EFTA01113966

IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT, 
INAND FOR PALM BEACH COUNTY, 
FLORIDA 
CASE NO.: 502009CA0408003OOOCMBAG 
JEFFREY EPSTEIN, 
Plaintiff/Counter-Defendant, 
JUDGE: 
DAVID CROW 
VS. 
SCOTT ROTHSTEIN, 
individually, BRADLEY J. 
EDWARDS, individually, 
Defendants/Counter-Plaintiff, 
EPSTEIN'S OBJECTIONS TO EDWARDS'S REVISED EXHIBIT LIST 
Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his 
undersigned counsel and pursuant to Paragraph D4 of this Court's Order Setting Jury 
Trial and Directing Pretrial and Mediation Procedures, hereby objects to the following of 
Defendant/Counter-Plaintiff Bradley Edwards's trial exhibits (numbered in order as they 
appeared in Edwards's Revised Exhibit List): 
I. 
All applicable criminal statutes 
4. 
Video of Jeffrey Epstein's home and route from victim to Epstein's home 
5. 
Order confirmation from Amazon.com for purchase of books "SM 101: 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" 
6. 
Non-Prosecution Agreement 
7. 
Jane Doe 102 Complaint 
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8. 
Messages taken from message pads found at Epstein's home 
9. 
Documents related to Jeffrey Epstein produced by Alfredo Rodriguez 
10. 
Jeffrey Epstein flight logs 
I I. 
Jeffrey Epstein phone records 
12. 
phone records 
13. 
Jail Visitation Logs 
14. 
Jeffrey Epstein's probation file 
15. 
All probable cause affidavits related to criminal investigation of Jeffrey Epstein 
16. 
All evidence, information and documents taken or possessed by FBI related to 
criminal investigation of Jeffrey Epstein 
17. 
Victims' statements to the FBI related to criminal investigation of Jeffrey Epstein 
18. 
Video of Search Warrant of Jeffrey Epstein's home being executed 
19. 
Application for Search Warrant of Jeffrey Epstein's home 
20. 
Complain
 v. Epstein and all subsequent Amended Complaints 
21. 
All records of homes, properties, bank accounts and any and all records related to 
Jeffrey Epstein's assets 
24. 
List of corporations owned by Jeffrey Epstein 
25. 
All documents evidencing relationship between Jeffrey Epstein and Jean Luc 
Brunel 
26. 
All documents evidencing relationship between Jeffrey Epstein and MC2 or any 
modeling agencies 
27. 
Yearbooks of Jane Doe 
28. 
2002 Royal Palm Beach High School Year Book 
29. 
2001 Royal Palm Beach High School Year Book 
30. 
2003 Palm Beach Gardens High School Year Book 
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31. 
Affidavit and Application for Search Warrant on Jeffrey Epstein's home 
32. 
Tape recording or transcript of recording of conversation between Jeffrey Epstein 
and George Rush 
33. 
Notepads found in Jeffrey Epstein's home and/or during trash pulls outside of his 
home during criminal investigation 
34. 
The Palm Beach State Attorney's Criminal file against Jeffrey Epstein 
35. 
All documents related to Jeffrey Epstein's 6/30/08 conviction 
36. 
Jeffrey Epstein's criminal plea colloquy 
37. 
Public records from the Department of Corrections related to Jeffrey Epstein 
38. 
Records from the Florida Department of Law Enforcement related to Jeffrey 
Epstein 
39. 
All statements made by Jeffrey Epstein 
40. 
List of properties and vehicles in Larry Visoski's name 
41. 
All of Jeffrey Epstein's Responses to Requests for Production, Requests for 
Admission, Answers to Intelmgatories in cases 08-80119, 08-80232, 08-80380, 08-
80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 
09-81092 
42. 
All discovery related responses of Jeffrey Epstein in cases 08-80119, 08-80232, 
08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 
09-80802, 09-81092 
43. 
Jeffrey Epstein's Answers and Affirmative Defenses in all civil cases against him 
44. 
All Complaints in which Jeffrey Epstein was a plaintiff or defendant 
45. 
Jeffrey Epstein's Deposition testimony and discovery responses in cases 08-
80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-
80591, 09-80656, 09-80802, 09-81092 
46. 
Jeffrey Epstein's Deposition testimony and discovery responses in State Court 
cases LM v. Jeffrey Epstein, Case No. 502008CA028051XXXXMB AB and E.W. v. 
Jeffrey Epstein, Case No. 502008CP003626XXXXMB 
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48. 
Any and all newspaper articles, online articles or publications related to Jeffrey 
Epstein 
49. 
Report and Analysis of Jeffrey Epstein's assets 
50. 
Video footage (DVD) of walk through site inspection of Jeffrey Epstein's home. 
