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 TO COMPEL AUDIO RECORDING Plaintiff/Counter-Defendant Jeffrey Epstein Epstein moves to compel Defendant/Counter-Plaintiff Bradley Edwards Edwards to produce the April audio recording of the telephone interview of Virginia Roberts and in support thereof states Introduction Epstein requests this Court to compel Edwards to produce the audio recording of the telephonic interview of Virginia Roberts taken April Pursuant to the best evidence rule the audio recording must be produced Epstein appropriately requested the audio recording and Edwards has failed to timely produce it Epsteins Discovery Request for Production of Audio Recording On May Edwards in support of his Motion for Leave to Amend to Assert a Punitive Damages claim filed the transcript of an April telephonic statement of FILED PALM BEACH COUNTY FL SHARON BOCK CLERK PM Virginia Roberts a copy of which is attached as Exhibit A The transcript indicates that Ms Roberts was being recorded Id The audio recording should have been produced in response to Epsteins December Request for Production In that request Epstein asked Edwards to produce Witness statements you intend to use in this case Exhibit Request No Documents were defined to include recording of sound Id Instruction No Although just a few months before the Request was served Edwards filed the transcript of Ms Roberts telephonic statement on which he relied and in fact used in this case Edwards responded None to the request Exhibit Request No This Courts Recent November/December Rulings Prompted a Second Request for the Audio Recording Undersigned counsel appeared in this case on November At the November and December and hearings the Court made rulings that impacted how this matter will be tried In addition during those hearings Edwards counsel stated that he would be calling Virginia Roberts an alleged victim of Epstein but not one of Edwards three clients E.W L.M or Jane Doe to testify live at trial As a result on January Epsteins counsels office made a request to Edwards counsels office for the audio tape of Virginia Roberts April telephonic statement Exhibit Edwards counsels office has ignored this request Furthermore Edwards Second Amended Exhibit List No identifies Statements deposition transcripts videotaped depositions and transcripts taken in connection with this and all related cases and exhibits thereto Exhibit No While Ms Roberts April telephonic statement was used in this case Edwards has not produced the audio portion Epsteins counsel was not present during Ms Roberts April telephonic statement Furthermore from the face of the written transcript it cannot be determined whether the statement was given under oath nor does the transcript identify who transcribed it Florida Evidence Code Requires Production by Edwards of the Best Evidence Section Florida Statutes of the Florida Evidence Code provides that an original writing recording or photograph is required to prove the contents of the writing recording or photograph See also Lawrence State So 2d Fla 1st DCA holding that a tape recording despite an available transcript and no dispute as to the tapes audibility was still the best evidence of the tapes contents Because the audio recording is the best evidence is in Edwards possession and properly requested by Epstein Edwards should be compelled to produce the audio recording See Duggan State So 2d Fla st DCA tape recordings of written transcripts of tape recordings were the best evidence Accordingly Epstein respectfully requests that the Court compel Edwards to produce the audio portion of Virginia Roberts April telephonic statement 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 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 Bradley Edwards Marc Nurik Edwards Pottinger LLC Law Offices of Marc Nurik Andrews A venue 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 Atterbury Goldberger Weiss P.A Australian Avenue Suite West Palm Beach FL goldberger agwpa.com smahoney agwpa.com Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein EXHIBIT A 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 I Qi NOTICE OF F1L COMES NOW the Defendant/Count rC BRADLEY EDWARDS by and through his undersigned counsel and he the attached transcript of the telephone interview of Virginia Roberts to sumt lie proffer made in support of Counter-Claimants Motion for Leave to Amend itive Damages I HEREBY CERTIFY tlia true and correct copy of the foregoing has been furnished by U.S Mail to all Counse attached list on this day ofMay CJ Jack Scarola Florida Bar No Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida Phone Fax Attorney for Defendant/CounterClaimant Edwards Edwards adv Epstein Case No Notice of Filing Supplement COUNSEL LIST Jack A Goldberger Esquire jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss P.A Australian Avenue So th Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Farmer Jaffe Weissing Edwards Fistos Lehrman PL Andrews Avenue Suite Fort Lauderdale FL Phone Martin Weinberg Esquire Martin Weinberg P.C Park Plaza Suite Suffolk MA Attorneys for Jeffrey Epste jY Joseph Ackerman Jr Esquire Fax Attorneys for Jeffrey Epstein jla fowler-white.com Fowler White Burnett P.A Phillips Point West f4 Flagler Drive West Palm Beach FL Phone Fax i Attorneys for J1frey Epstein SN arc un I marc nu om Law,OJfices..;.ofMarc Nurik One Bt;9ward Blvd Suite Fort Lauderdale FL Phone Fax Attorneys for Scott Rothstein PRIVIl,EGED PURSUANT TO FS and/or WORK PRODUCT TELECON PARTICIPANTS JACK SCAROLA BRAD EDWARDS VIRGINIA ROBERTS RE Edwards adv Epstein DATE April JS BE JS JS JS Virginia Jack Scarola and Brad Edwards Hi Virginia Hi Jack Hi Brad How you guys doing Were doing fine thank you Im.,e of the trouble and before we go any further let me tell you if I have you sion I have started a tape recorder and I want to be able to tape this conversation from the very beginning Is that alright with you Sure thats fine Jack pro eki Ok good thank you eciate that Let me start off by introducing myself I know that Brad has spbke you about me but I am Brads lawyer and I assume that you can confinn that you have never had any communication before Is that right Thats have however gotten some infonnation from Brad about conversations that ave had with him and that will enable me hopefully to make this a little bit more Lc nt and take up a minimum amount of your time while still getting the information tnat we think is going to be helpful to us and to any jury that might ultimately have to hear these facts So let me begin by asking you first to tell us what your full name is Louise Roberts Thats my maiden name My married name is Virginia Louise Edwards adv Epstein Telephone interview with Virginia Roberts Page2 of23 JS JS JS JS JS JS JS Could you spell your last name for us That is your married last name Alright thank you and where are you living right now I live in Australia That is where you are right now correct Weve reached you tralia for this phone And how long have you resided in Australia This is my th year conversation That is correc yes And what time is it in Australia right now I think its about now A Ok Thats 9am correct Thats correct Alright Virginia the re conversation is because it is our understanding that you know a man by thrnam ffrey Epstein and I want to begin by asking you please to tell us about the circ bs of your first meeting Mr Epstein Ok I was intro uc to Mr Epstein by Ghislaine Maxwell I was working at Donald Trumps spa in a-Lago and I was prompted by Ghislaine to come to Jeffreys mansio n.z lm each that afternoon after work to make some extra money and to learn abo assagj She met me at the spa and I was reading a book about anatomy so I was alre i erested in massage therapy as it was and not having any of the education or yb KUQ anything behind me I thought this was a great opportunity to work for her and I went to Jeffreys mansion about or in the afternoon My dad drove me My dad worked at Mar-a-Lago with me and he met Ghislaine and she seemed like a nice proper English lady and she knows I mean you know one time then _once before I left to travel overseas she just seemed really nice and like she would like to help me out So my dad left and I had no problem getting home that night one of her drivers would take me back after my trial So she led me upstairs and into Jeffreys bedroom and past that is Jeffreys massage room which has got his steam room and a shower and a massage table and there is actually an extra room that has that nobody knows about it its kinda like a secret room and its got a whole bunch of decorative pictures of pornographic literature and sex toys and I can_?