuting on a pro bono basis almost independently He had the assistance of the University of Utah law professor Paul Cassell So his motive was to escape or reduce his liability in a large number of pending civil actions and to escape liability for an even larger number of potential criminal prosecutions While the limitation that Your Honor has described applies to the probable cause issue for the reasons that Your Honor has stated those reasons have no applicability when it comes to talking about motive and malice When it comes to talking about motive and malice I respectfully suggest the jury needs to understand why it is that somebody would take the risk of filing a malicious lawsuit what did he have to gain by doing that And what he had to gain was not simply to influence Bradley Edwards prosecutorial decisions with regard to three cases but to influence Bradley Edwards decisions with regard to a large number of other pending civil lawsuits and even more significantly a claim that could expose Jeffrey Epstein to spend the rest of his life in jail So thats the relevance and materiality that we have not directly addressed yet that does arise when we start talking about why are we going to be talking about all of these other claims Your Honor is right There are specific admissions included within those other pleadings But the mere existence of those other cases that were being prosecuted on a coordinated basis does make a very significant difference in terms of motive Thank you sir THE COURT Okay Thank you as well Again I am going to have to take these up on an issue-by-issue basis in order to determine the relevancy Thirty-five again are the answers to affirmative defenses in all civil cases against him Same ruling I am going to have to take those up on an issue-by-issue basis Thirty-six All complaints in which Epstein was a defendant same ruling I will have to take those up on an individual Palm Beach Reporting Service Inc basis In other words that means that Im going to defer The newspaper articles online articles or publications related to Jeffrey Epstein MS ROCKENBACH Number was not produced Actually Mr Scarola and I can get together and look at articles There might be some that I agree to MR SCAROLA They were produced in connection with Mr Jansens report You have a copy of every one of them MS ROCKENBACH Okay so Jansens report So then this exhibit goes to Mr Jansen which I have a motion to strike and preclude that is in draft form that I was working on last night So I think then perhaps the Court can take that up in the context of Mr Jansens testimony and that motion in that Mr Jansen is a damages expert that has testified about defamatory statements What I started to say is I would agree to some newspaper articles that my client relied on in bringing the original proceeding because he has testified that he relied on these newspaper articles that connected Mr Edwards to Mr Rothsteins Ponzi scheme and that formed in part the basis for his probable cause to originate the proceeding But as to the mountain of newspaper articles or periodicals or Internet hits that Dr Jansen reviewed and I guess are attached to his report that Im now hearing are Exhibit we would absolutely object to because they are not relevant in the malicious prosecution action MR SCAROLA If were going to take up Mr Jansen in response to a motion that we havent seen yet may I suggest that we take up Mr Jansen in response to a motion THE COURT At this point to try to marshal the number of articles online articles newspaper articles and publications related to Jeffrey Epstein is close to impossible so Im not going to get into that right now Report and analysis of Epsteins assets again likely goes to the punitive damages aspect Im not going to get into that now as well The video footage of the walk-through site inspection of Epsteins home is probably likely to closely resemble that of punitive damages although it may be also this issue of whether or not theres going to be an exception taken to strike that to any of the individuals who are at issue and their memory as to whether or not they recall what if anything maybe in or not in Mr Epsteins home and could be an issue of credibility and could be supported by way of the video Again I will take that up if that becomes an issue later on The properties cars boats and planes of Mr Epstein again could be taken up later if it becomes an issue Probable cause affidavits prepared against Jeffrey Epstein and Sarah Kellen same ruling I made earlier regarding probable cause If the affidavit was prepared against Epstein himself then its relevant unless it relates to any issues of Mr Edwards knowledge and his diligence and the like relating to his preparation of his cases Forty-five Documents relating to or evidencing Epsteins donation to law enforcement MS ROCKENBACH Irrelevant and prejudicial because then it reflects poorly Its an insinuation that our system can be purchased and thats just inappropriate Its not appropriate for a malicious prosecution action whatsoever THE COURT Well the likelihood again I am going to sustain the objection unless I find that