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Filing# 71543277 E-Filed 05/02/2018 09:23:26 AM
JEFFREY EPSTEIN,
Plaintiff/Counter-Defendant,
V.
SCOTT ROTHSTEIN, individually, and
BRADLEY J. EDWARDS, individually,
Defendants/Counter-Plaintiff.
_________________
./
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY, FLORIDA
Case No. 50-2009CA040800:XXXXMBAG
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S
MOTION TO COMPEL COUNTER-PLAINTIFF
BRADLEY J. EDWARDS TO IDENTIFY HIS TRIAL WITNESSES
Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") moves to compel Counter-
Plaintiff Bradley J. Edwards ("Edwards") to identify the witnesses he actually intends to call at
trial and the subject matter of their testimony, and states:
INTRODUCTION
Edwards' operative Witness List identifies a total of 169 witnesses, which includes 165
individual witnesses and four general categories (No. 77, "Any additional individuals identified as
victims"; No. 151, Epstein's witnesses; No. 152, rebuttal witnesses; and No. 153, "All people on
Jeffrey Epstein's Inmate Visitor Log while he was in jail). Most of the listed witnesses have no
personal knowledge concerning Edwards' malicious prosecution claims against Epstein or
Epstein's probable cause for filing and continuing his proceeding against Edwards, making
speculation as to the specific subject matter of their permissible testimony impossible. Edwards
should be required to pare down this excessive number of witnesses for what should be less than
FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 05/02/2018 09:23:26 AM
NOT A CERTIFIED COPY a five-day malicious prosecution trial 1 and to identify the permissible subject matter about which the witnesses will testify. Without knowing which of the more than 169 witnesses will actually be called to testify at trial, who may be called from the general categories of witnesses who were not individually named, and what permissible testimony they will give, it is impossible for Epstein's counsel to properly prepare for the trial and Epstein will be substantially and unfairly prejudiced. Clearly, Edwards is attempting to try previously settled lawsuits involving his past three clients rather than the instant malicious prosecution cause of action. Edwards' intention to do so is plainly evidenced by the extensive grandstanding of his counsel, Jack Scarola, to the press in numerous attempts to taint the jury pool and prevent Epstein's right to a fair trial, spanning from 2013 to present: • "Trump is on a star-studded witness list for an upcoming trial in Palm Beach County Circuit Court that attorney Jack Scarola promises will be the first public airing of Epstein's lurid lifestyle." https://www.palmbeachpost.com/news/national-govt--politics/how-many-degrees- separation-between-trump-and-sex-off ender- epstein/WC 1 WNrtBC6uc9jCqk4COsL/ (March 12, 2017). • "A trial that promises to offer the first public airing of convicted sex offender Jeffrey Epstein's activities with teenage girls at his Palm Beach mansion is to be held in December .... " https :/ /www .palmbeachpost.com/news/ crime--law /trial- date-set-for-lawsuit-against-billionaire-sex-offender- epstein/VJbBnxT9PK 4AXk0mbLchBK/ (July 7, 2017). • Scarola agreed he would refrain from describing Epstein as "a billionaire pedophile" or "a convicted child molester." He said he does intend to call Virginia Roberts Giuffre to testify. In a civil lawsuit, she claimed Epstein turned her into a sex slave at age 15 when she was working at Mar-a-Lago in Palm Beach .... While Tr...
