Edwards adv Epstein Response in Opposition to Epsteins Motion in Limine as to Newly Filed Exhibits Case No all of the exhibits were already in the hands of defense counsel In fact at the December hearing Epsteins counsel noted that at least one of the numbered exhibits did not match to the corresponding exhibit that had been provided See Tr at copy attached as Exhibit A On December Edwards filed the correct version of his Exhibit List Undersigned counsels office emailed Epsteins counsel that same day explaining this inadvertent error A copy of the email is attached as Exhibit Pursuant to the Courts Order on Epsteins Revised Omnibus Motion in Limine Section Edwards was required to produce to Epstein all trial exhibits that had not previously been produced by no later than December A copy of the Court Order is attached hereto as Exhibit Given that the exhibits at issue had been produced in October of Edwards is in full compliance with this Order See Exhibit Epsteins request to nonetheless categorically exclude all exhibits that were produced in November of simply because undersigned counsels office inadvertently filed the wrong version of its exhibit list is an extreme sanction that is not warranted In essence the Court would be striking Edwards December Amended Exhibit List pleading which is the most extreme sanction which can be imposed by a court See World Enter Inc Union SPOL S.R.O So 2d Fla 3d DCA Striking Edwards Amended Exhibit List due to undersigned counsels office having inadvertently filed the wrong copy of that pleading would impermissibly punish Mr Edwards the litigant for that mistake See Paris Intern Records Edwards adv Epstein Response in Opposition to Epsteins Motion in Limine as to Newly Filed Exhibits Case No Filmworks Inc Rodriguez So 2d Fla 3d DCA reversing a trial courts ruling striking pleadings and granting the affirmative relief based on the failure of defense counsel to appear at a case management conference which without more is too severe a sanction to impose upon a litigant where as here the record is devoid of any evidence reflecting counsels willful or flagrant disregard of the courts authority Moreover Epstein has clearly suffered no prejudice from this inadvertent error as Epstein received copies of the exhibits at issue months ago Thus rather than categorically excluding exhibits that were timely provided pursuant to the Courts order the Court should consider the admissibility of each individual exhibit While it is Edwards position that all exhibits are relevant and material to the issues to be tried in this case undersigned counsel will not seek to introduce any of these exhibits or deposition testimony in the presence of the jury unless and until the Court has ruled outside of the jurys presence that Edwards is entitled to do so Given the significant remaining pre-trial motions and issues that remain to be heard Edwards submits that the Court should simply defer on ruling until Edwards raises the issues outside the presence of the jury For those reasons Epsteins Motion in Limine should either be denied or the Court should defer on the individual admissibility of each exhibit and designated deposition transcript until raised at trial Edwards adv Epstein Response in Opposition to Epsteins Motion in Limine as to Newly Filed Exhibits Case No I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve I to all Counsel on the attached list this day of February Jae Scru:6la Fl rida13ar No a Vitale Jr Fl6rida Bar No li.ttorney E-Mails jsx searcylaw.com and mmccann searcylaw.com Primary E-Mail _scarolateam searcylaw.com Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida Phone Attorneys for Bradley Edwards Edwards adv Epstein Response in Opposition to Epsteins Motion in Limine as to Newly Filed Exhibits Case No Bradley Edwards Esquire staff.efile pathtojustice.com Andrews A venue Suite Fort Lauderdale FL Phone Fax COUNSEL LIST Jack A Goldberger Esquire jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss P.A Australian A venue Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Nichole Segal Esquire njs FLAppellateLaw.com kbt FLAppellateLaw.com Burlington Rockenbach P.A Railroad Avenue Suite West Palm Beach FL Phone Attorneys for Bradley Edwards Scott Link Esquire Eservice linkrocklaw.com Scott linkrocklaw.com Kara linkrocklaw.com Angela linkrocklaw.com Tanya linkrocklaw.com tina linkrocklaw.com Link Rockenbach P.A Palm Beach Lakes Boulevard Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Marc Nurik Esquire marc nuriklaw.com One Broward Blvd Suite Fort Lauderdale FL Phone Edwards adv Epstein Response in Opposition to Epsteins Motion in Limine as to Newly Filed Exhibits Case No Fax Attorneys for Scott Rothstein IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Case