something that might have something reasonably to do with this I understand the intent But again any probative value would be materially outweighed by the prejudice and the relevance Forty-six Victim notification letter from the U.S Attorneys Office to victim Again I think that more closely aligns itself with that victims rights case thats being brought Again I will sustain until such time Palm Beach Reporting Service Inc as I find it may have something to do with the issues I described earlier Mr Dennisons Dr Dennison Reeds report of victim Thats an expert I dont know what that is MS ROCKENBACH Ask Mr Scarola Psychological examination of L.R This is something that was in the federal court action THE COURT That was the same lady I tried to protect by not using her last name MS ROCKENBACH I apologize Your Honor and agree to strike that THE COURT Its stricken It will middle initial It may have been a two-part name Just identify her as L.R That would be the designation we use MS ROCKENBACH I fail to see the relevance of a psychological report THE COURT Same ruling Again it doesnt have anything to do with the three ladies involved here Palm Beach Police Department incident report Does that have anything to do with any of the three people here MR SCAROLA Im sorry Was that a question Your Honor THE COURT Yes MR SCAROLA I believe it does Again I dont intend to offer it until such time as I have established its relevance THE COURT Same argument And at this point thank you That will be sustained unless otherwise necessary MS ROCKENBACH I dont have copies of THE COURT Same thing with Same thing with Same ruling with regard to MR SCAROLA I would only point out when Your Honor is saying the same ruling Im sorry but Im really not THE COURT Sustained unless theres some reason for it to be provided as it relates to the three plaintiffs that Mr Edwards represented or it has to do with issues concerning his preparation his evaluation of the cases and all of the rest of those things that I have already indicated And that it would not be necessarily the contents of the exhibit but the ability to speak generically about the fact that he had those exhibits on hand when he did what he did MR SCAROLA Thank you THE COURT Thanks Same thing with same ruling Who is Alberto Pinto What does he have to do with this MS ROCKENBACH This is a contractor who my client hired to do a housing project There is no relevance We read the letter We provided it to the Court THE COURT Anything Mr Scarola on this MR SCAROLA Same position Your Honor THE COURT Same ruling finding it to be irrelevant unless otherwise shown to the Court to relate to issues pertaining to those that the Court has indicated or others that may come up later on down the line I am preliminarily going to sustain the objection Bank statements tax returns have to do with the punitive aspects I will defer on those MC2 emails MC2 is another person who has sued Mr Epstein MS ROCKENBACH I do not know that exhibit MC2 was the investing company that was defrauded by Mr Rothstein THE COURT I cant keep track MS ROCKENBACH No Thats not right I got that wrong I dont have these emails I dont THE COURT Can anybody answer who MC2 may be MR SCAROLA No sir THE COURT We will have to take a look at those at a different time At this point I will reserve DVD of plea and colloquy We talked about that earlier Sustained unless it becomes an issue we need to deal with later on Preliminarily its sustained Transcript of plea and colloquy taken on Same ruling Massage table Again unless it Palm Beach Reporting Service Inc becomes an issue as to one of these people indicating that strike that Somebody that may indicate that a massage was done someone denying the massage table ever existed I dont think its relevant Again it may come up as to massages being done and that type of thing but the actual table is a good exemplar of going beyond over the top of what we need to do here that is to bring the actual table Its not like those instances where a vehicle is actually brought into a courtroom or part of a vehicle is brought in for the jury to use the vehicle outside the courthouse The vehicle is the actual MR SCAROLA I dont anticipate bringing a massage table in sir THE COURT All right Thats good to know Thank you No contact orders entered against Epstein criminal score sheet regarding Epstein documents evidencing Epsteins community control and probation Epsteins sex-offender registrations MR SCAROLA May we stop there THE COURT Yes MS ROCKENBACH Before we stop Your Honor was about to rule on through THE COURT Sixty through is sustained for the reasons that Ive already earlier indicated on the record Sixty-three Epsteins sex offender registrations MR SCAROLA Yes as part of Mr Epsteins sex offender registration particularly in the state of New York Im not sure the extent to which it applies elsewhere he was obliged to disclose his ownership interest in vehicles airplanes and residences that is he had to list all of those things And one of the ways that we have identified Jeffrey Epsteins assets is through those sex offender registration disclosures that he was