51. 
Photos of all of Jeffrey Epstein's properties, cars, boats and planes 
52. 
Probable Cause Affidavits prepared against Jeffrey Epstein anc 
53. 
Audio tape of 
54. 
Photographs, videos and books taken in the search warrant of Jeffrey Epstein's 
home 
55. 
Documents related to or evidencing Jeffrey Epstein's donations to law 
enforcement 
56. 
Victim Notification Letter from US Attorney's Office to Victim 
57. 
Expert Dr. L. Dennison Reed's Report of Victim 
58. 
Palm Beach Police Department Incident Report dated 4/20/06 
59. 
All reports and documentation generated by Palm Beach Police Department 
related to Jeffrey Epstein 
60. 
All Witness Statements generated by Palm Beach Police Department relating to 
Jeffrey Epstein 
61. 
Passenger Manifests of Jeffrey Epstein's aircraft and private plane flight logs 
62. 
Passenger lists for flights taken by Jeffrey Epstein 
63. 
Letter from Jeffrey Epstein to Alberto Pinto regarding house island project 
64. 
Jeffrey Epstein's bank statements 
Jeffrey Epstein's tax returns (this item not numbered on Edwards's Trial Exhibit 
Listt) 
' 
• 
' 
• 
ein, Jeff Puller 
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66. 
DVD of plea and colloquy taken on 6-30-08 
67. 
Transcript of plea and colloquy taken on 6-30-08 
68. 
Massage Table 
69. 
Lotions taken from Jeffrey Epstein's home during search warrant 
70. 
Computers taken from Jeffrey Epstein's home during search warrant 
71. 
Vibrators, dildos and other sex toys taken from Jeffrey Epstein's home during 
search warrant 
72. 
No Contact Orders entered against Jeffrey Epstein 
73. 
Criminal Score Sheet regarding Jeffrey Epstein 
74. 
Documents evidencing Jeffrey Epstein's Community Control and Probation 
75. 
Jeffrey Epstein's Sex Offender Registration 
76. 
Jeffrey Epstein's Booking photograph 
77. 
CAD calls to 358 El Brillo Way, Palm Beach FL 33480 
78. 
List of Jeffrey Epstein's House contacts 
79. 
Documents related to Jeffrey Epstein's investments 
80. 
Letter from Chief Michael Reiter to Barry Krischler 
81. 
List of planes owned by Jeffrey Epstein 
82. 
Letter from Guy Fronstin to Assistant State Attorney dated 1-11-06 
83. 
Letter from Guy Fronstin to Assistant State Attorney dated 1-13-06 
84. 
Letter from Guy Fronstin to Assistant State Attorney dated 2-17-06 
85. 
Letter from Guy Fronstin to Assistant State Attorney dated 4-6-06 
86. 
Letter from Guy Fronstin to Assistant State Attorney dated 4-10-06 
87. 
Letter from Goldberger dated 6-22-06 
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88. 
All subpoenas issued to State Grand Jury 
89. 
Documents related to the rental of a vehicle fa 
90. 
Ted's Sheds Documents 
91. 
Documents related to property searches of Jeffrey Epstein's properties 
92. 
Arrest Warrant 
93. 
Police report regardin 
picking up money dated 11-28-04 
94. 
List of Trilateral Commission Members of 2003 
95. 
Alan Dershowitz Letter dated 4-19-06 and Statute 90.410 
96. 
Guy Fronstin letter dated 4-17-06 
97. 
Jeffrey Epstein Account Information 
98. 
Jeffrey Epstein Criminal Closeout Sheet-
99. 
Jeffrey Epstein Polygraph Test and Results 
100. 
Victim% GED testing information and results 
101. 
JEGE, Inc. Passenger Manifest 
102. 
Hyperion Air Passenger Manifest 
103. 
Flight information fa 
104. 
Passenger List Palm Beach flights 2005 
105. 
Jeffrey Epstein notepad notes 
106. 
Pleadings of _1 
and 2 v. US case 
107. 
Jeffrey Epstein 5th Amendment Speech 
108. 
Reiter letter to Krisher dated 5-1-06 
109. 
Jail receipts of Jeffrey Epstein 
110. 'olice 
Report dated 11-28-04 
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11. 
Compulsory Medial Examination of victim, CMA 
112. 
Victim's school records and transcripts 
113. 
Victim Notification letter dated 7-9-08 
114. 
Victim's employment records from IHOP 
115. 
Police report of Juan Alessi theft at Jeffrey Epstein's home 
116. 
Victim's Medical Records from Milton Girls Juvenile Facility 
117. 
Victim's Medical Records from Dr. Randee Speciale 
118. 
