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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