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 ALLOW AMENDMENT TO EXHIBIT LIST Plaintif:uCounter-Defendant Jeffrey Epstein Epstein respectfully requests that the Court allow him to amend his Exhibit List and states INTRODUCTION The resetting of this case for trial on Counter-Plaintiff Bradley Edwards Edwards severed Counterclaim will require a new trial order and provides ample time to permit Epstein to amend his Exhibit List and add the exhibits he produced to Edwards on February February and March which all fell into general categories previously disclosed Edwards had knowledge of both the exhibits themselves and the content well before Epstein amended his Exhibit List on March to identify each document individually and therefore Edwards cannot claim surprise or prejudice For instance the exhibits included documents produced in this Epstein intends to substantially narrow the list of exhibits and will not be adding the more than exhibits Edwards complained about FILED PALM BEACH COUNTY FL SHARON BOCK CLERK PM case litigation Edwards was directly involved in and public records such as police reports and litigation involving Edwards three clients among other documents RECORD FACTS Pursuant to this Courts July Order Specially Setting Jury Trial D.E the deadline for the exchange of exhibit lists was days prior to trial At that time trial was set on December making the deadline October The July Order also provided in pertinent part ADDITIONAL EXHIBITS WITNESSES OR OBJECTIONS At trial the parties shall be strictly limited to exhibits and witnesses disclosed and objections reserved on the schedules attached to the Pre-Trial Stipulation prepared in accordance with paragraphs and absent agreement specifically stated in the Pre-Trial Stipulation or order of the Court upon good cause shown A party desiring to use an exhibit or witness discovered after counsel have conferred pursuant to paragraph shall immediately furnish the Court and other counsel with a description of the exhibit together with the reason for the late discovery of the exhibit or witness Use of the exhibit or witness may be allowed by the Court for good cause shown or to prevent manifest injustice D.E at emphasis added Epsteins current trial counsel were retained after the October deadline and on November in light of the uncertainty of what issues would be tried and the numerous outstanding evidentiary issues moved for a continuance of the trial and to extend the pre-trial deadlines including the deadline for allowing the parties to filed amended Exhibit Lists D.E Edwards opposed this request D.E On November the Court granted the continuance request and continued the special set trial to March The Courts Order however did not address Epsteins request for an extension of the pre-trial deadlines D.E On November Epstein amended his Exhibit List D.E On November November and December after the deadline set by the Courts July Trial Order and without leave of Court Edwards filed amended Exhibit Lists as well D.E Counsel sought clarification from the Court on November regarding the disclosure cutoff ruling The Court granted Edwards Motion to Reconfirm the Existing Pre-Trial Deadlines because of his concern over additional discovery The Court noted however that it would permit additional limited discovery upon further motion D.E On November December and December the parties participated in extensive special set hearings wherein the Court made rulings relating to the issues and evidence to be presented at trial The parties filed their Joint Pretrial Stipulation on December attaching their last filed Exhibit Lists Epsteins November Exhibit List and Edwards December Exhibit List D.E In the Pretrial Stipulation the parties agreed that they did not waive their right to amend their Exhibit Lists Id On December February February and March Epstein made a rolling production to Edwards of his trial exhibits Pursuant to the Clerks pre marking guidelines Exhibit A on March Epstein served his Clerks Trial Exhibit List which identified each of the exhibits individually D.E These exhibits were comprised of the following a exhibits already produced in this case exhibits concerning L.M E.W and Jane Doe the lntervenors/Edwards three clients exhibits relating to a defamation lawsuit Edwards filed in against Alan Dershowitz one of Epsteins attorneys printouts from Edwards current website and verdicts and judgments referenced on the website Edwards property records and documents from the Crime Victims Rights Act CVRA action At the March hearing in response to Edwards Motion to Strike Untimely Supplemental Exhibits the Court found that the exhibits Epstein produced on February February and March were untimely and could not be used at trial While of the exhibits are the subject of a request for an in camera review because of privilege claims asserted by Edwards