Victim's Medical Records from Wellington Regional Hospital 
119. 
Victim's Medical Records from St. Mary's Medical Center 
120. 
Victim's Medical Records from United Health 
121. 
All surveillance conducted by law enforcement on Jeffrey Epstein's home 
122. 
Emails received from Palm Beach Records related to Jeffrey Epstein 
123. 
All items listed on the Palm Beach Police Property Report Lists 
124. 
All items taken in the execution of the search warrant of Jeffrey Epstein's home: 
358 El Brillo Way, Palm Beach FL 33480 
125. 
All copies of convictions related to Jeffrey Epstein 
126. 
Jeffrey Epstein criminal records 
127. 
All documents produced by Palm Beach Police Department prior to the deposition 
of Detective Recarey 
128. 
Photographs of all persons listed on Victims' Witness Lists 
129. 
Statements, deposition transcripts, videotaped depositions and transcripts taken in 
connection with this and all related cases and exhibits thereto 
130. 
Any and all expert witness reports and/or records generated in preparation for this 
litigation by any party to this cause 
132. 
Curriculum vitae of Dr. Ryan Hall 
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133. 
Any articles or publications of Dr. Ryan Hall 
134. 
Any articles or publications of Dr. Richard Hall 
135. 
Any articles or publications of Dr. L. Dennison Reed 
136. 
All items and documentation review by Dr. L. Dennison Reed 
137. 
Transcript and video (DVD) of IME of Victims 
138. 
All exhibits to Dr. L. Demlison Reed's Deposition 
139. 
All exhibits to Dr. Richard Hall's Deposition 
140. 
All items and documents reviewed by Dr. Richard Hall 
141. 
All items and documents reviewed by Dr. Ryan Hall 
142. 
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.- need to see before we agree 
143. 
Any and all mortality tables 
149. 
All pleadings and attachments in the action under the Crime Victims Rights Act 
prosecuted by Bradley Edwards on behalf of victims of Epstein's criminal molestations. 
150. 
All attachments to Edwards's Motion for Summary Judgment. 
151. 
All time records and hourly billing documentation produced in discovery. 
152. 
All pleadings filed by Epstein in the Rothstein bankruptcy proceeding. 
153. 
All Settlement Agreements between Epstein and victims of his sexual 
molestations. 
Epstein objects to all of the afore-referenced Exhibits on several grounds, 
including, but not limited to: Relevance; Prejudice; Confusion; Misleading; Hearsay; 
Impermissible/Inadmissible Character Evidence; Impermissible/Inadmissible Evidence of 
other Crimes, Wrongs, or Acts; and the fact that most of the items on this list were not 
EFTA01113973

provided to Epstein through discovery or otherwise in this case, in direct violation of this 
Court's Order Setting Jury Trial and Directing Pretrial and Mediation Procedures, and 
Epstein's "Exhibit A" to Bradley J. Edwards's Deposition Duces Tecum. 
By listing these grounds for objection to the afore-listed Exhibits, Epstein is not 
waiving his right to assert additional objections, or objections to any non-listed Exhibits 
at trial. 
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 19, 2013. 
/s/ Tonja Haddad Coleman 
Tonja Haddad Coleman, Esq. 
Florida Bar No.: 176737 
Tonja Haddad, PA 
5315 SE 7th Street 
Suite 301 
Fort Lauderdale, Florida 33301 
954.467.1223 
954.337.3716 (facsimile) 
Attorneys for Epstein 
EFTA01113974

SERVICE LIST 
CASE NO. 502009CA040800XXXXMBAG 
Jack Scarola, Esq. 
[email protected]; [email protected] 
Searcy Denney Scarola et al. 
2139 Palm Beach Lakes Blvd. 
West Palm Beach, FL 33409 
Jack Goldberger, Esq. 
[email protected]; [email protected] 
Atterbury, Goldberger, & Weiss, PA 
250 Australian Ave. South 
Suite 1400 
West Palm Beach, FL 33401 
Marc Nurik, Esq. 
I East Broward Blvd. 
Suite 700 
Fort Lauderdale, FL 33301 
Bradley J. Edwards, Esq. 
[email protected] 
Fanner Jaffe Weissing Edwards Fistos Lehrman 
425 N Andrews Avenue 
Suite 2 
Fort Lauderdale, Florida 33301 
Fred Haddad, Esq. 
[email protected] 
1 Financial Plaza 
Suite 2612 
Fort Lauderdale, FL 33301 
Tonja Haddad Coleman, Esquire 
[email protected]; [email protected] 
Law Offices of Tonja Haddad, P.A. 
315 SE 7th Street, Suite 301 
Fort Lauderdale, FL 33301 
Attorneys for Jeffrey Epstein 
EFTA01113975