obliged make and did make So it has to do with punitive damages in addition perhaps to something else But it has to do with punitive damages in particular THE COURT I will take a look at that when the time comes if it comes at all Thank you Booking photographs Again same ruling as I made on the other matters regarding the criminal aspects of the case MR SCAROLA This would simply be a photograph Your Honor THE COURT Whats its relevancy MR SCAROLA Im not sure Mr Epstein is going to be here THE COURT Are you planning to subpoena him MR SCAROLA No sir No If he chooses not to be here I have videotaped deposition THE COURT Thats fine MR SCAROLA I want to be able to identify him as the person who got convicted THE COURT It could be duplicative of a video MR SCAROLA It may be Again I just want to explain to Your Honor thats why its listed THE COURT I will defer CAD calls C-A-D MR SCAROLA I cant tell you THE COURT Sustained MS ROCKENBACH I have a copy of the exhibit that Mr Scarola provided They are Palm Beach Police Department THE COURT I have already sustained the objection for reasons that were indicated earlier List of Epsteins house contacts You have that one MS ROCKENBACH I do May I approach Your Honor THE COURT Sure MS ROCKENBACH Its a document titled Vehicles Mail Deliveries May I retrieve these THE COURT This looks like his vehicles grocery stores that he shops at health and beauty utilities storage mail and delivery services maintenance travel banking bicycles bookstore cleaning service Entertainment Breakers comedy Palm Beach Reporting Service Inc corner Mar-a-Lago It goes to different servicing companies such as extermination type of thing It has a list of names and numbers Okay again the same ruling that I made earlier and that is that it would not be relevant except for issues that I have discussed earlier that may impact upon particularly Mr Edwards diligence what he had particularly at the time of his employ with the Rothstein firm and those things I have already mentioned in the record Documents related to Epsteins investments would be a punitive damage issue that we will take up at a later time Letter from Chief Reiter from the Palm Beach Police Department to Barry Krischer it should be instead of Krischler I presume MS ROCKENBACH Thats correct Its dated May 1st THE COURT Let me take a look at it Sixty-nine is a list of planes owned by Epstein That would be again reserved if necessary for the punitive damages component of the case Did you see these letters MR SCAROLA Its been a long time THE COURT I couldnt imagine what relevancy it would have to do with this Unless you can provide me any additional information its sustained Fronstin Was he one of Mr Epsteins attorneys at one time MS ROCKENBACH Yes Your Honor And these all are Exhibits are all letters from MR SCAROLA Im sorry Im having difficulty doing two things at once Im reading this letter I would like I would like to comment that the Palm Beach Police Department was the principle investigating agency with regard to these claims And obviously the chiefs position with regard to these claims is reflective of the quality of the claims that was called into question in the complaint by Mr Epstein So to the extent that Mr Epstein is aware of the fact that the chief investigating office through its chief is challenging the way in which his cases are being treated is relevant and material with regard to his taking the highly unusual step of filing a baseless malicious claim against Bradley Edwards that is Mr Epstein filing that claim against Bradley Edwards THE COURT Im sorry MR SCAROLA Mr Epstein knows that he is facing very substantial jeopardy And that letter is corroborative of that Its part of what he knows when he files the claim THE COURT The objection is sustained MS ROCKENBACH The next set of items through they are all letters from Mr Epsteins lawyer Guy Fronstin prior counsel to the assistant State Attorney Lanna Belohiavek from the Office of the State Attorney They are all different but they all relate to for instance Exhibit Number is a disclosure of third-party attorney fee payment where my client had offered to pay for his house manager who was going to be giving a statement to the assistant state attorney And it was in compliance with ethical rules It actually is but it has no relevance Thats the point It actually is a good thing but here it shouldnt come in because we are just getting too far astray I have these documents and these folders if Your Honor would like to look at them MR SCAROLA Part of what all the attorneys prosecuting claims against Jeffrey Epstein were dealing with including Brad Edwards was the degree of control that Mr Epstein was exercising over various witnesses And those letters evidence the degree of control that Jeffrey Epstein was exercising over various witnesses who were part of the then ongoing criminal investigation That is why such things as the depositions of pilots and the subpoenaing of flight logs and the necessity to try to find third parties who were not under Mr Epsteins influence to give sworn testimony concerning what was going on on airplanes became necessary