_ what happened there Edwards adv Epstein Telephone interview with Virginia Roberts Page of23 JS JS JS JS When you say that the room was hidden Virginia how was the room concealed It wasnt like a door that you would normally go into like some kind of special opening you open that and then a little door so it looks like its a little closet so-to-speak but when you walk in there its obviously a lot bigger than just a closet It wasnt too big but it was bigger you know It wasnt a gigantic room it was just like a ll room which you know it probably could fit some shoes in there _it had racks of 0oxes some sweatshirts neatly folded and the ceiling to the floor was covere omggraphic pictures of the girls that he had met When you say So anyways that was getting there and I was introduced to Je Aie was laying naked on top of the massage table and obviously for one Im iear old girl and seeing him on the table was weird but also learning about anafo massage I thought this would be part of it So obviously I thought it wa tne massage program so I said ok this is fine And he then instructed me QOW ouch the body Jeffreys body how to massage him and for the first hour,lfw Jlc ally a real massage maybe not an hour maybe like minutes or something mething like that _and thats when he turned over on the other side and to expp.o tJni 265self fully So then Ghislaine told me that she wanted me to undress and beeyn to off my shirt and skirt my white uniform from Mar-A-Lago she also took of rt and got undressed and so I was there with just my undies on and she was_ leJefy are and made some kind of little flake about the underwear that I was aring cause 1t wasnt my normal sexy girl underwear and just like I dont know cl arts on it or something like that just your normal you know real cute unde pyways so during all of this Im kind of like whats going on how do I act wha say I was so afraid of not afraid or fearful for my life but _unsure of ho all this started and wanting to obtain a profession_ I was so afraid thinking about se and disappointing them I dont know its a weird situation by far and as exp cted to _Lick his nipples instructed on how to do so by J.E_ and give him ora while he wanted to fondle me and then at the end I was told by Ghislaine to get sto straddle Jeffrey sexually and when we were done we went and had a sho er the room and Jeffrey told me to wash him up and down you know with a bar ba make sure he was all cleaned up And then he took me downstairs and took to two of the guards and told John to bring me home John was the butler at the time Let me interrupt you for just a moment there if I could Virginia You mentioned as you were recounting those details that you were years old at the time What is your date of birth August th And can you tell us please as best youre able to estimate it what the date was when this first encounter occurred Edwards adv Epstein Telephone interview with Virginia Roberts Page4 of23 JS JS JS JS Ive got it written down Its like Im not good with math hold on I thought I wrote it down but I didnt Im not too sure I think it was off the top of my head and around June of I would say as I was turning at the end of the summer Alright You talked about the room where Jeffrey had the pornographic photographs Did you actually see that room on occasion of your.first vi it there1 No I got to see that room a few v1s1ts after but I was Just trymg to des tloom to you guys so you knew exactly what room I was talking about Another question for you and I dont mean to be prying into br life and if I ask you any questions at all that youre uncomfortable answering tJ:ien you just tell me that and well move on because I appreciate your cooperation the last I thing I want to do is impose upon that cooperation but can you tel ase just generally what kind of sexual experience you had had prior to this confront_a ith Jeffrey Yeah sure A close family friend has sexua ll and I was on the streets at years old I was picked up by a year old A eel Ron_ Eppinger_ who did exactly what Jeffrey did with me abuse and viol yo thfulness I was with him for months So he was gone then cR t;YIDend who was like my school friend from young days but we Just kep nta_p with each other and we were on and off constantly and that was Tony etou and there was also another younger guy was near my age Michael I can blr his last name but yeah there I mean there wasnt like a string of men efa.nyt.Qipg but there was Ron like I told you and he was the first guy expecting mt:e to-a 9?called disgusting affairs Jeffrey actually knew Ron which was quite weir whe rold Jeffrey the story about Ron and Jeffrey had actually met him and yeah just another story and yeah there were a couple of men but that gives ea Now wh ou cribed the photographs in the room as pornographic tell me just a little bil a the photographs if you would please First how many of them were ther k4 and like I said they covered the room from the ceiling not the ceiling but 4lrorth.the top of the edge of the wall to the bottom of the floor I want to say at least a ftvndred even more there could have been more in the boxes _Some of them were photographs like the large size some of naked women posing you know positions sexy positions Others were you know some girls had bikinis on and it wasnt so pornographic but it was all women and it was all in a sexual nature Were there photographs where more than one person appeared Oh yeah plenty of them There were lots of naked photographs I mean I was just trying to give you a visual range There was anything from 5x6s to 4x8s to 8x4s Some of them Edwards adv Epstein Telephone interview with Virginia Roberts Page of23 JS JS JS had frames some of them were out of frames but they were all like I said they were all women they were all sexual in nature Was it your impression that there were a hundred photos of a hundred different people or were there multiple photos of the same woman or girl There was definitely a lot of different girls I mean it wasnt easy to sit ther and say you werent finding girls out of some photos no Were there a hundred di Qt ones There could have been pictures of some girls I really couldnt get clo eces,sarily to actually cognize fa es_ or anything like t_hat But if you you kn f._li ge of them were all different maJonty of them were different yeah Did there ever come a point in time when you became awar photograph of you had been added to the collection Yes there was Ghislaine took several nude photo me for Jeffrey So yeah there were pictures of me and there were pictur snt shy that wasnt the only place in his house that he kept the photos I likeq,..,plfotos all over his house If you looked in his den or on his desk or in on th al ole a giant hall table in his house there were at least a hundred photos of 1i es Not all of them were naked a lot of the ones that were all around his erc;;not naked girls posing pornographically some were pictures of celebrities ticj he had known_ or things like that or had pants on or whatever but yeah the wayr lot of mixed photographs in the outside ones Were there any pho ogra h"s of ir or young women that you knew or that you subsequently came to kn hat saw in the house Yeah yeah there ere was pictures of Nadia Bjournik pictures Sarah Keller ctures inmy pictures of me pictures of the regulars but a lot of the girls sometimes could have like girls a day and he would only see those girls once if ot bolyi I dont know These werent my days I heard hes gotten a lot sloppie I left So I dont know anyways but when I knew him there was just a it seepe Jher as such an influx of girls coming in and so did I_ recognize a lot of the yfaybe maybe not but then they were all defirutely beautiful they were all ng,-ili age some of them young some of them older in their I mean it was just Were all beautiful JS Youve told us about the first visit Was there any discussion on the occasion of that first visit about your returning Yes they were very pleased with me and after the encounter was finished the sexual encounter he went and told me I did well and I have a lot of potential to become a massage therapist and if Id like I could return tomorrow you know and do the same thing and get paid so Jeffrey insisted that I come after work and over the next few days I guess the relationship grew into more and within a couple of weeks not even Edwards adv Epstein Telephone interview with Virginia Roberts Page of23 a couple of weeks maybe a week I had quit Mar-a-Lago and I was working for Jeffrey full time JS Ok lets talk about your job at Mar-a-Lago if we could You said that your Dad was working there What was his position at Mar-a-Lago JS JS JS JS He was a maintenance supervisor I think is what it was called He lik m.ar a a 267.ggeed the tennis courts and air conditioners and things like that Sky William Roberts And is he still living here in South Florida now No hes not hes in California A Ok Is your Dad aware of what is currently gQ th regard to your having made public statements about your relationship Yes he is well aware of it I told my en before all this stuff came out because they were the first ones contacted Jrnalists from Mail on Sunday I know that they the Mail on Sunday printed Jhat I fia one out and tried to I mean I think one of the photos said that I was angry tha I_t sw effrey and the Prince walking together and that is why I came out and went 260l?lic i th everything Not true I mean I am angry about how they are still up tetliei lf ays together and that theyre still hanging out but I didnt contact the Mai on clay and I didnt bring it out I figured that everyone was going to bring it out ay and I better bring it out the right way Hes known everything from the start and my family is very supportive with everything going on Im kind ffegoin around a little bit and I apologize for that but since the subject has tell me first of all why you are providing this cooperation to us and I am cert e11;1Cppreciative of it but I want you to tell us why it is youve chosen to spend tim on the telephone and provide this infonnation that youre now providing to help the bigger picture you know I think all of us