NOT A CERTIFIED COPY • Attorney Jack Scarola said it will be the first time the victims will have a chance to tell their stories. https://www.palmbeachdailynews.com/news/local/newest-lawsuit-against- epstein-expected-include-victim-testimony/CZ 14s0ESb0O4rib 7nj c 1 hL/ ( October 20, 2013). While this Court has stated that it will protect the judicial process and allow testimony "befitting of the known integrity of the history that has been pervasive in the 15th Judicial Circuit,"2 Edwards intends to create a very different environment at trial. Indeed, Edwards has listed every conceivable person who may have had some connection, however slight, to the criminal proceedings against Epstein or any civil proceedings against him, and even those who had no connection at all ( e.g., President Trump, former President Clinton, and David Copperfield, to name only a few). The exhaustive list of witnesses includes other tort claimants who Edwards never represented, the family members of tort claimants, counsel who represented other tort claimants, law enforcement, investigators, dignitaries, public officials, Epstein's associates, and celebrities with whom Epstein has socialized, and others with no connection at all to this malicious prosecution case. The vast majority of these witnesses have no place at the trial of this case. Their testimony would serve only to inflame or unfairly prejudice the jury and tum what should only be an orderly trial, focused on a few key issues pertaining to a single claim of malicious prosecution, into an unruly spectacle of multiple mini sex trials involving allegations of conduct from up to twenty years ago. Surely, if Edwards is allowed to present more than 169 witnesses, the potential for this trial to devolve into a circus extending well beyond any reasonable duration and resulting in a mistrial cannot be overstated. 2March 8, 2018, Afternoon Hearing Transcript 28:1-7. (Exhibit A.) 3
NOT A CERTIFIED COPY EDWARDS' WITNESS LISTS In the last eight years, Edwards has filed nine Witness Lists and four Rebuttal Witness Lists, each time increasing the number of witnesses, as follows: • June 30, 2010 - Witness List (D.E. 100)-7 witnesses: 1 individual and 6 general categories. • June 25, 2013 - Witness List (D.E. 638) - 14 witnesses: 7 individuals and 7 general categories. • August 19, 2013 - Rebuttal Witness List (D.E. 649) - 2 witnesses: 1 individual and 1 general category. • January 7, 2014 - Amended and Supplemental Witness List (D.E. 791) - 15 witnesses: 8 individuals and 7 general categories. • March 4, 2014- Rebuttal Witness List (D.E. 806) - 2 witnesses: 1 individual and 1 general category. • August 15, 2016 - Second Amended and Supplemental Witness List (D.E. 902) - 28 witnesses: 17 individuals and 11 general categories. • August 25, 2016 - Rebuttal Witness List (D.E. 905) - 3 witnesses: 2 individuals and 1 general category. • August 31, 2016 - Third Amended and Supplemental Witness List (D.E. 907)- 14 witnesses: 13 individuals and 1 general category (in addition to August 15, 2016, List; not replacing- bringing the total to 42 witnesses). • June 30, 2017 - Fourth Amended and Supplemental Witness List (D.E. 935) - 1 witness: 1 individual (in addition to August 15, 2016, and August 31, 2016 Lists; not replacing - bringing the total to 43 witnesses). • July 21, 2017 - Fifth Amended and Supplemental Witness List (D.E. 939) - 158 witnesses: 153 individuals and 5 general categories. • October 6, 2017 - Sixth Amended and Supplemental Witness List (D.E. 1010) - 159 witnesses: 154 individuals and 5 general categories. 4
NOT A CERTIFIED COPY • October 16, 2017 -Rebuttal Witness List (D.E. 1015) - 2 witnesses: 1 individual and 1 general category. • November 9, 2017 - Seventh Amended and Supplemental Witness List (D.E. 1042) - 169 witnesses: 165 individuals and 4 general categories (Operative List) (Exhibit B). In his July 12, 2017, Interrogatories to Edwards, Epstein attempted to discover the subject matter of each witness's testimony. For more than 120 of these witnesses, Edwards responded with an overly generalized and intentionally vague description: Each of the witnesses listed below as numbered 25-157 (with the exception of records custodians) has information pertaining to the malicious prosecution elements or absence of probable cause and malice. If called, each could provide information regarding the truth of the claims prosecuted by Edwards against Epstein, and the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages. (8/11/17 Answers to Interrogatories) (Exhibit C). This general description provides no meaningful information about the specific subject matter of each witness's testimony which should be provided at this stage. It is equivalent to Edwards stating nothing more than that the witnesses will be testifying as to the issues to be proven at trial. RULINGS OF THIS COURT While deciding the extent of Epstein's deposition testimony which would be allowed at trial, the Court recognized that the trial should proceed on a level playing field and that graphic type questions would not be allowed: I want to make sure that the record is clear, and that's this. I have an obligation, as both sides are well aware, to ensure that we are working on a level playing field to the extent that it is possible. I have the obligation, as Ms. Rockenbach points out, to be the gatekeeper ...
