JEFFREY EPSTEIN Plaintiff/Counter-Defendant vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually Defendants/Counter-Plaintiff Electronically Filed PM 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 N?q qr NEeD K?i N?M?qr EeD k??O I CTX U3 U3 U3 U3 S6 E"L I I I5K7C:I 9O U3 Cn qrr qr q??r?q 9qr CTX G5 qr CX rC l0 WS zN pf1 ODV8L?m jC1DxV CTX CTX A qr 10Cy rYY Ң??P?V CTX C"C rqM?rq?q?qr qr CTX YY Jb?C.y CTX CTX GG4 A A G5 C.C M??r 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S5kB??a iG wA CTX U2 6Y CTX U2 6Y I K,,j j,s 6Y P!p qr 10Cy qr YY G?O 9K mSd X0 9r?yal 1d bY0 XNf??qN D?J CTX P!Z b!o C,C qrM 10Cy qr8 I fX2 9R lO KV CTX Oo CTX A qr r?qr rq YY Lsy7H4 C,6E IL CTX U3 CTX J,O3_3xx qrM?r q?CX Y9/C 9CX CTX Y10Cy CX CX CX YC YY FV uTl bEWa ȓjJ-8 Gc G??Q9E 9Wq CTX CTX Up i I A 9_ qr qr YY D.X 7s F??Y bc3_c iH CTX CTX A qr 10Cy YY EMq 7H AY mK9Z BY A2 P6L N7 CTX CTX a I I i qr rC CTX CTX 7O I FMM qr qr i I I3 CTX Z6 I L(K4 P:u Z6P CTX y8 DCA Accordingly a motion in limine is proper to exclude any irrelevant and immaterial evidence when its probative value is outweighed by prejudice Devoe Western Auto Supply Co So 2d Fla 2d DCA A motion in limine is especially appropriate to preclude inadmissible evidence that will be highly prejudicial to the moving party and if referenced in a question or by counsel would unlikely be disregarded by the jury despite an instruction by the court to do so Fischman Suen So 2d Fla 4th DCA In the case at hand Epstein requests that this Court enter an Order precluding any reference to the below-listed matters/items A All of the Exhibits listed below The items listed below appear on Edwards Amended Trial Exhibit List However despite Epsteins request for same back in April they were never turned over to Epstein As such Edwards should be precluded from utilizing or referencing them at trial Given the sheer volume of the list exhibits of items that have not been turned over it would be impossible for Epstein to review and evaluate same prior to trial causing unfair prejudice Escutia Greenleaf Products Inc So 2d Fla 1st DCA Agrofollajes S.A E.I Du Pont De Nemours Co Inc Nos WL at Fla 3d DCA Dec stating Florida courts have explained that the rules of discovery are intended to avoid surprise and trial by ambush Sanction for failure to make discovery may be striking of pleadings prohibition of introduction of evidence at trial or refusal to permit presentation of claim or defense Mitchem Grubbs So 2d Fla 1st DCA Furthermore these items are irrelevant to the case at hand pursuant to of the Florida Statutes and to the extent that Edwards could argue that any are relevant any alleged probative value is substantially outweighed by the danger of unfair prejudice confusion of issues misleading the jury or needless presentation of cumulative evidence FLA STAT Dailey Multicon Development Inc So.2d Fla 4th DCA Unfair prejudice has been described as an undue tendency to suggest decision on an improper basis commonly though not necessarily an emotional one This rule of exclusion is directed at evidence which inflames the jury or appeals improperly to the jurys emotions Wright State So 3d Fla Here the below-listed items undeniably have no bearing on Edwardss abuse of process or malicious prosecution claims In fact the repeated references to victim prove that While it is clear from Edwardss Exhibit List that Edwards would like to re-litigate his previous cases against Epstein these items undeniably are irrelevant and intended to do little more than unfairly inflame and prejudice the jury with irrelevant information from Epsteins criminal case and prior civil cases not one of which is an abuse of process or malicious prosecution case Video of Jeffrey Epsteins home and route from victim to Epsteins home Documents related to Jeffrey Epstein produced by Alfredo Rodriguez Jeffrey Epstein phone records Sarah Kellens phone records All probable cause affidavits related to criminal investigation of Jeffrey Epstein All evidence information and documents taken or possessed by FBI related to criminal investigation of Jeffrey Epstein Victims statements to the FBI related to criminal investigation of Jeffrey Epstein Video of Search Warrant of Jeffrey Epsteins home being executed Application for Search Warrant of Jeffrey Epsteins home 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 Tape recording or transcript of recording of conversation between Jeffrey Epstein and George Rush Notepads found in Jeffrey Epsteins home and/or during trash pulls outside of his home during criminal investigation All statements made by Jeffrey Epstein List of properties and vehicles in Larry Visoskis name 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 Audio tape of Haley Robson Photographs videos and