and the lntervenors L.M E.W and Jane Doe,2 the remaining exhibits consist of documents produced in this and the underlying cases and public records Now that no trial order is yet in place and because as fully explained below Edwards cannot claim surprise by any of the additional exhibits and will not otherwise be prejudiced by Epsteins identification of the subject exhibits Epstein requests permission to amend his Exhibit List to include a narrowed list of the previously disclosed exhibits and other exhibits Epstein deems appropriate ARGUMENT Epstein respectfully requests an Order granting him permission to amend his Exhibit List and to revisit the Courts earlier ruling that the exhibits were untimely and cannot be used at trial The documents Epstein seeks to add are relevant do not include any of the documents Edwards claims are privileged4 cannot come as any surprise to Edwards and will not prejudice Edwards in light of the timing of their disclosure In light of the pending request for an in camera review the request for relief set forth in this Motion does not pertain to those exhibits To date the Courts rulings on that Motion have not been memorialized in a written order Epstein has filed a Motion for an in camera review of the exhibits D.E I Amendment of Exhibit Lists is Timely Under the Circumstances and is Allowed Pursuant to the Parties Joint Pretrial Stipulation There is no trial order in place However amendments to the parties Exhibit Lists are permissible pursuant to the Courts July Trial Order and the parties December Joint Pretrial Stipulation The July Order provided in pertinent part ADDITIONAL EXHIBITS WITNESSES OR OBJECTIONS At trial the parties shall be strictly limited to exhibits and witnesses disclosed and objections reserved on the schedules attached to the Pre-Trial Stipulation prepared in accordance with paragraphs and absent agreement specifically stated in the Pre-Trial Stipulation or order of the Court upon good cause shown D.E at emphasis added In addition in their December Pretrial Stipulation the parties expressly agreed that they do not waive their right to amend their Exhibit Lists and to identify additional objections for those exhibits that have not yet been disclosed and/or provided to correspond with the parties respective Exhibit Lists D.E at emphasis added Thus an amendment should be allowed based on the Pretrial Stipulation alone In fact it would be an abuse of discretion for the Court to decline the requested amendment See City of Opa Loca Williams So 2d Fla 1st DCA because the parties pre-trial stipulation allowed for amendments to the stipulation to list exhibits and witnesses the JCC abused his discretion in denying the motion to amend See also Palm Beach Polo Holdings Inc Broward Marine Inc So 3d Fla 4th DCA citation and internal quotation marks omitted The Pretrial Stipulation is a powerful blueprint that fully enables a well-run and fair trial It is the policy of the law to encourage and uphold stipulations in order to minimize litigation and expedite the resolution of disputes II The Scope and Focus of the Trial was Established in December At the November December and December hearings the Court established the scope and focus of the trial Specifically the Court made evidentiary rulings of the type of evidence that would be allowed at trial and made findings about the extent to which Edwards would be able to present evidence about his three clients cases Those rulings required Epsteins trial team to reevaluate their trial strategy and the supporting evidence which resulted in an amended Exhibit List Now that the Fourth District Court of Appeal has upheld this Courts Order severing the claims Epstein will again need to re-evaluate his trial strategy and supporting evidence I Edwards Will Not Otherwise be Prejudiced by the Amendment While a trial judge has broad discretion in determining whether to permit introduction of an exhibit not disclosed pursuant to a pretrial order the trial judges discretion should be guided primarily by whether the objecting party would be prejudiced by the admission of the evidence Tomlinson-McKenzie Prince So 2d Fla 4th DCA citing Bingerv King Pest Control So 2d Fla Accord Gaspars Passage LLC RaceTrac Petroleum Inc No 2Dl WL at Fla 2d DCA Apr The trial court also abused its discretion by denying Gaspars motion to amend its exhibit list in August several weeks before trial The intended exhibits became relevant as a result of the amended pleadings but again the trial court failed to conduct the required prejudice analysis before denying the motion As the Fourth District explained in Tomlinson-McKenzie The objecting party is prejudiced by the admission of such evidence if the party might have taken some action to protect itself had it had timely notice of the witness or exhibit and there exists no other alternatives to