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FBI VOL00009

EFTA01113986

9 sivua
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IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT, 
INAND FOR PALM BEACH COUNTY, 
FLORIDA 
CASE NO.: 502009CA040800XXXXMBAG 
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: 
All applicable criminal statutes 
All applicable Florida Statutes 
All applicable Rules of Evidence 
Video of Jeffrey Epstein's home and route from victim to Epstein's home- Irrelevant 
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" 
Non-Prosecution Agreement 
EFTA01113986
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102 Complaint 
Messages taken from message pads found at Epstein's home-
Documents related to Jeffrey Epstein produced by Alfredo Rodriguez 
Jeffrey Epstein flight logs 
Jeffrey Epstein phone records 
phone records 
Jail Visitation Logs 
Jeffrey Epstein's probation file 
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 Epstein's home being executed 
Application for Search Warrant of Jeffrey Epstein's home 
Complaint Jane Doe v. Epstein and all subsequent Amended Complaints 
All records of homes, properties, bank accounts and any and all records related to Jeffrey 
Epstein's assets- ok for punies only? 
Jeffrey Epstein's passport (or copy) 
Jeffrey Epstein's driver's license (or copy) 
List of corporations owned by Jeffrey Epstein ok for punies only? 
All documents evidencing relationship between Jeffrey Epstein and Jean Luc Brunel 
All documents evidencing relationship between Jeffrey Epstein and MC2 or any 
modeling agencies 
Yearbooks of Jane Doe 
EFTA01113987
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2002 Royal Palm Beach High School Year Book 
2001 Royal Palm Beach High School Year Book 
2003 Palm Beach Gardens High School Year Book 
Affidavit and Application for Search Warrant on Jeffrey Epstein's home 
Tape recording or transcript of recording of conversation between Jeffrey Epstein and 
George Rush 
Notepads found in Jeffrey Epstein's home and/or during trash pulls outside of his home 
during criminal investigation 
The Palm Beach State Attorney's Criminal file against Jeffrey Epstein 
All documents related to Jeffrey Epstein's 6/30/08 conviction 
Jeffrey Epstein's criminal plea colloquy 
Public records from the Department of Corrections related to Jeffrey Epstein 
Records from the Florida Department of Law Enforcement related to Jeffrey Epstein 
All statements made by Jeffrey Epstein 
List of properties and vehicles in Larry Visoski 's name 
All of Jeffrey Epstein's Responses to Requests for Production, Requests for Admission, 
Answers to Intel rngatories in this matter, and 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 
All discovery related responses of Jeffrey Epstein in this matter and 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 
Jeffrey Epstein's Answers and Affirmative Defenses in all civil cases against him 
All Complaints in which Jeffrey Epstein was a plaintiff or defendant 
Jeffrey Epstein's Deposition testimony and discovery responses in this case and 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 
EFTA01113988
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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. 502008CP003626)OOOCMB 
Jeffrey Epstein Deposition Testimony and discovery responses in State Court case Jeffrey 
Epstein v. Scott Rothstein, et al. Case No. 502009CA040800XXXXMBAG 
Any and all newspaper articles, online articles or publications related to Jeffrey Epstein 
Report and Analysis of Jeffrey Epstein's assets- punies trial only 
Video footage (DVD) of walk through site inspection of Jeffrey Epstein's home. 