Palm Beach Reporting Service Inc MS ROCKENBACH They may be relevant if we were trying Mr Edwards cases that were settled They are not remotely relevant in this action THE COURT I tend to agree Again for the same reasons that I ruled earlier I sustain the objection to these letters from this attorneys Mr Epsteins attorneys to the assistant State Attorney Mr Goldbergers letters MS ROCKENBACH May I approach Your Honor It is dated June 22nd THE COURT Off the record A discussion was held off the record THE COURT I made an error confusing Mr Salnick with Mr Krischer I apologize to them both So I will need to take a look at that letter from Chief Reiter again and see if it changes my thought process in that regard MS ROCKENBACH Your Honor I have it if you want to take another look It encloses a probable cause affidavit and case filing packages from the police department Palm Beach Police Department from the chief of police THE COURT Sure Sorry about that Im going to take the same position as to number so its sustained for the reasons I have earlier indicated Number the letter from Mr Goldberger to Mr Krischer Do you want to comment Mr Scarola MR SCAROLA No Your Honor Same argument THE COURT Same ruling Im going to sustain it Also it carries with it the potential of Mr Goldberger having to be a witness I just dont see it as necessarily even tangentially related to the three cases that we have I dont know if one of these young women were part of this The one who is described here is not listed even by initials so I will take the same position I have taken earlier MS ROCKENBACH Your Honor number Im not sure if you need the packet but its subpoenas that were issued THE COURT No Its the same ruling I have made earlier with regard to other matters concerning the criminal file MS ROCKENBACH Thank you THE COURT The documents related to the rental of vehicles for Vanessa Zalis Who is she MS ROCKENBACH I dont know that I would have to have Mr Scarola explain why rental and I dont even see rental agreements I would expect to see a rental car Alamo Hertz or something This document that was produced is FedEx labels priority overnight FedEx labels to my client at his Palm Beach residence with a handwritten note and it says Contract up on February 2nd Then it has a handwritten note Dollar Rent a Car No relevance THE COURT I dont know who this is Do you have any idea who we are talking about here MR SCAROLA Same argument THE COURT Same ruling Ted Shed MR SCAROLA Same argument THE COURT Same ruling Documents related to the property searches of Jeffrey Epsteins property MR SCAROLA Same argument THE COURT Same ruling Arrest warrant of Kellen MR SCAROLA Same argument THE COURT Same ruling Police report regarding Alexandra Hall picking up money dated MR SCAROLA Same argument THE COURT Same ruling These are all sustained unless shown to the Court later that theres a particular relevance to any of these documents Thats the same ruling I have indicated Eighty-two List of Trilateral Commission Members of Do you know what that is MS ROCKENBACH I still dont even after looking at the document But it is on a website Bible Believers.org a nine-page document with individual names of people THE COURT Its refreshing the Bible is being mentioned during all of this MR SCAROLA Same argument Palm Beach Reporting Service Inc THE COURT Same ruling Alan Dershowitzs letter dated April 19th and statute I guess this has to do with similar activity Same argument MR SCAROLA This is slightly different Your Honor This has to do with the allegation that there was a significant change in the approach to prosecution of these cases after Brad Edwards was employed at RRA And one of the elements that is cited to is that he begins to take discovery with regard to other victims In fact there were multiple activities that occurred prior to Brads employment with RRA that were directed at the discovery of matters relating to other victims And the federal statute requires that a notice be given to the other side of the intent to rely upon evidence with regard to other victims THE COURT Did you take Mr Dershowitzs deposition as it relates to this case MR SCAROLA No sir But I have had the pleasure of deposing Mr Dershowitz THE COURT Not as it relates to this case MR SCAROLA No MS ROCKENBACH I do not have a copy of the letter Your Honor It was not in production THE COURT I will defer on that one Fronstin letter Again goes with the same protections that I earlier indicated I will sustain Epsteins account information MS ROCKENBACH I dont know what that means It was not produced THE COURT It will have to be produced in the meantime MR SCAROLA Yes I hope it will be It is listed although it has not yet been produced by Mr Epstein in anticipation of his being ordered to produce it THE COURT Eighty-six Epsteins criminal close-out sheet will again be sustained for reasons earlier stated on the record The JEGE passenger manifest number is Hyperion Air passenger manifest Same ruling Same thing with the flight information Eighty-nine Passenger list same ruling case Notepad/notes Maria MR SCAROLA Same argument THE COURT Same ruling