can make a big difference in ot of other peoples lives and I think that this has gone on long enough and its a big slap in my face that he can get away with hurting me so bad let alone so many other girls and laugh about it I guess I talked to you guys out because I want to see the right thing happen not just to him but I want people in the world to understand this is not the way of life you know its not acceptable to go out procure young girls and make thein think that this is the way you should be living and thats all Yeah I guess my reason for doing it is to help the bigger picture you know Im a big believer in karma and I believe that good things will come back to you so I guess thats why Im doing this Edwards adv Epstein Telephone interview with Virginia Roberts Page of23 JS Just for the record neither Brad nor I nor anyone representing that they have anything to do with us has made any promises to you Is that correct JS JS JS JS That is correct Ill tell you since this is our first conversation that nobody has made me feel like Ive been bribed or bought or had to say anything Ive told you anything that I know from my own self not some things somebody told me If anything Brads been 267careful not to tell me anything and let me do all the talking so its site I Alright Lets get back then to the story of your relationship withJ and weve talked about your first encounter with him and how it evolved frQ into your full time employment with Jeffrey but what were you doing at Marla efore you quit Mar-a-Lago I was just a locker room attendant and sometimes I dia bysitting for the rich and famous So I wasnt anything big I worked in the R.a al Thats why I was studying anatomy because I was really really interested in i a _massage therapist_ and at the locker room I didnt do much I mean I rr tea for a living I would you know make sure the toilet paper had a litt aiig in it after everybody went to the toilet or wipe down the water from the basfn ow it was a very easy peasy job Did you get that job through your Yes my Dad got me the job Ok and you were only 9Ia at the time were they aware of how old you were at Mar-a-Lago Of course defi,tely We had to go through extensive you know we even had to get drug tested and and so on and so forth I mean Mantas is very strict on employ yeaH verybody knew Ok _i is Jc ever any conversation with Ghislaine about how old you were before you we to Jeffreys mansion he didnt ask me how old I was from the start but when I did get to Jeffreys it was discussed how old I was JS With whom During the entire hour of what I call the legitimate massage I was giving him it was cat and mouse games getting information from me to find out who I am am I a willing participant in these kind of things and how would I react if they were about to take the next step But they got information off of me they got my age they got my a little bit of my history so they knew I was you know not very stable at home and they knew that Edwards adv Epstein Telephone interview with Virginia Roberts Page of23 JS JS JS JS you know I was actually interested in making my life better by studying so what they were offering me was a chance to become a legitimate masseuse but it was getting trained They would have people show me how to work the body and be called a massage therapist and get me books on it and you know keep me interested and every time you know I was with Jeffrey literally was about massages I dont mean just going in and have sex with him I mean massage because it would always start out with massage and then it would lead into sometimes other things Alright once this evolved into full time employment what did full im ee1 pJ yment mean That was entirely having to travel with Jeffrey in every city en was in Palm Beach I stayed at my apartment and he would call me to his ouse once or twice a day som times and thats you know do things with him Someti go out shopping sometimes wed go out and watch a movie You kno le things like that go to an expo or a fair whatever it was But when weAer other cities I was at my apartment_ I lived with him full time What I time is even in the middle of the night I could get a ring on my phone nex.t tf Pell me to come in his room you know so it was literally full time Lh When you say that when you were you were living in your apartment ere you living on your own or olf iving with members of your family at that time No after I quit Mar-a-L1 offered to get me an apartment in Palm Beach somewhere Royal Palm a it was a nice apartment He furnished it for me it was absolutely beauti ah thats the only time I would spend time away from him really This apartment Royal Palm Beach Boulevard or out in the Village of Royal Palm Beach I i dl ont remember Ive been trying to rack my brain because the FBI was as th same thing and were trying to find it but yeah Im Not sur_ I didnt get to sf ct much time in it I was only there about an entire week out of every month ably but the majority of the time I was with Jeffrey anyways It was somewhere in R._p,yal Palm Beach I dont know about Royal Palm Beach drive I dont even remember the Royal Palm Beach drive anym re so Im not too sure Ok let me see if I can draw the distinction for you and maybe that will help you to help us Royal Palm Beach is a village that is No no no I got Royal Palm Beach I just didnt know the Royal Palm Beach Drive like what street its off of Were you talking about a street Edwards adv Epstein Telephone interview with Virginia Roberts Page of23 JS JS JS JS JS JS JS Yes I was talking about a street Royal Palm Drive is on the island of Palm Beach and its a street that is lined with large royal palm trees and Im wondering if this was an apartment on the island or was this an apartment out west of town No it was actually in Royal Palm Beach not on the island Alright I would be driven it was closer to my family than it was closer to himA"4 to be cl se enough to everybody else so that when I was in town I lcliu see them quickly Ok So were not talking about Royal Palm Boulevard WereGki about the town of Royal Palm west of town Jeffrey got you an apartment out the Thats correct When he was in Palm Beach you were gen er ying at the mansion you were staying at the apartment that he got for you town Thats correct A OL I mean then there was time f!,do wanna say that every time I stayed at my apartment There was times wed fl 1.om some city maybe too late at night to really want to go back home so yo ow like at night or in the morning I was just staying in the yellow something like that one of the guest rooms in Palm Beach But majon of I would definitely want to get back to my own apartment Alright at general hours of your full time employment when The til set hours It wasnt like logging and you know hitting the shift button not like that The way I would get paid would be ok if I was in Palm Beach I d!ge an hour to massage Jeffrey or some of his friends and then go home So ould be like that If I was traveling with him it would be per massage so I would be ing paid per day So I wouldnt be getting paid on an hourly rate He wouldnt say ok today youre going to work for me from in the morning until at night It never like that I was on call all the time When you were here in Palm Beach were you actually getting paid only for the time spent massaging Jeffrey or were you getting paid from your arrival at his house until you left the house From the time the massage started Edwards adv Epstein Telephone interview with Virginia Roberts Page of23 JS JS JS JS JS JS JS From the time the massage started Ok Sometimes wed go there and I would wait for a while or talk with Ghislaine and Jeffrey about something or wed meet somewhere and talk about something A lot of times Id meet him upstairs in his room where he was ready for me But then there was a lot of times where it didnt start right away so he couldnt really pay me from the tlme I got there sometimes unless it was just paid from the time I massaged him til tjme the massage was over Alright Did your duties for Jeffrey ever include anything othe a providing him massages and sex in connection with the massages Did l.v you any other responsibilities to perform I was asked to do the same hings that I did to ffre of his fellow c?lleagues as well Those were my duties He looked at 1t thi i that I was gomg to be a pro essional massage therapist and maybe I need icJ entele so he had me perform erollc massages on a few people Did that start here in Palm Beach County It did The first one did Ok and_ho long after you did he first ask you to provide services for one of his friends __ About months I thin Wit wasnt a full year it wasnt months but between months and a year ihy Im saying months And when you services to a friend of Jeffreys who paid you for those services Jeffrey I would get paid the next time I saw Jeffrey so if I was invited to the Bre.ee JIat9Yto give a massage I would give a massage I would go home and the next day hen saw Jeffrey he would pay me for what I did So it was paid always by him up by him so he always knew what to pay me did get tips and things like if you call it that you know like a hundred dollar tip or something from a few of you know yeah Was there There was always payment from Jeffrey Was there ever any discussion with Jeffrey about what was expected to happen when you provided massage services to one of Jeffreys friends Edwards adv Epstein Telephone interview