No JEFFREY EPSTEIN Plaintiff/Counter-Defendant vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually Defendants/Counter-Plaintiff VOLUME I TRANSCRIPT OF PROCEEDINGS DATE TAKEN TIME PLACE BEFORE Tuesday December 5th a.m p.m Dixie Highway Room l0C West Palm Beach Florida Donald Hafele Presiding Judge This cause came on to be heard at the time and place aforesaid when and where the following proceedings were reported by Sonja Hall Palm Beach Reporting Service Inc Palm Beach Lakes Boulevard Suite West Palm Beach FL Palm Bead EXHIBIT Inc is the video of the search warrant of my clients home while being executed the search I dont have the video but I presume by that it wasnt produced but I presume by that description it is the same ruling THE COURT The same ruling as in the application for the search warrant is sustained MR SCAROLA Let me just point out to Your Honor that the reason why thats listed is because the victims including these three give detailed descriptions of where they were in the house and what the interior looked like And all of that is corroborated by the search warrant video THE COURT Again its with the proviso and caveat that I will re-examine each of these exhibits if need be when the context is pointed out But for now the same ruling is being issued MS ROCKENBACH Number actually Its identified on the exhibit list by Mr Edwards as the application for a search warrant of my clients home And its Palm Beach Reporting Service Inc possible that by mistake Mr Scarolas office produced a different document because what was produced in this context was an order sealing affidavit and application for search warrant and related search warrant and inventory in return And attached to that were the subpoenas to the custodian of records for BellSouth T-Mobile and Cingular So it looks like phone records MR SCAROLA Sounds like the wrong exhibit MS ROCKENBACH Sounds like the wrong exhibit but we would object to on the same basis that the application for the search warrant of Mr Epsteins home would not be relevant would be prejudicial THE COURT I have already indicated the same as to number MS ROCKENBACH Eighteen Your Honor is the complaint THE COURT That again is typically a matter of judicial notice so we will deal with it if we need to at a later time All records of homes properties bank Palm Beach Reporting Service Inc Chris Rodgers From Sent To Subject CaselD CategorylD lntakeCase SentFromSession Thank you Chris Rodgers December PM Scott Link RE Regarding Edwards Bradley adv Epstein File CRODGERSW1 PM From Scott Link mailto:Scott linkrocklaw.com Sent December PM To Chris Rodgers crodgers SearcyLaw.com Cc Tina L.Campbell Tina linkrocklaw.com Jack Scarola JSX SearcyLaw.com David Vitale Jr dvitale searcylaw.com Kimberly Marsh kmarsh searcylaw.com Mary Mccann mmccann Searcylaw.com Kara Berard Rockenbach Kara linkrocklaw.com Subject Re Regarding Edwards Bradley adv Epstein File Of course Scott Scott Link Board Certified Business Litigation LINK ROCKENBACH PA Palm Beach Lakes Blvd Suite West Palm Beach FL office I fax I Email scott 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 On Dec at PM Chris Rodgers crodgers SearcyLaw.com wrote Hey Tina We are having data download speed issues with some of our exhibits While we hope to get you these exhibits by the end of today our fear is that the download delay might take longer than expected actually it already has Given that and in an abundance of caution would you be willing to extend to us a one day extension to provide you with the missing Edwards exhibits Thank you for your understanding with this matter Chris Rodgers From Chris Rodgers Sent December AM To Tina L.Campbell Tina linkrocklaw.com Cc Jack Scarola JSX searcylaw.com David Vitale Jr dvitale searcylaw.com Kimberly Marsh kmarsh searcylaw.com Mary Mccann mmccann Searcylaw.com Scott Link Scott linkrocklaw.com Kara Berard Rockenbach Kara linkrocklaw.com Subject Regarding Edwards Bradley adv Epstein File Good Morning Tina Yesterday it was discovered that we inadvertently attached an incorrect version of our Exhibit List to our Unilateral Pre-Trial Stipulation which was filed on November While the exhibit list provided in this filing was incorrect the actual exhibit documents forwarded to you on November were correct As an example the provided exhibits go to number while the Exhibit List stops at number You will notice that the correct Exhibit List attached corresponds correctly to the provided exhibits To correct this error we are filing this correct Exhibit List today as our Second Amended Exhibit List Please e-mail or call with any concerns or questions regarding this correction Chris Rodgers image001.jpg w.searcylaw.com Senior Litigation image002.png Parale al/lnvesti ator crodgers