NOT A CERTIFIED COPY *** So to the extent that it would be needed to go in front of the jury, any questions that deal with the issue of Mr. Epstein's lawsuits brought by Mr. Edwards on behalf of the respective clients, would be germane. And any invocation ... would be germane and relevant and found to be admissible. That's the core ruling of the Court. Now, when it comes to issues of general graphic questioning, such as what has been exemplified by way of the counter-defendant's motion, those will not be permitted. (11/29/17 Tr. 70:18-71:6; 72:16-73:5).3 The Court further recognized that the trial was not to be used to test Epstein's criminal guilt but, rather, should focus on Edwards' malicious prosecution claim: I don't want this to tum into is a case testing whether or not Epstein was an alleged serial child molester. It would not, in my view, pass muster legally, and I don't want to try this case twice. I think that we should be extremely circumspect when it deals -- when we are dealing with global issues of molestation of graphic descriptions of any types of alleged molestation, except where we are dealing with claims that have been brought on behalf of those represented by Mr. Edwards. The risk of error, if we go beyond that intended limitation, is significant. And I want to make sure that we, again, are focused on the elements of the claim. And whether it be for compensatory damages associated with Mr. Edwards' claim or punitive damages associated with Mr. Edwards' claim, we are still dealing with a malicious prosecution claim, solely a malicious prosecution claim. And so to deviate from that direction would be precarious and concerning to the Court, in particular, because when we're dealing with issue of probable cause, we're focusing on -- as I've made clear - not only Mr. Epstein's stated intent, but I fully intend to allow circumstantial evidence, inclusive of the invocation of the Fifth Amendment relevant questions pertainin...
NOT A CERTIFIED COPY To allow this to intrude into allegations of serial molestation 1s dangerous and is concerning. (11/29/17 Tr. 98:3-99:20) (emphasis added). While the Court will allow Edwards to present evidence concerning his three clients' (E.W., L.M. and Jane Doe) claims and general evidence about the number of other claims and Edwards' role in litigating those matters, other evidence concerning claims of other tort claimants who were not represented by Edwards will not be allowed: SCAROLA: Your Honor suggested -- and I thought that I heard you correctly -- that evidence with regard to other claims actually filed against Epstein would be relevant and material. And clearly it is. THE COURT: I believe what I said was those cases filed by Mr. Edwards or any claims that were made against Epstein by a client represented by Mr. Edwards. (11/29/17 Tr. 96:6-14.) So again, my ruling on that is if there are questions that have to do with this issue, globally they will be allowed to be asked subject to further argument as it relates to the multiplicity of the numerous victims that we are dealing with here as alleged. (11/29/17 Tr. 118:22-119:3.) ... what may or may not be asked of Mr. Edwards and Mr. Epstein principally on these cases or these issues, the global order of the Court would be that those individual claims would not be subject to discussion as to the merits, as Mr. Scarola has stipulated. However, as it relates to both probable cause, i.e., motive and malice, the number of claims -- that is, speaking in terms of volume -- that Mr. Epstein was facing at the time that he brought the suit and continued the prosecution of that suit would be relevant. So that's the distinction being drawn by the Court, the detail, the merits, whatever may have been discovered as it relates to those cases would not be individually admissible in evidence, or any of those details from those cases. However, as I said, the sheer number of cases may be re...
NOT A CERTIFIED COPY (12/7/17 Tr. 5:1-23)4 (emphasis added). SCAROLA: Will we be permitted to discuss the fact that Mr. Edwards had taken a leadership role in coordinating the prosecution of all of those claims, that is, that it was a -- it was a unified effort on the part of multiple law firms that Mr. Edwards was playing a leadership role, which then led to a basis to focus upon Mr. Edwards because of that leadership role? THE COURT: If that's based on fact, then I believe it would be -- you would be able to introduce that, yes. (12/7/17 Tr. 6:3-14.) The Court memorialized these rulings in its January 16, 2018, Order. (Exhibit F.) ARGUMENT A. Edwards Must List his Actual Trial Witnesses, Not Grandstand for the Press Edwards' designation of more than 169 witnesses is unnecessary, excessive, abusive and deliberately misleading. Edwards' Witness List is intentionally broad and the subject of the witnesses' testimony so vague as to force Epstein to expend time and resources preparing for mini trials on a much broader scope than what this Court has already ruled it will allow. It reflects an abusive strategy seemingly calculated to attract media attention, to cause Epstein to needlessly incur substantial costs, and to cause his counsel to divert precious time and resources from trial preparation on the key witnesses and issues in this case. Furthermore, Edwards' identification of general categories of witnesses, such as "[ a ]ny additional individuals identified as victims" (No. 77) and "[a]ll people on Jeffrey Epstein's Inmate Visitor Log while he was in jail" (No. 153), rather than specific individual witnesses, forces Epstein into an impermissible trial by ambush, at least with respect to unnamed witnesses within these categories. It should not be allowed as Epstein is unable to make any preparations to address these witnesses' testimony and, where 4 Excerpts of the December 7, 2017, hearing transcript are attached as Exhibit E. 8
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necessary, to challenge their credibility.