with Virginia Roberts Page of23 JS JS JS JS JS In a roundabout way yes In so many ways Jeffrey really really had to train me and that was why Ghislaine said that she and Jeffrey enjoyed me so much was because they never really had to speak much to me to tell me what they wanted me to do You know I wasnt waiting for you know their directions Jeffrey would tell me to go give an erotic massage to friends He wouldnt give me much detail about it but he would say to treat them like you treat me Did he refer to it as an erotic massage or are those your words A Erotic massage is my words Thats exactly what it was but he wou me to treat them how he wanted it so Id do what he wanted without havin to me words more I mean I complied with what he wanted because it at of a I dont know I dont know how to say it it was just very mindboggling hqw I let him have so much control or power over me basically The massages would oi.ttine to what Jeffrey wanted with my so called new clientele and with words would ask me to provide them with sexual pleasure after the massag Did you ever report back to Jeffrey about wha when you provided massages to his friends Of course of course and I knew 4_ sds were reporting back to him as well because there were times where he a gate conversation by saying you know so and so a great time you did detf you know so and so gave me a call and told J.E how 1t went went on No but he wou have a laugh he had a laugh with me a few times about some of their different manne I guess you would say like some of them one guy had a foot fetish andJhat eally weird and I mentioned it to Jeffrey and we would have a laugh over it Hl gidnt want to know details He wasnt asking me so tell me what did you guyeo t10Jly No he just basically gave me a slap on the back and said you know goo ol nd we had some kind of conversation about it I cant recall any conversation Sf lh op of my head I really dont know one Its been that long But yeah we did ibout it briefly Can you give me an estimate as to the number of friends for whom Jeffrey provided and paid for your services There was about you know I dont know guys possibly And are you able to name those people for me Edwards adv Epstein Telephone interview with Virginia Roberts Page of23 JS JS JS JS JS JS JS No not at this stage I just some of these people are really influential in power and I dont want to start another shitstorm with a few of them Ill tell you that there was some erotic massages given to Im just afraid to say it to you Ok Virginia Its like geez I dont know if want to Im really scared of where this is go Alright I understand that and as I told you from the beginning if I a estion that you are uncomfortable answering you just tell me that and I on and I understand that at least right now you are uncomfortable answeri D-am certainly going to respect that Thank you so much Jack No thats quite alright I am very appreciate of the on you are providing and I dont want you at any time to feel that we are takip unfaii advantage of that cooperation so give me the information that youre comfo ble w;itg me and if we get to a point where you re uncomfortable I will respect iw move on from there Ok I want to talk a little bit about the that you did with Jeffrey About how long into your relationship with him tt start Immediately I starte ediately Not internationally until I think about Gosh,1 cant rememby ee n,Vfuink it was a year later that we started doing international travel Maybe like to a year again Not too sure to be honest So that would approximately the summer of Somewhere around there Yes ere around there Somewhere around a year somewhere around there I canwm_ it exactly But like I said we started doing domestic traveling i!Ft1 it ly so my first destination with him was New York and Santa Fe and the 6-di aif California I would take trips with him occasionally Sometimes we would go Louis or New Orleans or Santa Cruz We were traveling just about everywhere I tlynk How did you travel Well we took Jeffreys private jet and unless I was being sent somewhere by myself for what we were just talking about before then I would travel on a what do you call a public jet whatever it is commercial flight Edwards adv Epstein Telephone interview with Virginia Roberts Page of23 Yes Just a normal flight an e-ticket JS Like the rest ofus common folk JS JS JS JS JS But when I was traveling with Jeffrey the majority of the time would be on the black jet Now wh you say there would be times when you uld travel by yourself.:.l,_l,ause he was sendmg you somewhere tell me about that How did that come abou So one of his colleagues would be at the Carribean or Santa Fe Yw York or wherever and he would call me up on those days where I am with him or in Palm Beach with him and he would ask me to get on the next to so and so and go meet so and so and thats when I would take e-tickets His sec or special assistant hatever would org ze it for me and give me the a.ifsJin ss I would just walk up the lme and theyd let me nght through Can you give me any ideas as to how many pened that Jeffrey would send you off to meet some friend of his at some tside of Palm Beach How many times it happened Im ot 1.robably about times Ok And on those occasions hoy time would you spend with one of Jeffreys friends when you were sent to hat you would have to travel to Only a couple of days thats it And how were you pa ose trips I would be paid p-upon my arrival back with Jeffrey So whenever I was back with Jeffrey ou ld nt up how many days Ive had sometimes give me even more than what I not deserved but what I earned and give me a little extra a daily rate for those trips or was that per massage also assage With Jeffrey I would be honest I wouldnt tell him I did massages if I nt He knew he could trust me He could always come back to the other person that he sent me to give massages and ask them as well so you know it was always by per massage JS Alright When weve been talking about massages tell me exactly what it is were talking about when we speak about massages Same thing I would do to Jeffrey Again it would start out as a massage which would start with them being naked and me giving him a legitimate massage to begin with so Edwards adv Epstein Telephone interview with Virginia Roberts Page of23 Id start with his feet go up to his calves up his legs buttocks back his neck his head his arms yada yada and then it would be time to flip over and some of the men would want me to continue on massaging the front side of them and they would instigate me to begin having sex with them or foreplay whatever you want to call it JS So routinely these massages involved sexual activity Is that accurate JS JS That is accurate Lets talk about the travel _that you were involved in when you on Jeffreys pnvate plane Generally speaking who were the passengers he when you traveled Well Larry was the pilot and then there was a short small sb I dont know his name but he was a co-pilot and then he change and was another guy brought in later on Generally speaking there was always Jeffr times Ghislaine sometimes Emmy sometimes a whole bunch of other girls met es famous people sometimes some politicians or yeah just about anybody ld fl his plane There was never no any set routine who would come and ouu It was an influx of people on Jeffreys airplane I want to deal with these things se_J Iijk order to respect some of the reservations that you have so Im going to asl ho the people were that you remember flying with Jeffrey on his plane wherRo re personally present without regard to whether there was any sexual activit.y:thit:1Sc urred on the plane or not So Im not asking you to implicate any of these fahib ople in improper conduct but just tell me what the names of the people remember that you consider to be famous people Ok there was omi Campbell Heidi Klum there was Bill Clinton There was Al Gore there was bunch of models I wouldnt really honestly be able to give their names T_.kere tt Groning the producer of the simpons cartoon Jack CCousteaus grandd ter a lot of interior designers architects politicians I am just trying to think of a yh es as possible for you Off the top of my head thats as good as I can get for JS right thats fine And again I am not implying by my questions nor do I want ai.answers to be interpreted as your suggesting that any of those people that you have just identified were engaged in any improper activities on any particular flight but I want to talk to you now about what went on on occasion on the airplane Ok Ok It was a lot of the same thing that went down on the ground A lot of times it would be just be me and Jeffrey or me and Jeffrey and Ghislaine or me and Jeffrey and some other girl sometimes Emmy Sarah and Nadia Bjournik There would be sexual conduct there would be foreplay there was a bed in there so we could basically reenact exactly Edwards adv Epstein Telephone interview with Virginia Roberts Page of23 JS JS JS JS JS JS what was happening in the house It would start off with massaging or we would start off with foreplay sometimes it would lead to you know orgies Were there occasions when you were in Jeffreys company whether on the ground or in the air where there were other girls present whom you knew to be under age Yes There was a constant influx of girls coming in and going out And we we ll very young On occasion there was some older girls and I dont mean older as their