searcylaw.com ext Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Blvd West Palm Beach FL I Privileged and Confidential I Electronic communication is not a secure mode of communication and may be accessed by unauthorized persons This communication originates from the law firm of Searcy Denney Scarola Barnhart Shipley P.A and is protected under the Electronic Communication Privacy Act U.S.C The information contained in this E-mail message is privileged and confidential under Fla Jud Admin and information intended only for the use of the individual named above If the reader of this message is not the intended recipient you are hereby notified that any dissemination distribution or copy of this communication is strictly prohibited Personal messages express views solely of the sender and shall not be attributed to the law firm If you received this communication in error please notify the sender immediately by e-mail or by telephone at and destroy all copies of the original message Thank you JEFFREY EPSTEIN Plaintiff/Counter-Defendant SCOTT ROTHSTEIN individually and BRADLEY EDWARDS individually Defendants/Counter-Plaintiff IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICJAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Case No ORDER ON PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEINS REVISED OMNIBUS MOTION IN LIMINE SECTION EDWARDS TRIAL EXHIBITS THIS MATTER came before the Court for hearing on November and December upon Section Edwards Trial Exhibit List of the Revised Omnibus Motion in Limine tiled by Plaintift,Counter-Defendant Jeffrey Epstein Epstein D.E I The Court having reviewed the Motion and the Response filed by Defendant/Counter-Plaintiff Bradley Edwards Edwards D.E I having heard argument of counsel and being otherwise fully advised in the premises it is hereby ORDERED AND ADJUDGED that Epsteins Revised Omnibus Motion in Limine was directed at Edwards Amended Exhibit List dated November D.E On December I after two days of hearing and substantive Court rulings Edwards filed a Second Amended Exhibit List D.E identifying new items and modifying some of his earlier disclosed exhibits This Order only addresses the exhibits identified on Edwards November Exhibit List To the extent any exhibit numbers have been replaced with different items or new numbers have been added those will be subject to a separate Order after the appropriate motion and hearing The rulings set forth herein for all exhibits disclosed on Edwards December I Second Amended Exhibit List that have not been modified will remain unchanged EXHIBIT I I On or before December Edwards shall produce to Epstein all trial exhibits that have not been previously produced in the form to be introduced at trial with the exception of Exhibit No which is addressed separately in paragraph below Tr On or before January I Edwards shall produce to Epstein the specific court filings to be used as trial exhibits from the Crime Victims Rights Act proceeding Jane Does and United States of America U.S District Court Southern District of Florida Case No 80736-Civ-Marra/Johnson designated as Edwards Trial Exhibit No Edwards shall not produce each and every item identified on the Courts docket but shall cull out the specific items he intends to use at trial The Court hereby sustains Epsteins objection to Exhibit No as being overbroad The Court will revisit this ruling if Edwards narrows the documents he intends to introduce at trial Tr As set forth in more detai I below the Court has sustained Epsteins objections to a number of Edwards trial exhibits Those objections wi II be sustained unless there is a showing at trial that the exhibits are relevant and material to the issues to be determined For example exhibits may be admissible if they relate to Edwards three clients L.M E.W and Jane Doe if they relate to issues concerning Edwards preparation and evaluation of his clients cases or for any other reason enunciated by the Court on the record at the November and December hearings In those instances Edwards will be allowed to speak generically about the facts surrounding those exhibits but will not necessarily be allowed to introduce the exhibits at trial without fwther Order of the Court The Court will make decisions on an item-by-item basis at the appropriate time Any discussions relating to an exhibit to which an objection has been sustained shall be conducted outside the presence of the jury Tr I No I As set fo11h in more detail below the Com1 defers rulings on Epsteins objections directed to Edwards trial exhibits concerning Epsteins net worth and in support of Edwards punitive damages claim The Court will address these objections at the appropriate time Tr The Court makes the following specific findings LEGEND FOR EPSTEINS