alleviate the prejudice The supreme court in Binger stated that Prejudice in this sense refers to the surprise in fact of the objecting party and it is not dependent on the adverse nature of the testimony Other factors which may enter into the trial courts exercise of discretion are i the objecting partys ability to cure the prejudice or its independent knowledge of the existence of the witness ii the calling partys possible intentional or bad faith noncompliance with the pretrial order and i the possible disruption of the orderly and efficient trial of the case or other cases Id quoting Binger So 2d at In Tomlinson-McKenzie the appellate court found that appellees could not have been prejudiced by the introduction of the surveillance tape at trial in the sense that prejudice refers to the surprise in fact of the objecting party because the motion to amend the witness and exhibit list was filed several months prior to the actual trial date In addition the other factors set out in Binger militate strongly toward admission of the surveillance tape There was no finding that appellants failed to comply with the pretrial order in bad faith The record reflects that appellants moved to amend the witness and exhibit list as soon as the surveillance tape became available Further an objecting party may not having closed its eyes to the existence of evidence prior to trial claim that the admission of that evidence would disrupt the orderly and efficient trial of the case So 2d at Similarly here Edwards cannot be prejudiced by the introduction of the subject exhibits because this Motion to Amend his Exhibit List is being filed before the actual trial date has even been reset See id In addition the other factors set out in Binger militate strongly toward admission of the subject exhibits Id There was no finding that appellants failed to comply with the pretrial order in bad faith Id Epsteins current counsel had not been retained when the Court entered its July Order Specially Setting Jury Trial Nevertheless both Epstein and Edwards filed Exhibit Lists after the deadline set forth in that Order The request to amend is not made in bad faith but rather necessitated by the change in the scope and focus of the trial as determined by this Court in December Epsteins new counsel took steps in good faith after that hearing to reevaluate all evidence compiled to determine how to best defend Epsteins case and determined an amendment to Epsteins Exhibit List was warranted Further Edwards may not having closed his eyes to the existence of evidence prior to trial claim that the admission of that evidence would disrupt the orderly and efficient trial of the case Id IV The Exhibits are Relevant Epstein seeks to amend his Exhibit List to be allowed to add documents that are relevant to this litigation to include both a substantially modified list of those items identified on his March Clerks Trial Exhibit List not including the documents that Edwards claims are privileged and are currently subject to a request for an in camera review and any other documents Epstein may determine are relevant A Exhibits from the Production in this Case On his November Exhibit List Epstein identified at No All documents produced by any party or non-party in this matter Epstein made a rolling production of those exhibits on December and March which included documents produced by Edwards documents produced by Wackenhut Security documents produced by Michael Legamaro a non-party RRA investor and documents produced by other third parties On his March Clerks Trial Exhibit List Epstein identified each of the documents produced under this general category individually Because the subject documents were already produced in this case and Epstein produced them to Edwards again in December and March as trial Should the Court find that the documents are not privileged Epstein will amend his Exhibit List to add those exhibits as well exhibits Edwards could not be surprised or prejudiced by the introduction of these items at trial a trial which has yet to be reset Exhibits Relating to L.M E.W and Jane Doe On his November Exhibit List Epstein identified at No All public records and news articles relating to any witnesses listed by either party During the November December and December hearings the Court advised the parties that Epstein would essentially need to prove each allegation of his original Complaint including the allegation that Edwards three clients L.M E.W and Jane Doe claims against Epstein were weak The Court also indicated it would allow Edwards to discuss his three clients claims against Epstein and Edwards advised that his three clients would testify at trial Because of these rulings Epsteins counsel shifted their focus from defending probable cause to providing additional evidence to support the fact that Edwards clients claims were weak at the