Pleadings of Jane Doe and vs US MR SCAROLA Thats the CVRA case Your Honor THE COURT That will likely be discussed obviously it will be discussed How much of the pleadings that need to be addressed will be a matter of the Courts consideration later Epstein Fifth Amendment speech MR SCAROLA Those are just a reference to deposition excerpts THE COURT Reiter letter to Krischer Thats already been talked about Thats a duplication unless he wrote another one I think its a duplication You can check MR SCAROLA Sixty-eight isnt dated This one is dated I dont know whether theyre two different letters or the same one Your Honor MS ROCKENBACH Ninety-four It was not produced to me THE COURT Im going to assume that its the same unless its produced separately And it will be ordered to be produced separately within days if not already done Just like anything else Im ordering it be produced that I may have ordered in the past within a 15-day period Ninety-six police report Same ruling same position taken by Mr Edwardss counsel Victims individual says victims not plural school records and transcripts I dont know which victim youre talking about Maybe its the young lady who was the model student as discussed earlier allegedly prior to Mr Epsteins involvement MS ROCKENBACH Palm Beach Reporting Service Inc THE COURT Shes not one of the people involved here today MS ROCKENBACH Thats correct THE COURT I will sustain it MS ROCKENBACH Your Honor if I may I think I have a sampling of this exhibit All the pages I have in front of me say Shana THE COURT Ninety-seven would be the same ruling Ninety-eight the same ruling Ninety-nine the same ruling One hundred All surveillance conducted by law enforcement on Epsteins home Same ruling One hundred one Emails received by Palm Beach Records related to Jeffrey Epstein Who is Palm Beach records MS ROCKENBACH I dont know and I dont have the exhibit It was not produced THE COURT Again to be produced At this time sustained Same ruling One hundred and two All items listed on the Palm Beach Police Department property report lists Same ruling One hundred and three All copies of convictions related to Epstein I have already ruled on that at least globally that until further inquiry is done and further information is received regarding the pleas and to whom they apply I am not in a position to make definitive ruling on that One hundred and six strike that One hundred and four is Jeffrey Epsteins criminal records That mirrors some of the things Ive indicated It would be sustained pending further inquiry or review based upon reasons stated already by the Court One hundred and five All documents produced by Palm Beach Police Department prior to the deposition of Detective Recarey R-E-C-A-R-E-Y Again same ruling Im just going to ignore Its a catch-all I usually dont rule on any way One hundred and thirteen All pleadings and attachments in the action under the Crime Victims Rights Act prosecuted by Edwards on behalf of victims of Epsteins criminal molestations As I have done earlier to be consistent I sustain the objection because of its breadth lack of specificity without prejudice to specific documents being provided within days to the attorneys for Epstein MR SCAROLA Im sorry We are talking about THE COURT Yes MR SCAROLA They have all of those Your Honor Mr Epstein entered an appearance in the case He was permitted to intervene so they have got all of those pleadings Theyre also THE COURT Thats fine But I could imagine that in I think somebody mentioned eight or nine years litigation Mr Goldberger pointed out earlier not every one of those documents are going to be relevant here So whatever the plaintiff is seeking to introduce as a result of that should be culled and should be provided to the other side MR SCAROLA And my response to that is as I stand here right now I dont know I am listing it because it is potentially relevant Theres obviously been a lot of discussion to the Crime Victims Rights Act case And if Your Honor wants me to duplicate everything thats been filed in that case THE COURT Thats not what Im suggesting Mr Scarola What Im saying is the problem that I have and how I usually rule on these matters is that when a file is identified as all pleadings and attachments particularly whereas here your client is an attorney who is the lead attorney in the prosecution of the CVRA claims then he should be aware of what would be relevant as it relates to his malicious prosecution claim against Epstein Not all of those documents will be relevant I wouldnt expect a defendant in a malicious prosecution claim Epstein to have to review the attorneys in Palm Beach Reporting Service Inc particular having to review all the documents and guessing which ones may or may not be introduced or sought to be introduced or considered to be introduced So thats the issue that Im dealing with They must be culled and they must be provided to them days maybe a little short in light of the holiday season so Im going to give you days MS ROCKENBACH Thank you Your Honor MR SCAROLA May I simply state that at this stage in this litigation not knowing what Mr Epstein is going to