OBJECTIONS I All Objections All Objections except Authenticity Relevance Probative value substantially outweighed by danger of unfair prejudice confusion of issues misleading the jury or needless presentation of cumulative evidence Privileged Opinion Hearsay Authenticity Other please identify basis of objection IO Completeness I I Overbroad Not provided to Counsel for Epstein Prior to Filing Pretrial Stipulation Not a proper exhibit Trade secrets/Confidential Edwards Exhibit Description Epsteins Courts Ruling Ob_jections All applicable criminal statutes Not addressed at hearing All applicable Florida Statutes Not addressed at hearing Photos and information of Jeffrey Epsteins IO ll/29/l7Tr homes airplanes and automobiles Deferred Order confirmation from Amazon.com for Tr purchase of books SM IO I A realistic Sustained Introduction Slave Craft Roadmap for Erotic Servitude-Principles Skills and Tools and Training Miss Abernathy A Workbook for Erotic Slaves and Their Owners Non-Prosecution Agreement Overruled No Edwards Exhibit Description Epsteins Courts Ruling Objections Jane Doe I Complaint Tr Sustained Messages taken from message pads found at Tr I Epsteins home Deferred Not to be mentioned during opening statements Documents related to Jeffrey Epstein produced by Tr I Alfredo Rodriguez Deferred Not to be mentioned during ooening statements Jeffrey Epstein flight logs I Tr Sustained Jeffrey Epstein phone records JO I I Tr Sustained Sarah Kellens phone records I I Tr I Sustained Jail Visitation Logs Tr Sustained Jeffrey Epsteins probation file Tr I Sustained All probable cause affidavits related to criminal investigation of Jeffrey Epstein Deferred Victims statements to the FBI related to criminal Tr I investigation of Jeffrev Eostein Sustained Video of Search Warrant of Jeffrey Epsteins Tr home being executed Sustained Application for Search Warrant of Jeffrey Cannot Epsteins home be read Sustained Complaint Jane Doe Epstein and all subsequent as Tr Amended Complaints to subsequent Deferred Amended Comolaints In his December Second Amended Exhibit List Edwards changed the description of this exhibit to Video of Epstein Property Inspection This Order does not make any rulings on the new description and may be subject to a new Motion in Limine as Epstein deems appropriate No Edwards Exhibit Description Epsteins Courts Ruling Ob.iections All records of homes properties bank accounts Tr and any all records related to Jeffrey Epsteins Deferred assets Jeffrey Epsteins passport or copy Tr Sustained Jeffrey Epsteins drivers license or copy Cannot be read Tr Sustained List of corporations owned by Jeffrey Epstein Deferred Yearbooks of Jane Doe Tr Not produced Deferred Royal Palm Beach High School Year Book Tr Not produced Deferred Royal Palm Beach High School Year Book Tr Not produced Deferred Palm Beach Gardens High School Year Tr Book Not produced Deferred Affidavit and Application for Search Warrant on Tr I Jeffrey Epsteins home Sustained In his December Second Amended Exhibit List Edwards modified this exhibit to include additional descriptive language from Palm Beach State Attorneys File Exhibit The Comi finds that this language does not substantially change the exhibit and thus the Courts ruling holds No Edwards Exhibit Description Epsteins Courts Ruling Objections Notepads found in Jeffrey Epsteins home and/or during trash pulls outside of his home during Sustained in part and overruled in criminal investigation part The impact upon the issues as to preparedness knowledge as far as Mr Edwards is concerned his diligence as to discovery if those are called into question then this exhibit may be discussed The actual documents themselves are excessive and would be getting into other matters that would not be germane to Edwards three clients and therefore may not be used until discussed outside the presence of the jury The Palm Beach State Attorneys Criminal tile against Jeffrey Epstein Sustained in part and overruled in part If Edwards had access to formulate his positions as to the legitimacy of his three clients claims this file may come into play The sheer amount of the criminal file would also be relevant to Mr Epsteins state of mind at the time he filed the underlying Complaint The individual pages are not subject to admission and would need to be discussed outside the presence ofthe jury All documents related to Jeffrey Epsteins Tr conviction Deferred Jeffrey Epsteins criminal plea colloquy Tr I Deferred List of propetties and vehicles in Larry Visoskis I name The exhibit Deferred provided was an entire Motion which was denied not just the identified item No Edwards Exhibit Description Epsteins Courts Ruling Obicctions All of Jeffrey Epsteins Responses to Requests for II Tr Production