or anything I mean like something like that just very rarel majority of the girls that Jeffrey actually met or had on his plane or in his house wer age Do you know how it is that Jeffrey established with any of thes l"l irls Yes I do He would send me personally or with other girls to shops to _pick up anywhere I mean we were constantly on the look er girls that might satisfy Jeffrey What instructions were you given about what ID Young pretty you know a fun persona!j ey couldnt be black If they were any other descent other than white they fu cally beautiful That was just about it Who gave you those criteria They both gave us the 267nst cti_o it wasnt just me Jeffrey asked most girls to bring a friend and make extra ey would use us young girls So that way it probably looked a lot more safe to a if we were procuring to younger girls that were already doing it That was the at Jeffrey had it Were you given rtruction at all on how to approach these girls Yes an Ghislaine both taught to depending on _the circumstances depi the gtrl you could offer them a Job as a massage therapist or you could tell the yo ave a really rich friend with you know great contacts in the acting world or world and he loves pretty girls you should come back and meet him make 1QJ11oney you know we had a whole bunch of ways to be able to procure girls Can you give me any idea as to the total number of underage girls that you know engaged in sexual conduct with Jeffrey during the period of time you had your relationship with hi I would have no way of estimating that whatsoever I mean there could be a hundred there could be more honestly Im not too sure how many girls really I wish I did know I mean like I said there were so many over the course of years with Jeffrey Edwards adv Epstein Telephone interview with Virginia Roberts Page of23 JS Let me see if we can try to narrow it down a little bit Is there any doubt in your mind that it was more than IO Yes there was definitely more than JS JS JS JS JS Ok what I want you to do is to give me the highest number that you are comfortable in saying there were definitely more than number of underage girls that I kn Jef.frey Epstein engaged in sex with while I had a relationship with him How woui fill in that blank Definitely more than how many Id say definitely more than a hundred CJ Alright Did Jeffiey ever help to pick out your clothes Oh yes I mean he wasnt out to dress me like a porn fnything He would always dress me very classy but wed just go shopping all gether Did he ever express any style preferences iiu how he wanted you to dress Besides dressing classy Im you know e"Ysuggestion to you about how he wanted you dressed He didnt like I said wasnt tryino-4 r6sffoe in any prostitute way or anything like that It was nice classy outfits ng like Gucci Dolce Gabbana Chanel things like that He was buying me very nice clothing It was provocative I mean I was wearing miniskirts llJ_lcPtigh shorts and little shirts that showed my belly and my cleavage and everythir:fg ey were very expensive clothes Was there every any role playing Yes There was of it Jeffrey loved the latex outfits Ghislane had for us girls he had bon outtps he had all different kinds of outfits but his favorite was the school Teleout that know Ghislaine would take me to dress me up to surprise J.E or Jeffrey would to get dressed up that would include wearing a tiny little skirt with nothing underneath a white collared shirt that you would be wearing to school with a tie in it tied up _in a bow_ my hair in pigtails stockings on up to my knees and I would go in there and act like a kid and wed do role playing sexing JS Did Jeffrey ever brag to you about the age of any of the girls with whom he had relationships Edwards adv Epstein Telephone interview with Virginia Roberts Page of23 JS JS JS JS Yes he did He did all the time The worst one that I heard from his own mouth was this pretty year old girls he had flown in for his birthday It was a surprise birthday gift from one of his friends and they were from France I did see them I did meet them Jeffrey bragged afterwards after he met them that they were year olds and flown over from France because theyre really poor over there and their parents needed the money or whatever the case is and they were absolutely free to stay and flew out Those were the worst ones He was constantly bragg ing about girls ages or where he em from or their past and how terrible their past was and good he is making it for the Where were the year old girls flown to from France Where did they to Palm Beach And were they flown in on Jeffs private plane or did they get plrted No They Vere transported by somebody else Ok Was the sexual activity that went on on airp conducted in such a way so that any of the crew was aware of what was goin They were told to knock if they had ti if the crew had to come out They were told you know to come out as lit1J1 as po 245ible so they werent out there hanging out watching everything no but it do an idiot to put two and two together to say well theres a whole bunch 243.HaIB dre sed teenagers on board with this old man who is constantly being massage Jn th and he wants me to keep the door shut for what reason I mean only the that together but yeah they knew Did Mr Epstein ever to ou about people of power and influence owing him favors He would laughtt it you know I never really knew what to take serious from Jeffrey because as a funny character at times You never knew if what he was saying was tru lot eah lots of people owed him favors from what he told me Hes got evei lfis pocket and he would laugh about he helps people for the sole purpose in en they owe him something Thats why I believe he does so many favors in the tfr pl JS and how did you first become aware that Mr Epstein was in trouble with the law I was first informed by I think someone from the FBI called me first and started to ask me questions and I started to answer the questions but then fear took over and I just said look I dont know whats going on Ive got a young family that I dont want to risk you know please dont bother me about this again and it was real short simple conversation and within a week or I had gotten a call from Jeffreys attorney and then a week later Jeffrey himself Edwards adv Epstein Telephone interview with Virginia Roberts Page of23 JS Ok well lets back up before we get to those conversations and tell me approximately when it was that you were contacted by the person who you believe was with the FBI Ok Its hard for me to pinpoint ifI had to pinpoint it it would be in sometime JS Alright And you were living in Australia at that time correct JS JS JS JS JS Correct A You were contacted by telephone Thats correct by my cell phone i Ok and do you have any idea how your name came up leading contact No idea No idea whatsoever When I did ask at some girls had revealed my name I guess and thats how everybody the contact me OK rry ever tell t,C that Virginia how long was it after that phone call from the FBI person contacted by Mr Epsteins lawyers Like a week It ck to back to each other I remember being so scared after talking to the h.inkin1r,whats happening whats going on Its been like years years at that sta J:tow did they find me what do I have to do with this So yeah do rem ili ery well and it was only about a week later I was called by his attorney JS A that contacted you do you remember to say Bill Riley but he might have been from the FBI No it was Bill Riley Bill Riley Not sure if thats his correct name but thats what is coming to mind JS What do you remember about that conversation I remember a Mr Goldberger as well I remember there might have been two of them JS Alright Edwards adv Epstein Telephone interview with Virginia Roberts Page of23 JS JS JS I cant remember which one it was I want to say Bill Riley is the good one Alright so either Bill Riley or a Mr Goldberger or both of them contacted you and what do you remember about that I dont know if it was the same guy who contacted me that week later who put me in touch with Jeffrey I think he was on the phone and he put speakerphone on with Jeffrey So he connected me with Jeffrey I dont know if it was the same guy or dif but I definitely know that Bill Riley the first guy to contact me Im prel!Z iliodt that Ok Tell me about that conversallon He asked me what I knew about whats going on with Jeffrey apparently there was an investigation being held about some of the girls who ha out and said that Jeffrey had sexual contact with them under the ag minor and that he was discrediting lot of these girls and making them addicts and prostitutes and what have you so they wouldnt be looked upon q!il Jn the courts eyes so to speak And you know he told me in the first five tes you know if I stay quiet that Ill be looked after And that was the exacf.wa iy as said It wasnt like you know Im gonna pay you a zillion dollar or anyJnl you be quiet but if I stay quiet I would looked after And I remember sayi ant any part to do with this You know this is not something I want to be a of Yve got a young family I wish the best for everybody in this you know ak ere of thing A week later I was called after the hearing by one of Jeffreys la I-cant tell you exactly which one it was but he had Jeffrey on the other line andhe ected Jeffrey and I and Jeffrey tried to make some simpl_e conversation are.e How have things been You know what I mean