attempt to say with regard to the defense that every pleading in the Crime Victims Rights Act case is potentially relevant And every one of those pleadings is available on PACER And he is a party to the litigation So to comply with the Courts order I dont want to do something that Your Honor is telling me I ought not to do But to comply with the order as you have described it I would simply duplicate every pleading in that case that is on PACER so that I have the flexibility to introduce whatever I may need to THE COURT Thats why my suggestion is it would be that the objection would be sustained as the exhibit is phrased It would be the same thing if you were to stand here today if we were in trial and say here are the docket entries to the Crime Victims Rights Act case and I want the jury to review all docket entries which comprise pages I would say No it is not specific enough No the jury is not going to go through all of those without exactly knowing what they are looking for And so as phrased the objection is sustained I have given you the opportunity to otherwise remedy the situation But if thats the response that Im getting and I respect that then thats the ruling of the Court One hundred fourteen MR SCAROLA Im sorry Again I would in light of Your Honors comments THE COURT It was actually a ruling MR SCAROLA Yes sir In light of the Courts ruling and I dont mean to be arguing after the ruling I only want to understand it What I would do is I would take and I would have a separate listing of every pleading on PACER and I would produce every pleading on PACER And I dont want to do that if Im doing something that Your Honor believes that I ought not to be doing THE COURT The reason why I say that is number one we already have enough paper thats involved here Number two clearly in my view whether were dealing with a set of medical records whether were dealing with a set of psychiatric records admissions to hospitals admissions to psychiatric facilities rehabilitation facilities I have seen thousands of documents Ive done in camera inspections of thousands of documents I have culled from them probably often out of thousands of documents pages of what I believe to be relevant There are a number of documents that deal with food that was eaten by a given individual per day that has no relevancy at all whatsoever with the treatment There are other things that I cant think of right off the top of any head But while they have to be documented by the hospital they have to be documented by the rehab facility they are not necessarily relevant to the inquiry at issue and can be culled out What Im saying is with your client being the lead attorney on that case despite Mr Epstein being an intervener of some nature in that case its still incumbent upon the party offering the exhibits to present the most narrow compilation And that is what Im requiring you to do I gave you and your client days to cull those documents that in good faith are going to be sought and be admitted not the entirety because the likelihood of me admitting all of the docket entries over an eight-year period or nine-year period whatever it might is highly unlikely Palm Beach Reporting Service Inc because of jury confusion because of time and consideration of the jurys time when it comes to that MR SCAROLA And I would never offer it all THE COURT So thats exactly what Im trying to say The 30-day lead time that I am giving is in consideration of the amount of documentation that would have to be reviewed and that since Mr Edwards would likely be in the best position to be able to cull out those documents that would reasonably be calculated to be introduced into evidence So thats the order of the Court If you take me up on it thats fine If you dont then again I am sustaining the objection as phrased in number So thats with the caveat that I have described and offered to you MR VITALE Your Honor with regard to you had given us days to produce Would that also be extended to days given the holiday THE COURT No because again everything other than what I have just come up with I think you already should have produced it And if it hasnt been then that should be days The Crime Victims aspect is much lengthier and comprises seven or eight years of litigation The exhibit list was compiled and sent out on November which is about three or four days short business days short of a month so they already should have been produced but have not So those things that Ms Rockenbach is suggesting havent been that would be days other than number Number Edwards Motion for Summary Judgment The Court would like to take judicial notice MS ROCKENBACH I dont know that its an exhibit for the jury to consider This might go to I think Im guessing it was going to go to a legal argument before Your Honor as to whether there was a bona fide termination when my client dismissed the original proceeding that he brought against Mr Edwards THE COURT Perhaps If its an issue of fact then it will be overruled Mr Scarola you want to get heard MR SCAROLA Thats exactly what I was going to say Your Honor If they are contending that theres an issue of fact