Requests for Admission Answers to Deferred Interrogatories in this matter and cases All discovery related responses of Jeffrey Epstein Not addressed at hearing in this matter and cases I Jeffrey Epsteins Answers and Affirmative Defenses in all civil cases against him Deferred All Complaints in which Jeffrey Epstein is/was Tr defendant This also includes Deferred a motion which is not part of the stated exhibit Jeffrey Epsteins Deposition testimony and Not addressed at hearing discovery responses in this case and cases I Jeffrey Epsteins Deposition testimony and I I Not addressed at hearing discovery responses in State Court cases LM Jeffrey Epstein Case No AB and E.W Jeffrey Epstein Case No Jeffrey Epstein Deposition Testimony and Not addressed at hearing discovery responses in State Court case Jeffrey Epstein Scott Rothstein et al Case No Any and all newspaper articles on line articles or Tr publications related to Jeffrey Epstein Deferred Report and Analysis of Jeffrey Epsteins assets Tr I Deferred Video footage DVD of walk through site Tr inspection of Jeffrey Epsteins home Deferred Photos of al I of Jeffrey Epsteins properties cars boats and planes as to cars and Deferred boats Probable Cause Affidavits prepared against IO Tr I Jeffrey Epstein and Sarah Kellen Deferred No Edwards Exhibit Description Epsteins Courts Ruling Objections Documents related to or evidencing Jeffrey Tr Epsteins donations to law enforcement Sustained Victim Notification Letter from US Attorneys Tr Office to Victims Sustained Expert Dr Dennison Reeds Report of Victim I Tr Sustained Palm Beach Police Department Incident Report Tr I I dated Sustained All reports and documentation generated by Palm Beach Police Department related to Jeffrey Sustained Epstein All Witness Statements generated by Palm Beach Tr Police Department relating to Jeffrev Eostein Sustained Passenger Manifests of Jeffrey Epsteins aircraft Tr and private plane flight logs Sustained Passenger lists for flights taken by Jeffrey Epstein Sustained Letter from Jeffrey Epstein to Alberto Pinto Tr regarding house island project Sustained Jeffrey Epsteins bank statements Tr Deferred Jeffrey Epsteins tax returns Tr Deferred MC2 emails involving communications of Jeffrey Tr Epstein Jeff Fuller Maritza Vasquez Pappas Suat Not Produced Jean Luc Brunel and Amanda Grant Reserved ruling because documents not available DVD of plea and colloquy taken on Tr I Sustained Transcript of plea and colloquy taken on Tr Sustained Massage Table document Tr I marked as No Sustained is not a massage table In his December Second Amended Exhibit List Edwards modified this exhibit to include additional descriptive language CW SR The Court finds that this language does not substantially change the exhibit and thus the Courts ruling holds In his December Second Amended Exhibit List Edwards changed the description of this exhibit to Palm Beach Police Department Incident Report dated unredacted This Order does not make any rulings on the new description and may be subject to a new Motion in Limine as Epstein deems appropriate No Edwards Exhibit Description Epsteins Courts Ruling Obiections No Contact Orders entered against Jeffrey Epstein Tr Sustained I Criminal Score Sheet regarding Jeffrey Epstein Tr I Sustained Documents evidencing Jeffrey Epsteins Tr I Communitv Control and Probation Sustained Jeffrey Epsteins Sex Offender Registrations Tr from various states Deferred Jeffrey Epsteins Booking photograph Tr Document says Deferred cannot rely on this for legal action CAD calls to EL BRILLO WAY PALM Tr I BEACH FL Sustained List of Jeffrey Epsteins House contacts Tr document Sustained provided is not reflective of descriotion Documents related to Jeffrey Epsteins I Tr investments Deferred Letter from Chief Michael Reiter to Barry Tr Krischler Sustained List of planes owned by Jeffrey Epstein Tr document Deferred provided does not match description Letter from Guy Fronstin to Assistant State IO I Tr Attorney dated Sustained Letter from Guy Fronstin to Assistant State IO I Tr Attorney dated Sustained Letter from Guy Fronstin to Assistant State IO Tr Attorney dated I Sustained Letter from Guy Fronstin to Assistant State IO I Tr Attorney dated Sustained In his December Second Amended Exhibit List Edwards changed the description of this exhibit to Palm Beach Police Department Incident Report dated unredacted This Order does not make any rulings on the new description and may be subject to a new Motion in Limine as Epstein deems 267appropriate No Edwards Exhibit Description Epsteins Courts Ruling Ob_iections Letter from Guy Fronstin to Assistant State I Tr Attorney dated Sustained Letter from Goldberger dated Tr Sustained All subpoenas issued to State Grand Jury Tr Sustained in pait and overruled