time Epstein filed the original proceeding In light of the Courts rulings that L.M E.W and Jane Doe could testify in this malicious prosecution action Epsteins counsel re-inventoried the information obtained from extensive background research on each of Edwards clients in the underlying cases and conducted additional background research on them in preparation for cross examining these witnesses as to the weakness of their respective cases and their credibility This was a large undertaking because Edwards three clients have extensive criminal histories relating to incidents throughout the state Epstein made a rolling production of these documents to Edwards on February February and March and then listed them individually on his March Clerks Trial Exhibit List The documents directly relate to Edwards witnesses credibility trustworthiness and background L.M and E.W have both been arrested for prostitution L.M admitted to law enforcement that she was involved in prostitution because her mother was a prostitute All three clients have been arrested for shoplifting have drug problems and have admitted to lying In fact during her deposition in her lawsuit against Epstein L.M provided testimony that contradicted a sworn statement she gave to the FBI and then admitted that she lied to the FBI in that statement L.M clearly perjured herself and Epstein should be entitled to use documents to challenge her credibility at trial Because Edwards represents L.M E.W and Jane Doe and is fully aware of evidence of their pasts already provided in the underlying civil cases none of this information can or does come as a surprise to him As such Edwards should not be permitted to hide behind the purportedly late disclosure of the documents and the Court should allow Epstein to amend his Exhibit List to identify these exhibits The majority of the more than newly identified exhibits that Edwards complained about relate to this category Epstein plans to review the documents already produced and substantially narrow the number of exhibits disclosed in this category to the extent that the Courts ruling to exclude them was based on the large number of newly identified exhibits Alan Dershowitz On his March Clerks Trial Exhibit List Epstein identified exhibits relating to a defamation lawsuit Edwards filed in January against Alan Dershowitz one of Epsteins attorneys Those documents were produced to Edwards under Epsteins Exhibit No public records of any witness in February In the Dershowitz action Edwards alleged Bradley Edwards and Paul Cassell Alan Dershowitz 17th Judicial Circuit Broward County Case No Despite having previously been the victim of character assassination by the Defendant ALAN DERSHOWITZ associate and client Jeffrey Epstein BRADLEY EDWARDS enjoys a highly favorable national reputation particularly related to his work in defending the rights of child victims of sexual abuse Dershowitz Complaint emphasis added Edwards alleged that Dershowitz made a media assault upon him and Paul Cassell to attack his reputation and character DERSHOWITZ initiated a massive public media assault on the reputation and character of BRADLEY EDWARDS and PAUL CASSEL accusing them of intentionally lying in their filing of having leveled knowingly false accusations against the Defendant DERSHOWITZ without ever conducting any investigation of the creditability of the accusations and of having acted unethically to the extent that their willful misconduct warranted and required disbarment Dershowitz Complaint In April Edwards Cassell and Dershowitz resolved their respective claims and Edwards and Cassell informed the Court that the filing of their action against Dershowitz was a tactical mistake Dershowitz Notice of Withdrawal of Motion for Partial Summary Judgment In order to maximize his recovery on his claims against Dershowitz Edwards had to and did allege that his reputation had recovered from any effects of Epsteins suit against him and that Dershowitz defamatory public statements were the sole source of harm to his reputation Now that Edwards has admitted that suing Dershowitz was a tactical mistake and can obtain no further financial gain from claiming that Dershowitz is responsible for the harm to Edwards reputation Edwards once again claims that Epstein is the sole cause of harm to his reputation Epstein therefore identified exhibits from the Dershowitz defamation lawsuit that contradict this position Because Edwards was a party to the Dershowitz lawsuit the documents are no surprise to Edwards In fact it was Edwards who made those allegations in that lawsuit and he cannot and will not be prejudiced by allowing relevant exhibits from that lawsuit to be identified now Accordingly Epstein asks the Court to allow him to amend his Exhibit List to identify exhibits relating to the Edwards Dershowitz litigation Edwards Website and