as to whether there was a bona fide termination then the circumstance under which the voluntary dismissal was taken is obviously relevant and material What it was that was Jeffrey Epstein declined to defend against is relevant and material THE COURT It is overruled One hundred and fifteen is time records and hourly billing documentation produced in discovery Is that Mr Edwards claim of lost time and that type of thing MR SCAROLA Yes Your Honor THE COURT Well that may come in as far as damages to the malicious prosecution claim Have you received any of that yet MS ROCKENBACH I have a circle here meaning that it was not produced in the context and pursuant to the Courts order THE COURT You might want to get with Mr Vitale and see if you can MR SCAROLA It was produced prior to Mr Epsteins deposition In response to a request for production all of those time records have been produced THE COURT Again as I said with regard to the documents have to be culled to some degree so that it can be given to the other side as the exhibit thats being sought to be introduced at trial At this time it may still be going on so it may not be completed up to the time of the trial Just like medical records sometimes if theres ongoing treatment even though somebody is at maximum medical improvement but they are still treating there could still be a continuing type of exhibit MR SCAROLA These are time records of Mr Edwards time devoted to the defense of the maliciously filed claim Once that Palm Beach Reporting Service Inc claim was dismissed he was no longer devoting time to the defense of the claim Those records have all been produced They have been specifically identified He has segregated out time spent in defense of the case from anything else and they have that exhibit But if they need it to be re-produced to them again and Your Honor directs that we need to re-produce it again we will reproduce it again THE COURT Again Im not directing another reproduction Perhaps as I said Mr Vitale can handle that issue with Ms Rockenbach and it can be taken care of without further judicial intervention I am sure it can Next is all claims filed by Epstein in the Rothstein bankruptcy proceeding I would have to see those when the time comes All submissions by Epstein in connection with the Rothstein deposition Again I will see those when the time comes if necessary I will defer on those two All settlement agreements between Epstein and victims of sexual molestations Again I would have to see those when the time comes I am most interested in the three individuals at issue MR SCAROLA Your Honor there have been objections that have been raised to the production of those documents on the basis of a contractual confidentiality provision If the allegation remains that these cases the three at issue were somehow ginned up then the value of the claims in general is at least discoverable with regard to making a determination as to whether the claims were ginned up And again the degree of financial exposure that Mr Epstein was facing is reflected by the settlements of all of the claims that he ultimately settled after the filing of this maliciously allegedly maliciously prosecuted lawsuit So we will be asking the Court to compel production of all of those settlement agreements THE COURT Thats something that probably will need to be dealt with probably at a special-set hearing So I would suggest that we set something in the near future for a half-hour hearing so that we can deal with those issues independently I think its worth some time to be taken Phone journal taken from Epsteins home and produced to the FBI by Rodriguez Thats the houseman Same ruling as I made earlier with regard to that Photograph depicting Roberts Maxwell and Prince Andrew MS ROCKENBACH No relevance to this action Its prejudicial THE COURT Same argument Mr Scarola MR SCAROLA Yes sir Same argument THE COURT Sustained unless further information develops to bring to the Court otherwise All flight logs We talked about those before Same ruling Evidence of contributions to the Palm Beach Police Department Sustained Same ruling MR SCAROLA Yes sir I did speak of that the source of information regarding his assets THE COURT And I think I deferred on that If I didnt thats the way Im going to deal with it One hundred and thirty-two New York Post article Billionaire Jeffrey Epstein Im a sex offender not a predator February MR SCAROLA These are direct quotes from Mr Epstein Its the article in which he compares the abuse inflicted upon children as the equivalent of stealing a bagel THE COURT Unsworn statement out of court being used to prove the truth of the matter asserted MR SCAROLA No sir Being used to prove the fact that the statement was made being used to prove the state of the speakers mind and being used for purposes of the jurys assessment of punitive damages We dont contend that molesting children is the equivalent of stealing a bagel Palm Beach Reporting Service Inc If we were introducing this statement to prove the truth of the matter asserted we would be advocating that molesting a child is the equivalent of stealing a bagel THE COURT