in part If Edwards had access to formulate his positions as to the legitimacy of his three clients claims these documents may come into play The sheer amount of the criminal file would also be relevant to Mr Epsteins state of mind at the time he filed the underlying Complaint The individual pages are not subject to admission and would need to be discussed outside the presence of the jury Documents related to the rental of a vehicle for Tr Vanessa Zalis document Sustained produced contains other items not identified on list Teds Sheds Documents Tr document Sustained produced contains other items not identified on list Documents related to property searches of Jeffrey Tr Epsteins properties Deferred Arrest Warrant of Sarah Kellen Tr Sustained I Police report regarding Alexandra Hall picking up Tr money dated Sustained List of Trilateral Commission Members Tr Sustained Alan Dershowitz Letter dated I and Statute Tr Not Produced Deferred Guy Fronstin letter dated Tr Sustained Jeffrey Epstein Account Information Tr Deferred No Edwards Exhibit Description Epsteins Courts Ruling Obiections Jeffrey Epstein Criminal Closeout Sheet Tr Sustained JEGE Inc Passenger Manifest II Tr I Sustained Hyperion Air Passenger Manifest I Tr Sustained Flight information for Dana Burns Tr Sustained Passenger List Palm Beach flights Tr Sustained Jeffrey Epstein notepad notes.re Maria I Tr Sustained Pleadings of Jane Doe I and US case document Tr provided is not Deferred what is identified on list Jeffrey Epstein th Amendment Speech Tr Deferred References to deposition excerpts not ruled upon fully subject to specific line reference rulings which will be subject to a seoarate order Reiter letter to Krisher dated Tr Not produced Deferred Alexandra Hall Police Report dated Tr Sustained Victims school records and transcripts Sustained Victim Notification letter Tr Sustained Police report of Juan Alessi theft at Jeffrey Tr I Eosteins home Sustained Victims Medical Records from Dr Randee Tr Speciale Sustained All surveillance conducted by law enforcement on Tr Jeffrey Epsteins home Sustained Emails received from Palm Beach Records related Tr to Jeffrev Eostein Sustained In his December Second Amended Exhibit List Edwards modified this exhibit to include additional descriptive language to Virginia Roberts The Court finds that this language does not substantially change the exhibit and thus the Courts ruling holds No Edwards Exhibit Description Epsteins Courts Ruling Obiections All items listed on the Palm Beach Police Property Tr Report Lists items not Sustained orovided All copies of convictions related to Jeffrey Tr Eostein Sustained Jeffrey Epstein criminal records Tr Sustained All documents produced by Palm Beach Police I Tr Department prior to the deposition of Detective Sustained Recarev Statements deposition transcripts videotaped Tr I depositions and transcripts taken in connection No ruling catch all with this and all related cases and exhibits thereto Any and all expert witness repo11s and/or records Not addressed at hearing catch generated in preparation for this litigation by any all partv to this cause Demonstrative aids and exhibits including but Not addressed at hearing catch not limited to charts diagrams and models all surveys photographs and similar material including blow-ups of the listed items/exhibits Edwards reserves all objections to Epsteins Not an exhibit Not an exhibit Exhibits I Edwards reserves the right to supplement and/or Not an exhibit Not an exhibit amend his Exhibit List By listing an Exhibit Edwards is not waiving his Not an exhibit Not an exhibit right to object to same at trial and does not waive their right to amend same All exhibits listed by Epstein subject to Edwards Not an exhibit Not addressed at hearing catch obiections all All pleadings and attachments in the action under Tr the Crime Victims Rights Act prosecuted by Sustained because of breadth Bradley Edwards on behalf of victims of lack of specificity without Epsteins criminal molestations prejudice to specific documents being produced as set forth above Specific documents must be culled out all documents on the docket may not be identified Edwards must narrow scope I Edwards Motions for Summaiy Judgment all Tr I attachments thereto and all Undisputed Facts Overruled In his December Second Amended Exhibit List Edwards modified this exhibit to include additional descriptive language and/or Property Receipts The Court finds that this language does not substantially change the exhibit and thus the Courts ruling holds No Edwards Exhibit Description Epsteins Courts Ruling Ob_jcctions All time records and hourly billing documentation Tr produced in discovery Overruled Edwards is ordered to produce/cull out within days if the documents