Verdicts On his March Clerks Trial Exhibit List Epstein identified printouts from Edwards current website and verdicts and judgments referenced on the website These documents too were produced to Edwards under Epsteins Exhibit No public records of any witness in February On his website Edwards touts his jury verdicts including verdicts he has received since Epstein filed suit million million million etc It is important for the jury to understand and see how Edwards has not suffered from Epsteins filing of the lawsuit against him Like the other exhibits these documents are no surprise to Edwards as they come directly from his website or relate to litigation he was directly involved in Accordingly this Court should permit Epstein to amend his Exhibit List now to identify those documents Edwards Property Records Other public records Epstein produced to Edwards in February as part of his Exhibit No public records of any witness included Edwards real property ownership records Epstein identified these specifically on his March Clerks Trial Exhibit List The documents will show the jury how Edwards success after Epstein filed suit has allowed him to invest in more expensive and larger real estate These documents are public records which directly involve Edwards and transactions of which he has direct knowledge Edwards therefore cannot claim surprise and Epstein should be allowed to amend his Exhibit List to identify these documents See Gaspars Passage LLC No WL at If as Gaspars counsel alleged some of the exhibits were public record Race Trac would have difficulty establishing prejudice Indeed the transcript reflects that RaceTrac was aware of at least the property appraiser records-which are public record-because its expert had relied on a report that incorporated those records citing Tomlinson-McKenzie So 2d at An objecting party may not having closed its eyes to the existence of evidence prior to trial claim that the admission of that evidence would disrupt the orderly and efficient trial of the case CVRA Documents Edwards has taken the position that his involvement in the Crime Victims Rights Act action against the United States Government was a motive for Epstein to file suit against him Because Edwards has made it clear that he intends for that action to play a significant role in his presentation of his case Epstein produced to Edwards select documents from that action in December February and March that he intended to use as trial exhibits and then individually identified the documents on his March Clerks Trial Exhibit List Contrary to Edwards position he was not pursuing the CVRA action at the time Epstein filed this litigation Rather in August Edwards informed the Federal Court that it was not in his clients best interest to pursue that action In February the Federal Court denied Edwards clients Motion to Unseal the Non-Prosecution Agreement Other than putting the Court on notice of his change of firm Edwards did nothing in the case during his tenure at Rothstein Rosenfeld Adler RRA In fact he did nothing until September almost a year after RRA imploded and Epstein filed this litigation Epstein should be allowed to present evidence to the jury to show that Edwards was in fact not pursuing the CVRA action the Governments defenses and Epsteins limited involvement in that action Edwards himself identified the entire action on his Exhibit List Edwards Trial Exhibit No While he has produced certain documents from that action he has not listed them individually as required by the Clerks guidelines Epstein therefore should be allowed to amend his Exhibit List to identify documents from the CVRA action CONCLUSION Although a judge has broad discretion in determining whether to exclude evidence due to a partys failure to disclose the evidence within the time required by a pretrial order the exclusion of such evidence is a drastic remedy which should pertain in only the most compelling circumstances and only after the judge has made a case-specific determination as to whether admission of the evidence would result in actual procedural prejudice to the objecting party Med Logistics Inc Marchines So 2d Fla 1st DCA citing Binger According to Binger any prejudice of late-disclosed exhibits must be caused by surprise in fact So 2d at As set forth above the subject documents were produced to Edwards as trial exhibits in February and March and are documents Edwards already had in his possession or of which Edwards was already aware through litigation in his underlying client cases against Epstein or his own defamation lawsuit against Dershowitz or because of their public nature Furthermore the documents go the very heart of Epsteins defense-that Edwards cannot establish that Epstein did not have probable cause to file suit against Edwards that Edwards clients cases were weak and that Edwards has no damages See