books taken in the search warrant of Jeffrey Epsteins home Documents related to or evidencing Jeffrey Epsteins donations to law enforcement Victim Notification Letter from US Attorneys Office to Victim Expert Dr Dennison Reeds Report of Victim 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 MC2 emails involving communications of Jeffrey Epstein Jeff Puller Maritza Vasquez Pappas Suat Jean Luc Brunel and Amanda Grant Massage Table Lotions taken from Jeffrey Epsteins home during search warrant Computers taken from Jeffrey Epsteins home during search warrant Vibrators dildos and other sex toys taken from Jeffrey Epsteins home during search warrant CAD calls to El Brillo Way Palm Beach FL Letter from Chief Michael Reiter to Barry Krischler Letter from Guy Fronstin to Assistant State Attorney dated Letter from Guy Fronstin to Assistant State Attorney dated Letter from Guy Fronstin to Assistant State Attorney dated Letter from Guy Fronstin to Assistant State Attorney dated Letter from Guy Fronstin to Assistant State Attorney dated Letter from Goldberger dated All subpoenas issued to State Grand Jury Documents related to the rental of a vehicle for Vanessa Zalis Teds Sheds Documents Documents related to property searches of Jeffrey Epsteins properties Arrest Warrant of Sarah Kellen Police report regarding Alexandra Hall picking up money dated List of Trilateral Commission Members of Guy Fronstin letter dated Jeffrey Epstein Polygraph Results Victims GED testing information and results JEGE Inc Passenger Manifest Hyperion Air Passenger Manifest Flight information for Dana Bums Passenger List Palm Beach flights Jeffrey Epstein notepad notes Reiter letter to Krisher dated Alexandra Hall Police Report dated Compulsory Medial Examination of victim CMA Victims school records and transcripts Victim Notification letter dated Victims employment records from IHOP Police report of Juan Alessi theft at Jeffrey Epsteins home Victims Medical Records from Milton Girls Juvenile Facility Victims Medical Records from Dr Randee Speciale Victims Medical Records from Wellington Regional Hospital Victims Medical Records from St Marys Medical Center Victims Medical Records from United Health All surveillance conducted by law enforcement on Jeffrey Epsteins home Emails received from Palm Beach Records related to Jeffrey Epstein All items listed on the Palm Beach Police Property Report Lists All items taken in the execution of the search warrant of Jeffrey Epsteins home El Brillo Way Palm Beach FL All documents produced by Palm Beach Police Department prior to the deposition of Detective Recarey Photographs of all persons listed on Victims Witness Lists 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 Curriculum vitae of Dr Ryan Hall Any articles or publications of Dr Ryan Hall Any articles or publications of Dr Richard Hall Any articles or publications of Dr Dennison Reed All items and documentation review by Dr Dennison Reed Transcript and video DVD oflME of Victims All exhibits to Dr Demlison Reeds Deposition All exhibits to Dr Richard Halls Deposition All items and documents reviewed by Dr Richard Hall All items and documents reviewed by Dr Ryan Hall Demonstrative aids and exhibits including but not limited to anatomical charts diagrams and models surveys photographs and similar material including blow-ups of the foresaid items Any and all mortality tables Any argument statement evidence or comment related to the criminal charges to which Epstein plead or any alleged investigation Since it is irrelevant and immaterial to this suit Epstein requests that Edwards be precluded from using any pleading testimony remarks questions documents exhibits items investigation results or arguments related to any criminal investigations or charges as related to Epstein that might inform the jury of such facts and that Edwards further instruct his witnesses to omit such facts from their testimony This is improper for trial as it is impermissibly being offered as relevant solely to prove bad character and would unduly inflame and prejudice the minds of the jury against Epstein a FLA STAT Unfair prejudice has been described as an undue tendency to suggest decision on an improper basis commonly though not necessarily an emotional one This rule of exclusion is directed at evidence which inflames the jury or appeals improperly to the jurys emotions Wright State So 3d Fla Byrd BT Foods Inc So 2d Fla 4th DCA See also Canales Compania De Vapores Realma S.A So 2d Fla 3d DCA Any probative value of testimony about marriage proposal plaintiff purportedly made offering money to woman to marry him so that he could avoid deportation on issue of plaintiffs credibility was far outweighed by its prejudicial effect DeSantis Acevedo So 2d Fla 3d DCA