This Court should order Edwards to identify the
individual witnesses he actually intends to call to testify at trial, whether live or by deposition. The
failure to do so would be highly prejudicial to Epstein and impede the efforts of Epstein's trial
team in preparing for the central and relevant issues of this case.
This is not Epstein's first time seeking this relief; however, the Court has yet to hear
argument or to rule on this issue. Edwards filed his first excessive Witness List in July 2017.
(D.E. 939.) In September 2017, Epstein filed his original Omnibus Motion in Limine which, in
part, addressed the excessive number of witnesses. (D.E. 984.) In addition, Epstein's November
7, 2017, Supplemental Motion to Compel sought to compel Edwards to disclose the specific
subject matter each witness was going to testify about. (D.E. 1039.) Finally, on February 16,
2018, Epstein moved for a case management conference asking the Court to determine, among
other things, which witnesses would be called live versus through deposition. (D.E. 1206.)
Although the trial was postponed in light of the appellate stay, the Court now should address the
abuses in Edwards' Witness List, as the parties prepare for trial on the new date to be set by this
Court. Specifically, Edwards should be required to (1) identify the specific witnesses he will call
for trial, including from the general categories, and (2) specify the subject matter of their testimony.
Such a ruling is well within the Court's discretion and an appropriate exercise of its
authority. "Without question, the trial court has discretion to limit the number of witnesses which
may be called by the parties[.]" Fogel v. Mirmelli, 413 So. 2d 1204, 1207 (Fla. 3d DCA 1982)
(citing Ritter v. Jimenez, 343 So. 2d 659, 662 (Fla. 3d DCA 1977) ("[P]laintiffs contend that the
trial court improperly limited them to four 'before and after witnesses.' The ...
NOT A CERTIFIED COPY been recognized as appropriate.")). Indeed, under the circumstances, it is critical to ensure a fair and orderly trial "befitting of the known integrity of the history that has been pervasive in the 15th Judicial Circuit." B. Edwards Should Not Be Allowed to Secure an Unfair Tactical Advantage by Gaming the System Now that it has been determined that it is only Edwards' sole cause of action for malicious prosecution that is to be tried, Edwards should not be allowed to play "blind man's bluff' in advance of the trial of his case. He has had ample time to prepare, and by this time he undoubtedly knows specifically how he intends to present his case. He should therefore be compelled to identify which of his more than 169 listed witnesses he actually intends to call at trial and specifically what they will testify about. Because of the excessive number of witnesses on Edwards' Witness List with no conceivable personal knowledge of the issues which this Court has ruled it will allow to be presented at trial (see below), Epstein is unsure as to which witnesses Edwards is likely to call or the substance of their testimony, and therefore, Epstein is severely prejudiced in his trial preparation. Misleadingly disclosing more than 169 witnesses, most of whom have no relevant testimony, is abusive and diverts precious time and resources from the preparation of trial of relevant witnesses, particularly where Edwards has failed to provide any meaningful disclosure regarding the specific testimony to be elicited from his parade of witnesses. Rather than preparing exclusively for the trial of the relevant issues of this case, Epstein will be forced to speculate about and then challenge the irrelevant but highly and unduly prejudicial testimony of witnesses who may not even be called at trial. Epstein is also forced to prepare for "unknown" witnesses who fall within the general categories. Edwards should not be allowed to secure a tactica...
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Edwards' designation of more than 169 witnesses and prov1s10n of overly vague
descriptions of their potential trial testimony, if they testify at all, is the equivalent of non-
disclosure leading to an impermissible trial by ambush. See Dep 't of Health & Rehab. Servs. v.
J.B. By & Through Spivak, 675 So. 2d 241, 243 (Fla. 4th DCA 1996) (citations omitted)
("[L]itigation should no[t] proceed as a game of blind man's bluff. Civil trials are not to be
ambushes for one side or the other."). See also Binger v. King Pest Control, 401 So. 2d 1310,
1314 (Fla. 1981) (holding that compliance with pre-trial orders and directing proper disclosure of
witnesses eliminates surprise and prevents trial by ambush).
The Court has clearly insisted on a level playing field and that this trial will not be used as
a vehicle to try Epstein for his criminal charges or the tort claimants' claims. Rather, Edwards is
limited to presenting evidence about his malicious prosecution action, his allegations that there
was an absence of probable cause for Epstein to file suit and Edwards' three clients' claims as they
relate to those allegations in this case. While this Court has ruled that Edwards may speak only
generally about the claims of other plaintiffs he did not represent, as to the number of claims and
his role in those matters, Edwards is not permitted to go into detail about the merits of those claims.