Tomlinson-McKenzie So 2d at The surveillance tape of Ms Prince sitting in a car for extended periods of time and sitting on bleachers at her sons soccer matches goes to the very heart of this case-the extent of her injuries The surveillance tape provides a direct challenge to Ms Princes assertions that the injuries sustained in the accident diminished her capacity to earn a living because she could not sit for extended periods of time as required by her job Under the circumstances the trial judges omission of the surveillance tape was not harmless error Accordingly Epstein respectfully requests that the Court grant this Motion and allow him to amend his Exhibit List as set forth herein CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on April 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 Rachel Glasser FBN Primary Scott linkrocklaw.com Primary Kara linkrocklaw.com Primary Rachel linkrocklaw.com Secondary Tina linkrocklaw.com Secondary Troy linkrocklaw.com Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein SERVICE LIST Jack Scarola Karen Terry David Vitale Jr Searcy Denny Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach FL mep searcylaw.com jsx searcylaw.com dvitale searcylaw.com scarolateam searcylaw.com terryteam searcylaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Bradley Edwards Edwards Pottinger LLC Andrews Avenue Suite Fort Lauderdale FL brad epllc.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Jack A Goldberger Atterbury Goldberger Weiss P.A Australian A venue Suite West Palm Beach FL goldberger agwpa.com smahoney agwpa.com Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein Philip Burlington Nichole Segal Burlington Rockenbach P.A Courthouse Commons Suite West Railroad A venue West Palm Beach FL pmb FLAppellateLaw.com njs FLAppellateLaw.com kbt FLAppellateLaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Marc Nurik Law Offices of Marc Nurik One Broward Boulevard Suite Ft Lauderdale FL marc nuriklaw.com Counsel for Defendant Scott Rothstein Paul Cassell University Salt Lake City UT cassellp law utah edu Limited Intervenor Co-Counsel for L.M E.W and Jane Doe Jay Howell Jay Howell Associates Cesery Blvd Suite Jacksonville FL jayhowell.com Limited Intervenor Co-Counsel for L.M E.W and Jane Doe EXHIBIT A Civil Eyidence Pre.:Marking Guidelines Clerk Comptroller Palm Beach County Pagel of2 Tuesday January ABOUT THE OFFICE SHARON Ill DOCK derk Com1 1roner lillm Do.,d1 County Search Recorc:ls Now soorch Covil Records l.ti.W Search Official Records Jy 267coi.JRT SERVICES 267clRCUffCIVIL COURT COUNTY CIVIL COUR CRlillNAL COURT E-FILINO EVIDENCE CIVIL PRE MARKING GUIDELINES HOO-ofoHOO HO INDIGENT STATUS JURY DUTY SElf SERVICE CENTER TRAFFIC VIOLATIONS UNll;IED FAl,tll COUR Home I Links Conlacl Us I Locallons I FAQ SEAf CH _lle EnlerSearchTerm PUBLICATIONS NEWSROOM CAREERS LEGAL COMMUNITY FEES COSTS Evidence Civil rnE-iIARKING GUIDELINES Exhlbltlls Requlrements An upda!edJeg1ble;aad spec1fic"exlii6i isff,IUST be proy1aeaCLtljeJoaLclerK onJneirsday _oI JrialJ The list Is to lnclud the Case the party name party type Pili Resp Mo11er,Falher etc exhibit description of the exhibit and hearing/trial date criie xbJ91ls_musl 6e11um6ei-ei:IJ;equeo.lian f,tm_ex ub1!s 247stiyfilcli.sta oy_ana_all e_ace?ple Exhibit Requirements All exhibits that will be entered into evidence must be pre-marked using the Cii,ii Exhibit Card Template and affixed to the back of the exhibit All exhibits must be marked for ID on the exhibit card Numbers and letters only No symbols Exhibit No more than characters Including spaces The exhibits list must be numbered sequentially i.arge demonstrative poster boards or Items be used In court for evidence must be accompanied by smaller version for submissions to the Clerk Exhibits.must be stapled bound or raslened together with an ACCO type fastener two-pronged locking paper compressor NO NOTEBOOK BINDERS N.O 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Accesslbllily Privacy Policy Terms ornse Employee lnlormallon Ethics Homne Cl Clerk Co pimller Palm Beach County Under-Florida law email addresses are public records If you do not wanl your email address released In response lo a publlc records request do not send electronic em II lhis e_ ilY lns a tl ls of ce ph or In l!ng Pursuant lo F.S the custodian olpubllc records ts Hampton Peterson 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 I v"x i X5 EO5 5a r?q CX 9r Cy rq rqC M3 ş?:c p/p0 5H V)V 6T Y2 G5 qrM?r?qr?r9 q?10Cy rCX qr l1 X?l 3K fm?Q Z2f CX CX gT L??T 2E Cy 3P EM3 J4T L?h??M q?ᡚ?Y r??O?rJt CTX i P!e i I CTX rC YY I 1e 2j CTX X0T1i k3v Jh/e0h1 H(K W/Q0 CTX j?!k 5B r2 CTX A A A 4v z"p A A A0A?A AK CTX A A?!k CX qCX YCX i!d A fi8 l8 yuZ 6L pH m?c sP;0 6ZR Ni P0 0Q X(P0s s(s p0 Pp CTX qq dR B/J Va A y!k N?M??N rC f?Nla3 Yz 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