Probative value of the defendants cross-examination of the plaintiff and his main witness about prior unrelated incidents that insinuated that both the plaintiff and the witness had been dishonest was outweighed by prejudicial nature of questions This is an abuse of process and malicious prosecution case that Edwards is prosecuting against Epstein This information has no probative value whatsoever to the elements necessary to prove either claim or Epsteins defense Any reference to Epsteins Assertion of his Fifth Amendment Privilege to questions that are not directly related to the issues in this case Epstein asserted his Fifth Amendment Privilege in response to discovery in this matter when the requested information concerned allegations of sexual exploitation of minors Said allegations are undeniably irrelevant to the case at hand pursuant to of the Florida Statutes and to the extent that Edwards could possibly try to establish that this line of discovery is relevant any alleged probative value is substantially outweighed by the danger of unfair prejudice confusion of issues misleading the jury or needless presentation of cumulative evidence FLA STAT Dailey Multicon Development Inc So.2d Fla 4th DCA Unfair prejudice has been described as an undue tendency to suggest decision on an improper basis commonly though not necessarily an emotional one This rule of exclusion is directed at evidence which inflames the jury or appeals improperly to the jurys emotions Wright State So 3d Fla Byrd BT Foods Inc So 2d Fla 4th DCA Were any of the above facts made known to the jury it would be highly improper and prejudicial to Epstein Moreover this evidence is being offered impermissibly as solely to prove bad character The use of any derogating adjectives when referencing Epstein Edwards has continually referenced Epstein by the use of provoking and offensive misnomers such as billionaire pedophile or convicted child molester Such commentary is inappropriate and if Edwards did so at trial it would irrefutably be done solely to impermissibly inflame the jury or appeal improperly to the jurys emotions Wright State So 3d Fla Any reference to any and all cases against Epstein in which Edwards was not counsel of record While a limited amount of the information regarding Edwardss prosecution of cases against Epstein is germane to the issues in this case any mention of or use of information from any other case is not Such information is unfairly prejudicial Honeywell Intern Inc Guilder So 3d Fla 3d DCA As seen from Edwards trial exhibit list items above it is apparent that he intends to use as much information from other cases as possible This evidence is undeniably irrelevant to this cause of action and is solely being used in an effort to impermissibly inflame the jury or appeal improperly to the jurys emotions or solely to prove bad character Wright State So 3d Fla Byrd BT Foods Inc So 2d Fla 4th DCA I the introduction of the evidence tends in actual operation to produce a confusion in the minds of the jurors in excess of the legitimate probative effect of such evidence if it tends to obscure rather than illuminate the true issue before the jury then such evidence should be excluded City of Miami Calandra So 2d Fla 3d DCA citing Perper Edell So 2d Fla See also Agrofollajes S.A E.I Du Pont De Nemours Co Inc So 3d Fla 3d DCA probative value outweighed by prejudicial effect when evidence improperly becomes focus of trial Maldonado Allstate Ins Co So 2d Fla 2d DCA probative value of bicyclists status as an illegal alien was outweighed by unfair prejudice confusion of the issues and misleading of the jury as the evidence and instruction concerning status as an illegal alien improperly changed the focus of the jurys attention WE HEREBY CERTIFY that a true and correct copy of the foregoing was served via electronic service to all parties on the attached service list this September Tonja Haddad Coleman Tonja Haddad Coleman Esq Florida Bar No Tonja Haddad PA SE ih Street Suite Fort Lauderdale Florida facsimile Attorneys for Epstein SERVICE LIST CASE NO Jack Scarola Esq sx searcylaw.com mep searcylaw.com Searcy Denney Scarola et al Palm Beach Lakes Blvd West Palm Beach FL Jack Goldberger Esq jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss PA Australian Ave South Suite West Palm Beach FL Marc Nurik Esq East Broward Blvd Suite Fort Lauderdale FL Bradley Edwards Esq brad pathtojustice.com Farmer Jaffe Weissing Edwards Fistos Lehrman Andrews Avenue Suite Fort Lauderdale Florida Fred Haddad Esq Dee FredHaddadLaw.com Financial Plaza Suite Fort Lauderdale FL Tonja Haddad Coleman Esquire Tonja tonjahaddad.com efiling tonjahaddad.com Law Offices of Tonja Haddad P.A SE 7th Street Suite Fort Lauderdale FL Attorneys for Jeffrey Epstein