catching up Do you know if wyer did the lawyer stay on the line while Jeffrey was speaking to you Im pre re he did Thats why I think Jeffrey was on speaker phone because it soun lo ifferent and I was never taken off the line to begin with or connected to ano her so I was pretty sure Jeffrey was on speaker phone and the lawyer was fig:tlfe call After the simple conversation it led to what was going on again and you Jeffrey couldnt believe it You know he thought he helped all these girls out He ipnt think he was wrong in any circumstance here at all A lot of these girls were drug addicts and just after drug money You know he was really putting down these women or these girls I should say not giving them the credit they deserved and then he exactly repeated what the lawyer said the week before is that he would look after me if I stayed quiet and if I need any help you know his lawyers would represent me and he would get legal help for me whatever I need he would do and I told him exactly I said Jeffrey Im the mother of two children at that stage Im away from everything there I dont want to be a part of it Im not going to speak to anybody and I dont want to speak to anybody I dont want to be involved That was the last time I heard from him And the Edwards adv Epstein Telephone interview with Virginia Roberts Page20 of23 JS JS JS next thing I knew I was sent my victims letter my notification of being a victim through the US Attorneys Office and thats when I knew it was well out there enough not to have Jeffreys lawyers come back on me and discredit me in the same way he had done to all the other girls So I called up Joseph Bird who was the recommended lawyers on my paperwork that they had given me and started going from there So you contact Mr Joseph Bergs office and then you were dealing with hi 1cc.e from that point forward Thats correct Tell me about the ending of your relationship with Jeffrey Thr point in time did your full time employment end and how did that happen Ok So it hadnt really ended I walked away from ik_ effrey sent me to Thailand where I met my husband and escaped to Australia if return back to the states About months prior to that he came up with sttion that I thought was really disgustingly sick And it really showed me fo be ime in years I had been with him that nothing was going to change and k_ il just going to be used by him which I did not like He offered me a t11a.ii drt cl some of his money every month I forget what he called it a monthly i q_t Vliat he made to bear one of his children The proposition was that if anythi.ng fi ppened between Jeffrey and I that I would have to sign my child over ht br,ically and that the child would be his and Ghislaines and I would be lo.o it as long as nothing happened between Jeffrey and I So I was kind offr re do all of that I pushed Jeffrey more to please get me some more training I was getting older and not of as much interest to Jeffrey anyways I and he likes a female a lot younger So he sent me to Thailand in Septemb I was first supposed to meet a girl there and bring her back with me ever met up with her I proceeded get a short course in Thai massage so that was to up about my training so I went there and one of my friends from schooljn 267ted my to watch a fight like a muay thai fight which is like a form kickbo I went and watched it and I saw this guy that was a really good fighter and tgir td looked really hot so I asked my friend who knew him to introduce me We ot1 1Jroduced and fell in love immediately days later Rob proposed and days Uftx!twa being married in a buddist temple I called Jeffrey and told him Im sorry Im hcoming back Ive gotten married Ive fallen in love I thought hed wish the best fu;,me but he was kind of rude and he just said have a good life and hung up the phone and that was the last time Id talked to him ever until all this_started again Ok Virginia is there anything else that you would like to add to what you have told us up to this point in time Id like to know that this time around somethings going to be done about it and that Jeffrey and a lot of his colleagues no matter how rich they are will know that there is Edwards adv Epstein Telephone interview with Virginia Roberts Page21 of23 JS JS law and that there is people that still believe in it So thats it Thank you guys for listening to me hearing me out and helping me Its kind of hard to get through Thank you very much Yes Im sure it has been very difficult and I am very appreciative of the courage you have shown in doing what you have done which really brings me to the last subject and that is what was it that motivated you to go public with all of this Ri contacted me I like he_r I do I like her a ol I know she lis and JOUrnahsts are normally bloodsucking leeches but hke her for th aw ut sJie IS an honest bloodsucking leech She told me a lot about what was still gdil and she showed me a picture of Jeffrey with a little girl who looks like nave been years old I mean it was disgusting I agreed to talk with per agreed to do anything until she showed me some pictures and at that ge qemg a mother of children and having a daughter who I would do anything for fect I would put my neck on the line to make sure she never has to go throug at I had to go through and knowing all of this and knowing that hes still out th igg the same exact thing with no regrets no remorse no worry about what hes t_o,.lhose girls and all those girls feeling th same that did so I you know,4 iygit because I believe in my heart of hearts its the nght thing to do Its Ht uld want somebody to do for my daughter or my sister or my friend an it ado me to know that its still going on right now Its like the seashell story I don oure heard the story about the little kid who throws back a starfish you kIJ,cf th iftle brother tries to ask his sister why do you throw them in theyre all gogqa i9.11yways the little girl says well its this one that I can help and this one th help and thats what I feel like Im doing Im making a small dent in th we live in I certainly appreciate coyrage and I have heard that story and youre absolutely right that one person aybt be able to make a difference for everyone but one person can make a difference or someone and hopefully you are making a difference for someone an nna do the best we can to make sure you are making a difference Ply possible JS IbJhl other follow up things I want to ask you and again if any of these questions questions that youre uncomfortable in responding to then dont hesitate to tell me qat Do you have any recollection of Jeffrey Epsteins specifically telling you that Bill Clinton owes me favors Yes I do It was a laugh though He would laugh it off You know I remember asking Jeffrey whats Bill Clinton doing here kind of thing and he laughed it off and said well he owes me a favor He never told me what favors they were I never knew I didnt know ifhe was serious It was just a joke JS Where was here Edwards adv Epstein Telephone interview with Virginia Roberts Page22 of23 He told me a long time ago that everyone owes him favors Theyre all in each others pockets JS When you say you asked him why is Bill Clinton here where was here JS JS JS JS On the island When you were present wit Jeffrey Epstein and Bill Clinton on the isl lho lse was there Ghislaine Emmy and there was young girls that I could ide,.ify erreally knew them well anyways It was just girls from New York And were all of you staying at Jeffreys house on the isl fluding Bill Clinton Thats correct He had bout different vill,a,_ island separate from the main house and we all stayed the villas Were sexual orgies a regular occurrence at Jeffreys house Yes If we were to take sworn testi6 fr the people I am going to name and if those people were to tell the ti:R at they knew do you believe that any of the following people would ax._ evant information about Jeffreys taking advantage of underage girls So IA_ ust rtame a name and you tell me yes if they told the truth I think theyd have rele it ionnation or no I dont think they would or I dont know whether they nor Ok You understand Yes JS Ok i er Jhas relevant infonnation but I dont think hell tell you the truth JS Jan Dershowitz Yes JS David Copperfield Dont know JS Tommy Matola Edwards adv Epstein Telephone interview with Virginia Roberts Page23 of23 Dont know JS Prince Andrew JS JS Yes he would know a lot of the truth Again I dont know how much he would be able to help you with but seeing hes in a lot of trouble himself these days I might so I think he may be valuable Im not too sure of him Ok Virginia I think thats all I have for you Let me tell you what like to do As I told you in the beginning of this conversation weve be ing it and hopefully weve got a clear enough recording so that weve wn everything accurately and when its transcribed it will be clear and ace te what I would like to do is transcribe it,.send it to you have you take a look at it d..i 1theres anything that we got wrong in the statement you can write back can make changes in the transcri so that tr script is accurate Is that,Z_ air No womes That ts fiur No problem Alrigh great I really do appreciate enme what the best way is to send the transcnpt to you Email If you just want to sen if you want to send it by mail either or JS Ok Give me your email would please JS J;i apprecifile it JS ank you very very much Bye Bye now Take care Jack Nice meeting you