have not already been produced All deposition testimony and discovery responses Not addressed at hearing catch by Epstein submitted in this action all All pleadings filed by Epstein in the Rothstein Tr bankruptcy proceeding Deferred All submissions by Epstein in connection with the Tr Rothstein deposition Deferred All Settlement Agreements between Epstein and Tr victims of his sexual molestations Deferred Phone Journal taken from Epsteins home and Tr produced to the FBI by Alfredo Rodriguez duplicative of Deferred Not to be mentioned Exhibit No during openin_g statement Photo depicting Virginia Roberts Ghislaine Tr I I Maxwell and Prince Andrew Sustained All flight logs for any Epstein owned or I Tr I controlled aircraft Sustained All emails produced by Defendant and/or all Not addressed at hearing emails produced by Plaintiff in this case Evidence of contributions to the Palm Beach Tr Police Dept duplicative of Deferred Dr Bernard Jansen Expert Report Attachments Not addressed at hearing and Back-up Documents October Jeffrey Epstein vs Scott Rothstein Bradley Not addressed at hearing Edwards and L.M Complaint December Jeffrey Epstein vs Scott Rothstein Bradley Not addressed at hearing Edwards and L.M Fourth Amended Counterclaim January I Jeffrey Epstein vs Scott Rothstein Bradley Not addressed at hearing Edwards and L.M Plaintiff/Counter-Defendant Jeffrey Epsteins Answer and Affirn1ative Defenses to Defendant/Counter-Plaintiff Bradley Edwardss Fourth Amended Counterclaim February Jeffrey Epstein vs Scott Rothstein Bradley Not addressed at hearing no Edwards and L.M Notice of Voluntary objections Dismissal August I Brad Edwards sic Times Records and Billing IO Not specifically addressed at Records related to this matter hearing but duplicative to Exhibit No and those rulings are incorporated herein No Edwards Exhibit Description Epsteins Courts Ruling Obiections Jeffrey Epsteins NY State Online Sex Offender Not specifically addressed at Registry Profile hearing but deferred with Exhibit New York Post article Billionaire Jeffrey Tr Epstein Im a sex offender not a predator Deferred February Any and all responses to Subpoenas Duces Tecum Not addressed at hearing catch with or without deposition all All Interrogatories and Answers thereto Requests Not addressed at hearing catch to Produce and Responses Requests for all Admissions and Responses thereto Any and all documents produced in this action Not addressed at hearing catch all Any and all depositions taken in this action Not addressed at hearing catch all Any documents or other exhibit attached to or Not addressed at hearing catch used during anv deposition in this action all Any and all exhibits documents etc referred to Not addressed at hearing catch in anv deposition all Any and all documents and exhibits designated by Not addressed at hearing catch all parties to this action all Any and all exhibits needed for impeachment or Not addressed at hearing catch rebuttal all Any and all pleadings filed in this action Not addressed at hearing catch all Any and all records produced or that will be Not addressed at hearing catch produced by all records custodians relative to this all action DONE AND ORDERED in West Palm Beach Palm Beach day of January In his December Second Amended Exhibit List Ed,vards has shifted Exhibit Nos through to Exhibit Nos through Edwards has also identified new exhibits at Exhibit Nos through This Order does not make any rulings on the new exhibits which may be subject to a new Motion in Limine as Epstein deems appropriate Copies provided to SERVICE LIST Jack Scarola Nichole Segal Searcy Denny Scarola Barnhart Shipley P.A Burlington Rockenbach P.A Palm Beach Lakes Boulevard Courthouse Commons Suite West Palm Beach FL West Railroad Avenue mep searcylaw.com West Palm Beach FL isx searcvlaw.com njs FLAm2ellateLaw.com scarolateam searcvlaw.com kbt FLA1212ellateLaw.com Co-Counsel for Defendant/Counter-Plaintiff Co-Counsel for Defendant/Counter-Plaintiff Bradley I Edwards Bradley Edwards Bradley Edwards Marc Nurik Edwards Pottinger LLC Law Offices of Marc Nurik Andrews Avenue Suite One Broward Boulevard Suite Ft Lauderdale FL Ft Lauderdale FL I brad e12llc.com marcl nuriklaw.com staff.efile 12athtojustice.com Counsel/or Defendant Scott Rothstein Co-Counsel for Defendant/Counter-Plaint Bradley Edwards Jack A Goldberger Scott Link Atterbury Goldberger Weiss P.A Kara Berard Rockenbach Australian Avenue Suite Angela Many West Palm Beach FL Link Rockenbach PA jgoldberger agwpa.com Palm Beach Lakes Boulevard Suite I smahonev agwpa.com West Palm Beach FL Co-Counsel for Plaintiff/Counter-Defendant Scott linkrocklaw.com ffrey Epstein Kara a linkrocklaw.com Angela c1 linkrocklaw.com Tina 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