Many of the witnesses identified on Edwards' Witness List, however, can offer no testimony on
these limited issues, or their testimony would be cumulative, unduly prejudicial and present a
significant risk of exceeding the limited scope of inquiry allowed by this Court. Consequently,
they should not be allowed to testify at the trial.
The ultimate control over ambiguous and misleading witness disclosures is within the
broad discretion of the trial judge which "focuses on prejudice in the preparation and trial of a
lawsuit." Binger v. King Pest Contr...
NOT A CERTIFIED COPY 90.612, Florida Statutes controls the "mode and order of interrogation and presentation" of witnesses and evidence and provides: ( 1) The judge shall exercise reasonable control over the mode and order of the interrogation of witnesses and the presentation of evidence, so as to: (Emphasis added.) (a) Facilitate, through effective interrogation and presentation, the discovery of the truth. (b) A void needless consumption of time. ( c) Protect witnesses from harassment or undue embarrassment. This Court, therefore, has the power and, indeed, the duty to facilitate the orderly conduct of the trial of this case. In accordance with that power and duty, this Court should order Edwards to specifically identify each witness he will actually call as a witness at trial, whether live or by deposition, and to identify the subject matter of their testimony. This will both facilitate discovery of the truth, avoid needless waste of judicial resources and avoid undue prejudice to Epstein. C. Many of the Witnesses on Edwards' Current Witness List Do Not Have Personal Knowledge About the Malicious Prosecution Claim to be Tried and Any Testimony They Could Provide Would Be Prejudicial Only those witnesses Edwards identified who have personal knowledge of the relevant issues in this case should be allowed to testify. Section 90.604, Florida Statutes provides: Except as otherwise provided ins. 90.702 [experts], a witness may not testify to a matter unless evidence is introduced which is sufficient to support a finding that the witness has personal knowledge of the matter. Evidence to prove personal knowledge may be given by the witness's own testimony. § 90.604, Fla. Stat. ( emphasis added). 12
NOT A CERTIFIED COPY "Relevant evidence" is defined as evidence tending to prove or disprove a material fact. § 90.401, Fla. Stat. As stated above, this Court has already determined the trial of this matter will be focused on the elements of the claim: The risk of error, if we go beyond that intended limitation, is significant. And I want to make sure that we, again, are focused on the elements of the claim. And whether it be for compensatory damages associated with Mr. Edwards' claim or punitive damages associated with Mr. Edwards' claim, we are still dealing with a malicious prosecution claim, solely a malicious prosecution claim. (11/29/17 Tr. 98:17-99:1) (emphasis added). Thus, to be relevant to the issues tried in this case, the testimony must focus on the elements of Edwards' malicious prosecution claim. In answers to Interrogatories, Edwards claimed that almost every single listed witness has knowledge pertaining to the malicious prosecution elements or absence of probable cause and malice. Edwards knows that this is simply untrue. For instance, Edwards has listed at least 26 other tort claimants whom Edwards did not represent and their counsel, Landon Thomas a New York Times reporter (No. 29), Prince Andrew (No. 48), Leslie W exner (No. 78), President Donald Trump (No. 79), David Copperfield (No. 86), former President William J. Clinton (No. 116), Mark Epstein (No. 154), law enforcement (i.e., Nos. 11, 12, 63, 69, 90, 102, 103, 104, 119, 120, 132), and many others. In fact, most of the 169 witnesses identified by Edwards do not have personal knowledge nor can they present relevant evidence. Moreover, under section 90.403, Florida Statutes, even "relevant evidence is inadmissible if its probative value is substantially outweighed by the danger of unfair prejudice, confusion of issues, misleading the jury, or needless presentations of cumulative evidence." Any limited probative value that Edwards might argue his witnesses can provide is ...