No Im not sure thats the way that the hearsay rule is implemented Ms Rockenbach your position MS ROCKENBACH Thank you We did raise hearsay We raised relevance We raised probative value substantially outweighed by the danger or unfair prejudice confusion misleading the jury as well as hearsay and authenticity This is a very good example of an inflammatory exhibit by Mr Edwards and it seeks to try to prove I guess that my client is a bad person or bad character evidence under This is hearsay and it should not be admitted It would be inflammatory and very prejudicial to my client THE COURT Any request for admissions sent out in response to that article MR SCAROLA There may have been There certainly were deposition questions concerning whether Mr Epstein made statements to any third party regarding any of his molestation claims and he asserted the Fifth Amendment with regard to those So we would have the benefit of an adverse inference in that regard And the statement of a party opponent is not a hearsay statement Im sorry Theres an exception to the hearsay rule for the statement of a party opponent But it also goes to state of mind And clearly the offenders attitude about the offense he committed is highly relevant in a punitive damages claim THE COURT I recognize the party opponent issue Again its application is of concern to me in this particular context where the information comes from a newspaper So I would have to take a look at it Maybe we can set that at the same time we are going to set that other issue about the other victims information MR SCAROLA I can assure you that if Mr Epstein does show up for trial one of the very first questions Im going to ask him is Did you make this statement to the New York newspaper THE COURT Like I said we will take that up when time comes We can further discuss the objections at the same time we are going to be discussing the all settlement agreements All right MS ROCKENBACH Thank you Your Honor THE COURT Thanks a lot to our court reporter for staying and working through this as we have today MR SCAROLA I assume that we are going to deal with Fifth Amendment issues as the first issue when we reconvene THE COURT Well I thought we talked about those already MR SCAROLA No no You remember that I identified every question and answer THE COURT You are talking about the individual questions and answers Yes sir Absolutely And we will take those up first and then we will go to the motions to compel and motion for protective order if we have the time okay Remember on Thursday were pretty much going to limit us to the morning So we are going to from to then that will be it Okay So try and govern your arguments accordingly if you would please I am going to give you these materials back Mr Scarola as I said Im going to impose upon you to prepare the orders as I have already indicated Im not sure at this point since we do have these actual questions that we can really prepare an order until we get this done on Thursday as to the Fifth Amendment global rulings that the Court has already made And it may become more focused and be more specific once I have had an opportunity to go through all of these And I appreciate the fact that you have done that and gotten them to me In the meantime what Im going to do is Im going to keep some of this material MR LINK Judge thank you for your time today We appreciate your patience for Palm Beach Reporting Service Inc EXHIBIT 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 ORDER ON PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEINS REVISED OMNIBUS MOTION IN LIMINE SECTION EDWARDS TRIAL EXHIBITS THIS MATTER came before the Court for hearing on November and December upon Section Edwards Trial Exhibit List of the Revised Omnibus Motion in Limine filed by Plaintiff/Counter-Defendant Jeffrey Epstein Epstein D.E The Court having reviewed the Motion and the Response filed by Defendant/Counter-Plaintiff Bradley Edwards Edwards D.E I having heard argument of counsel and being otherwise fully advised in the premises it is hereby ORDERED AND ADJUDGED that Epsteins Revised Omnibus Motion in Limine was directed at Edwards Amended Exhibit List dated November D.E On December after two days of hearing and substantive Court rulings Edwards filed a Second Amended Exhibit List D.E identifying new items and modifying some of his earlier disclosed exhibits This Order only addresses the exhibits identified on Edwards November Exhibit List To the extent any exhibit numbers have been replaced with different items or new numbers have been added those will be subject to a separate Order after the appropriate motion and hearing The rulings set forth herein for all exhibits disclosed on Edwards December Second Amended Exhibit List that have not been modified will remain unchanged 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 EXHIBIT 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 EXHIBIT 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 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 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 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