JS You too Redaction has been made at the request of the witness EXHIBIT IN THE CIRCUIT COURT OF THE th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CIVIL DIVISION AG CASE NO J_udge David Crow JEFFREY EPSTEIN Plaintiff/Counter-Defendant SCOTT ROTHSTEIN individually an BRADLEY EDWARDS individually Defendants/Counter-Plaintiffs iif PLAINTIFF JEFFREY EPSTEINS SECONB;;REQ.ST FOR PRODUCTION TO EDWARDS Plain.tiff/Counter-Def dant Jeffr pstein Epstein hereby requests that Defendant/Counter-Plaintiff Bradle Eft produce for inspection and copying tho items requested in Epsteins Second lleques tf fr Production within days of _service at the offices of Fowler-White Burnett P.A 90r1?Pirtllips Point West South Flagler Drive West Palm Beach FL CERTIFICATE OF SERVICE I CERTIFY that a true and correct copy of the foregoing was served by e-mail and U.S MJf on this th day of December on Jack Scarola,.Esq Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Blvd West Palm Beach FL Jack Alan Goldberger Esq Atterbury Goldberger Weiss Australian Ave South Suite West Palm Bead FL and Marc Nurik Esq Law Offices of Marc Nurik One East Broward Blvd Suite Fort La1 derdale FL Epstein Rothstein and Edwards Case No AG Florida Bar No FOWLER WHITE Epstein Rothstein and Edwards Case No AG DEFINITIONS AND INSTRUCTIONS The term Edwards you or your means the party or parties to whom this Request for Production is addressed i.e Defendant/Counter-Plaintiff Bradley Edwards including all persons acting or purporting to act on his behalf Second A.mended Counterclaim means the Second An c!ounterclaim which you served on November on the Plaintiff/Counter-De 4?ndcll Jeffrey Epstein in this action partnership The term witness means any naturali ersorrf individual proprietorship ft limited liability company corpo f19n;i a:ffiliate subsidiary association persons or other entity natural person means A th _fiill name current telephone number and current business and home f;-r addresses or if t4 267curr rtt lephone number and/or current business and home addresses are not known Jh lnown telephone numbers and/or business and home addresses of the person.,.,l 4atessfs shall include the street and post office box if known and the city state country ahd zip code the full name and address of each employer each corporation of which the person is an officer or director and each limited liability company of which the person is a Epstein Rothstein and Edwards Case No AG manager or a member each partnership of which the person is a partner and each other business in which the person is a principal the persons current or if the current is not known the lasf"known position and the position or positions held by the person at the time of the filth the response to a specific request relates and person entity other than a natural person means i the full name of the en tli.e type of entity e.g corporation limited A liability company partnership etc the J1tilf its principal place of business its principal business activity the jurisdiction rt such organization ws of which it has been organized and the date of ea l.t of the entitys officers directors shareholders managers members tv partners or other pJ;;incipalS I sS.ti other available information concerning the existence or identity of the entity The terms identify describe or provide when used with reference to a document means A the name or designation of the document Epstein Rothstein and Edwards Case No AG the name of the person who participated the creation of the document the date of the document the person or entity to whom the document is addressed ari fihose to whom any copies of the document were addressed or delivered i i a brief description of the contents of the docume11t and_ all signatories to the document Doc 265ment means any agreement ft tr letter correspondence memorandum report calendar diary appointnie f,bci6 record including business financial and medical records ledger audit bilh.JriVoice statement schedule recording of sound or photographs electronic file wk the disk tape drive or otherwise printout i writing drawing sketch notes Qiand tten or otherwise map blueprint e-mail data compilation and written or rec rded lfrial of any kind and character ReferringJo i glfecting evidencing or relating to means in any way Jt directly or indirecdy con II ing referring to disclosing describing confirming supporting 0:iP evidencing Of setfting Arid and or shall be construed in the disjunctive or conjunctive as necessary i in order to bring within the scope of each request hich migh otherwise be construed to be outside its scope Person means any individual natural person partnership association firm limited liability company corporation organization trust governmental or public entity and any Epstein Rothstein and Edwards Case No AG of the officers directors shareholders members managers partners agents employees assigns or representatives of the same Substantiate state or explain means to produce documents or thipg that set forth the circumstances or bases for any belief contention or position or giv rmation or direction in response to a request If documents or things that are responsive to all or not within your custody possession or control for each state hertjt was last in your custody possession or control and why it is no longer in your custo ses ion or control and identify the person that you know has or last had or faJ lieve has or last had custody possession or control of such document or thin i If you do not presently hay custody possession or control documents or things that are responsive to a requ sr 267inc Jle a statement to that effect and at such time as any responsive document or thingfcomei ihto your custody possession or control produce same within ten days of its loca:tton if1:any event produce it no less than ten days prior to trial it Exc wheF therwise stated the time period for the requests made herein is Epstein Rothstein and Edwards Case No 1B/Div AG REQUESTS Each and every document that tends to support the claim in your Second Amended Counterclaim that you have suffered damage to your reputation as a result Qf tl;ie filing of this action against you Each and every document that tends to support the cl Second Sf Z:x_ __ Amended Counterclaim that you have suffered damage as a resultof il terference in your professional relationships claim you are making for special damages including loss of income this rt:;qtl st lfically shall include but not be iC limited to production of your federal income tpt yn 247rfor and records of income in i l1t:i Each and every do tunerlt/that tends to support the claim in your Second Amended Counterclaim that y;j i.suffered money damages resulting from the loss of the i value of your time divert frontyour professio,ial responsibilities this request specifically shall tt include but not be,,Hmitecr:10 the production of all your time and billing records calendars and diaries from 7O0iJhro gh the date on which you respond to this request ach and every document including but not limited to invoices and statements that tend to support the claim in your Second Amended Counterclaim that you have paid money or incurred obligations to pay money for your defense in this lawsuit Each and every document evidencing communications from others with respect to your reputation and standing in the legal community Epstein Rothstein and Edwards Case No AG Witness statements you intend to use in this case All.invoices and statements for legal services and costs incurred for the defense of this action against you fz Each agreement or other writing memorializing the arrangem yft pw-;mfut to which you are receiving legal services for the defense of this action includijitotlt not iimited to a retainer agreement with Searcy Denney Scarola Barn.part Shipley Each and every document that tends to sho tl:i your reputation has been damaged as a result of your relationship with Rothstein 11ff Adler frg:.-l Each and every document reflecti gt collections received from your i providing services as a lawyer for each of the Y,eit and i r?f Invoices statements of aq,im other documents reflecting trean 265ent for any if_ physical or psychological injury to have suffered as a result of this action being brought against you and yery document reflecting the _method used in calculating your loss of re income whether wage other remuneration for the period you claim to have suffered damages and every document reflecting the method used in calculating your alleged loss of fun,.re earning capacity as a direct result of the allegedly wrongful conduct Each and every document reflecting all lost business opport ties you claim to have suffered between apd the present Epstein Rothstein and Edwards Case No AG Each and every document reflecting the identity of the confidential source listed on your Privilege Log dated February Each and every document reflecting the legal authority that justifies your refusal to disclose the identity of the person identified as a confidential source in yoyt vil;g Log dated February AU closing statements for all clients who you represeiited ii brought claims against the Plaintiff and all other documents with respect to spcfi Jients reflecting amounts lJ paid to such clients or to you your time referring attonii;;x iamounts paid to the same advance costs and payments to any other person or ti All records of your contacts wi thet_are or other