Photos of all of Jeffrey Epstein's properties, cars, boats and planes punies trial only 
Probable Cause Affidavits prepared against Jeffrey Epstein and 
Audio tape o 
Photographs, videos and books taken in the search waimnt of Jeffrey Epstein's home 
Documents related to or evidencing Jeffrey Epstein's donations to law enforcement 
Victim Notification Letter from US Attorney's Office to Victim 
Expert Dr. L. Dennison Reed's Report of Victim 
Palm Beach Police Department Incident Report dated 4/20/06 
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 Epstein's aircraft and private plane flight logs 
Passenger lists for flights taken by Jeffrey Epstein 
Letter from Jeffrey Epstein to Alberto Pinto regarding house island project 
Jeffrey Epstein's bank statements-punies trial only 
Jeffrey Epstein's tax returns- punies trial only 
EFTA01113989
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MC2 emails involving communications of Jeffrey Epstein, Jeff Puller 
Pappas Suat, Jean Luc Brunel and Amanda Grant 
DVD of plea and colloquy taken on 6-30-08 
Transcript of plea and colloquy taken on 6-30-08 
Massage Table 
Lotions taken from Jeffrey Epstein's home during search warrant 
Computers taken from Jeffrey Epstein's home during search warrant 
Vibrators, dildos and other sex toys taken from Jeffrey Epstein's home during search 
warrant 
No Contact Orders entered against Jeffrey Epstein 
Criminal Score Sheet regarding Jeffrey Epstein 
Documents evidencing Jeffrey Epstein's Community Control and Probation 
Jeffrey Epstein's Sex Offender Registration 
Jeffrey Epstein's Booking photograph 
CAD calls to 358 EL BRILLO WAY, PALM BEACH FL 33480 
List of Jeffrey Epstein's House contacts 
Documents related to Jeffrey Epstein's investments- punies trial only 
Letter from Chief Michael Reiter to Barry Krischler 
List of planes owned by Jeffrey Epstein 
Letter from Guy Fronstin to Assistant State Attorney dated 1-11-06 
Letter from Guy Fronstin to Assistant State Attorney dated 1-13-06 
Letter from Guy Fronstin to Assistant State Attorney dated 2-17-06 
Letter from Guy Fronstin to Assistant State Attorney dated 4-6-06 
EFTA01113990
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Letter from Guy Fronstin to Assistant State Attorney dated 4-10-06 
Letter from Goldberger dated 6-22-06 
All subpoenas issued to State Grand Jury 
Documents related to the rental of a vehicle for' 
Ted's Sheds Documents 
Documents related to property searches of Jeffrey Epstein's properties- punies trial only 
Arrest Warrant o 
Police report regardin
picking up money dated 11-28-04 
List of Trilateral Commission Members of 2003 
Alan Dershowitz Letter dated 4-19-06 and Statute 90.410 
Guy Fronstin letter dated 4-17-06 
Jeffrey Epstein Account Information- punies trial only 
Jeffrey Epstein Criminal Closeout Sheet-
Jeffrey Epstein Polygraph Test and Results 
Victim's GED testing information and results 
JEGE, Inc. Passenger Manifest 
Hyperion Air Passenger Manifest 
Flight infonnation fo 
Passenger List Palm Beach flights 2005 
Jeffrey Epstein notepad notes 
Pleadings of 
1 and 2 v. US case 
Jeffrey Epstein 5th Amendment Speech 
Reiter letter to Krisher dated 5-1-06 
EFTA01113991
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Jail receipts of Jeffrey Epstein 
Police Report dated 11-28-04 
Compulsory Medial Examination of victim, CMA 
Victim's school records and transcripts 
Victim Notification letter dated 7-9-08 
Victim's employment records from IHOP 
Police report of Juan Alessi theft at Jeffrey Epstein's home 
Victim's Medical Records from Milton Girls Juvenile Facility 
Victim's Medical Records from Dr. Randee Speciale 
Victim's Medical Records from Wellington Regional Hospital 
Victim's Medical Records from St. Mary's Medical Center 
Victim's Medical Records from United Health 
All surveillance conducted by law enforcement on Jeffrey Epstein's 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 Epstein's home: 358 EL 
BRILLO WAY, PALM BEACH FL 33480 
All copies of convictions related to Jeffrey Epstein 
Jeffrey Epstein criminal records 
All documents produced by Palm Beach Police Department prior to the deposition of 
Detective Recarey 
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 
EFTA01113992
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Any and all expert witness reports and/or records generated in preparation for this 
litigation by any party to this cause 
Curriculum vitaes of any and all listed experts 
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. L. Dennison Reed 
All items and documentation review by Dr. L. Dennison Reed 
Transcript and video (DVD) of IME of Victims 
All exhibits to Dr. L. Demlison Reed's Deposition 
All exhibits to Dr. Richard Hall's Deposition 
All items and documents reviewed by Dr. Richard Hall 
All items and documents reviewed by Dr. Ryan Hall 
All exhibits listed on the Epstein's Exhibit List 
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 
Any and all mortality tables 
Edwards' reserves all objections to Epstein's Exhibits 
Edwards reserves the right to supplement and/or amend his Exhibit List 
By listing an Exhibit, Edwards is not waiving his right to object to same at trial and does 
not waive their right to amend same. 
All exhibits listed by Epstein subject to Edwards' objections. 
All pleadings and attachments in the action under the Crime Victims Rights Act 
prosecuted by Bradley Edwards on behalf of victims of Epstein's criminal molestations. 
EFTA01113993
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All attachments to Edwards' Motion for Summary Judgment. 
All time records and hourly billing documentation produced in discovery. 
All deposition testimony and discovery responses by Epstein submitted in this action. 
All pleadings filed by Epstein in the Rothstein bankruptcy proceeding. 
All submissions by Epstein in connection with the Rothstein deposition. 
All Settlement Agreements between Epstein and victims of his sexual molestations. 
EFTA01113994