media outlets Any agreements and CQll1:Jll tions relating to agreements or potential i;:f agreements for the sale of developufeht or any other transaction relating to movie book or other rights that you may or wifl benefit from which are related to the claims you or your clients fh ir::,c brought against the PlaintijI All decum n;r supporting your alleged belief that law enforcement is still investigating_ thjt Plimtiff/Counter-Defendant Jeffrey Epstein including those reflecting commll 6fi-s with or information received from the government/law enforcement media other att bieys or anyone else from which you claim to form this belief All documents supporting your claim that others still persist in prosecuting claims against Jeffrey Epstein Epstein Rothstein and Edwards Case No AG All documents supporting your claims in Paragraphs and of the Second Amended Counterclaim in which you allege the sole purpose of filing civil claims was never to recover monetary damages that Plaintiff/Counter-Defendant Jeffrey Epstein knew never A suffered monetary dam.ages and that he knowingly asserted baseless and unsunJP ble laims fu etc EXHIBIT JElFREY EPSTEIN Plaintiff vs i SCQTT ROTHSTEIN individually BR!ADLEY EDWARDS individually and individually i I Defendant I iN THE CIRC:r.JIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO PLAINTIFFS RESPONSE TO Defendant/Counterplaintiff Bradley Ed ar rid through his undersigned attorney pursuant to Rule Civil Procedure hereby respond to fol ows i wo ld require a disclos of the mental impressions and thought processes of counsel and is i acri-dingly prot fed by the work:-product privilege 1ec ion The identification of documents that tend to support a specific claim I wop ea disclosure of the mental impressions and thought processes of counsel and is i ac ordingly protected by the work-product privilege Objection The identification of docum nts that tend to support a-specific claim wo require a disclosure of the mental impressions and thought processes of counsel and is acc:ordingly protected by the work-product privilege Edwards adv Epstein Cas No Plaiptiff Response to Request to Produce Obje_ction The identification of documents that tend to support specific claim wo require a disclosure of the mental impressions and thought processes of counsel and is a ordingly protected by the work-product privilege Objection The identi cation of docum nts that tend to support eci:tiirclaim 1rS i"U wo require a disclosur of the mental impressions and thought proces o:counsel and is cf:R acdordingly protected by the work-product privilege Invoices reflecting expenses incurred in defense Qf;:flil lawsuit are available for inspection and copying at the offices of Bradley Edwai;dSf oou sfl at any mutually convenient b_ ti determined by.prior _arrangement The only responsive documents/:ar the original and amende!i mpilits in this action tt;_l Epsteins Motion i ise Rothstein with attachments and certificate of service filed bankruptcy proceedings bankrupflit:Y filings and hearing transcripts all which are already the r--o _pQ ssiori;of Epstein and his counsel Iltone i i;;l,i __ Invoices reflecting xpenses incurred in defense of this lawsuit are available for inspecti and copying at the offices of Bradley Edwards counsel at any mutually convenient ti determined by prior arrangement Ed ards adv Epstein Cash No Plaiptiff Response to llequest to Produce Responsive documents are available for inspection and copying at the offices of Brtdley Edwards counsel at any mutually convenient time determined by prior arrangement None Objection Overly broad not reasonably calculated to lead to iscovery of adrhissible evidence privileged pursuant to Bradley Edwards right and th riglits of his clients i law partners and associates to economic privacy and in some jrcm;nstances subject to contractual confidentiality provisions None Records reflecting the amount of ti Vhie Bradley Edwards has been obliged to p.evote to the defense of Epsteins ma iou ptlsive and baseless legal actions against i fi Bddley Edwards are available for ins on cffi:if copying at the offices of Bradley Edwards counsel at anymutually conveniept,titile termined by-prior arrangement li i None Records W.tl cting the amount of time which Bradley Edwards has been obliged to devote to th f:aefense of Epsteins malicious abusive and baseless legal actions against BrJdley Eqw are available for inspection and copying at the offices of Bradley Edwards co i utually convenient time detemiined by prior arrangement lo Objection Attorney work product privilege Objection Attorney work product privilege Edwards adv Epstein Case No Plaihtiff Response to.Request to Produce Objection Overly broad not reasonably calculated to lead to the discovery of adrhissible evidence privileged pursuant to Bradley Edwards right and the rights of his clients la partners and associates to economic privacy and in some circumstances,_ s11bject to i co tractual confidentiality provisions Objection Attorney work product privilege except to th Bradley A Edwards is identified as a source of information in published reP rts which are as easily S"f av ilable to Jeffrey Epstein as to Bradley Edwards through inte ets ches None ii None None except to the extent tha!ifend ictims Rights Act proceedings fall within thd desctjption of this request Pleadit jn matter are public records readily available to Jetyrey Epstein See Bradley warqs fotion for Summary Judgment and attachments thereto Lf and all pleadings and fiitpgtin the state and federal criminal proceedings against Epstein and in each of the civjJ claims brought against and settled by him-all of which are already in the i po sessionprB teih and/or the members of the various law firms who do and have repres nted i Edwards adv Epstein CasF No Plaiptiff Response to Request to Produce I HEREBY CERTIFY that a true and correct copy of the foregofog has been furnished by and U.S Mail to all Counsel on the atta hed list th.is i7r day of January Jack aro Js Flo ar No i arc enney arola Bargq rt lSfiipley P.A I Palm Beach Lakes B9_ulEjJ1rd est Palin Beach Flq a Phone Jffli i Fax i Attorney for ijr dJey 267Edwards ll Ed ards adv Epstein Case No Plaiptiff Response to Request to Produce COUNSEL LIST Jaclc A Goldberger Esquire Att rbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Phone i Fai;mer Jaffe Weissing Edwards Fistos Lehrman PL Andrews Avenue Suite Fot;t Lauderdale FL Phone Ftj Nurik Esquire Law Offices of Marc Nurik On Broward Blvd Suite Foi;t Lauderdale FL Fax Jo ph Ackerman Jr Esq1;!ire Fo"1ler White Burnett P.A Phillips Point West Flagler Drive West Palm Beach FL Phone Fa ii i EXHIBIT Tina Campbell From Sent To Subject Attachments Hi Chris Tina Campbell Wednesday January AM Chris Rodgers Epstein Edwards Roberts.Virginia Telephone lnterview.pdf Could you please send me the audio for this telephone interview Thank you Tina Campbell CP/FRP Certified Paralegal LINK ROCKENBACH PA Palm Beach Lakes Blvd Suite West Palm Beach FL office I fax I Email tina linkrocklaw.com This e-mail may contain privileged or confidential information If it is not meant for you please delete it and notify us immediately Please confirm receipt of time sensitive communications because email deliveries may be delayed or unsuccessful We do not provide tax advice Our communications may not be relied upon to avoid penalties that may be imposed by the Internal Revenue Service EXHIBIT Filing E-Filed JEFFREY EPSTEIN Plai11tiff vs SCOTT ROTHSTEIN iridividi.ially BRADLEYJ EDWARDS idividually,artd L.M individu tly Defendarits __ IN THE CIRCUIT COURTOF THE FIFfEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO COUNTER-PLAINTIFF;S BRADLEY EDWARDS SECOND AMENDED EXHIBIT LIST COMES,NOW the Counter-Plaintiff BRApLEY EDWJ RD_S aJ?.d hereby files his Amended Exhibit List as follows INDEXTO OBJECTIONS Noobjectfon_ AHobjections All objections,iexcept authenticity Irrelevant or immaterial Probative value substantially outweighed by dariger of unfair prejudice confusion of issues misle dirig the jury or needless presentation of cumulative evidence Privileged 0pinion Hearsay Authenticitylacking 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 Warrant 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 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 effi-ey 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 articles 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 Kiischler 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 A1Test Warrant 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 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 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 to all Counsel on the attached list this day of A ory 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 A A 4A E0 A4 DE a qr?q rq qrCX HhL Kg lg d?a d6U a M3 flW y??S m/y t0 I F/Z V/j 1a qC KS u?v vZ O5 a qr rCX qC 0V I I dc rM?M rM 10Cy n??m?n k?o?h I A I w?!ac qr MCX 10Cy ITy qr M3 Ґ??1rA5R h?H?T3P K?z X?K H?o I Idc rM?M rM 10Cy f헊?f?Tz e?e:Aa I v"x i X5 EO5 5a r?q CX 9r Cy rq rqC M3 ş?:c p/p0 5H V)V 6T Y2 G5 qrM?r?qr?r9 q?10Cy rCX qr l1 X?l 3K fm?Q Z2f CX CX gT L??T 2E Cy 3P EM3 J4T L?h??M q?ᡚ?Y r??O?rJt CTX i P!e i I CTX rC YY I 1e 2j CTX X0T1i k3v Jh/e0h1 H(K W/Q0 CTX j?!k 5B r2 CTX A A A 4v z"p A A A0A?A AK CTX A A?!k CX qCX YCX i!d A fi8 l8 yuZ 6L pH m?c sP;0 6ZR Ni P0 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