NOT A CERTIFIED COPY In addition, litigation of purely collateral matters for the sole purpose of impeaching a party or witness is improper. Dempsey v. Shell Oil Co., 589 So. 2d 373, 377 (Fla. 4th DCA 1991). A matter is considered collateral if it is not material and would not be admitted or any purpose other than the contradiction. Id. Thus, unless Edwards' listed witnesses have personal knowledge of the matter at issue and can speak to what Epstein believed when he filed suit against Edwards, the witnesses' testimony would be irrelevant and collateral, and thus, inadmissible, even for purposes of impeachment. Testimony of other tort claimants who Edwards never represented, the family members of tort claimants, counsel who represented other tort claimants, records custodians of schools Edwards' three clients attended, records custodians of medical practices Edwards' three clients received medical treatment, law enforcement, investigators, reporters, dignitaries, public officials, Epstein's associates and celebrities with whom Epstein has socialized can have no personal knowledge of facts relevant to the elements of Edwards' malicious prosecution claim. Their testimony would only serve to further unfairly prejudice Epstein and confuse the issues relevant to the elements of Edwards' claim, or would be cumulative, and outside the scope of what this Court said it would allow in order to maintain the level playing field and avoid reversible error of inquiry into matters well beyond this malicious prosecution action. Thus, none of the testimony of any of these witnesses should be allowed. In any event, Edwards should be compelled to designate each witness he actually intends to put on the stand and identify with specificity the subject matter which Edwards intends to elicit from each such designated witness, so that, before the witness is put on this stand, Epstein has an opportunity to challenge and this Court may determine whether the testimony wil...
NOT A CERTIFIED COPY D. Edwards Should Not be Allowed to Try Other Cases at the Trial of This Matter The Court has already found that the trial of this action will not be used to try any criminal case against Epstein or any of the prior civil actions against Epstein. Allegations in such other lawsuits against a defendant are not relevant and are highly prejudicial under section 90.403, Florida Statutes. See Long Term Care Found., Inc. v. Martin, 778 So. 2d 1100, 1102-03 (Fla. 5th DCA 2001). Likewise, "[i]t is inconsistent with the notions of fair trial for the state to force a defendant to resurrect a prior defense against a crime for which the defendant is not on trial." Jacobs v. Atl. Coast Ref, Inc., 165 So. 3d 714, 717 (Fla. 4th DCA 2015) (citation omitted) (finding that "because the prior case was settled, none of the allegations therein were proven"). Accordingly, witnesses who lack knowledge of facts or information germane to the specific issues in this litigation should be precluded from testifying at trial. CONCLUSION Edwards should not be allowed to make a circus out of this malicious prosecution trial and taint the jury with the spectacle of unduly prejudicial testimony. However, the excessively large number and wide array of individuals designated on his Witness List who have no connection to the relevant issues in this case clearly demonstrate his intention to do just that. By designating more than 169 potential witnesses without identifying which of them will actually testify at trial and specifically what they will testify about, Edwards is forcing Epstein into a game of blind man's bluff, effectively conducting an impermissible trial by ambush. The Court should not allow Edwards to employ these abusive tactics. It is highly prejudicial, if not nearly impossible, and a monumental waste of time and resources, to require Epstein to speculate blindly as to the testimony that might be given by all 169 witnesses, most of whom can have...
NOT A CERTIFIED COPY preparation required to effectively cross examine each of them regarding such testimony. Edwards should be ordered to identify specifically each witness whom he actually intends to call at the trial of this matter, whether the testimony will be live or by deposition testimony and the subject matter of the testimony, so as to ensure Edwards will not exceed the permissible scope of trial established by this Court. Moreover, Edwards should be prohibited from introducing any witness or any testimony outside of that scope. In addition, once Edwards properly identifies his witnesses and the specific subject matter of their intended testimony, Epstein requests the right to make further challenges, as appropriate. CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on May 2, 2018, through the Court's e-filing portal pursuant to Florida Rule of Judicial Administration 2.516(b )(1 ). LINK & ROCKENBACH, PA 1555 Palm Beach Lakes Boulevard, Suite 301 West Palm Beach, Florida 33401 (561) 727-3600; (561) 727-3601 [fax] By: Isl Scott J. Link Scott J. Link (FBN 602991) Kara Berard Rockenbach (FBN 44903) Rachel J. Glasser (FBN 577251) 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 16
NOT A CERTIFIED COPY SERVICE LIST Jack Scarola Karen E. Terry David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 mep@searcylaw.com jsx@searcylaw.com dvitale@searcylaw.com scarolateam@searcylaw.com terryteam@searcylaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards Bradley J. Edwards Edwards Pottinger LLC 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 brad@epllc.com Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards Jack A. Goldberger Atterbury, Goldberger & Weiss, P.A. 250 Australian A venue S., Suite 1400 West Palm Beach, FL 33401 j goldberger@agwpa.com smahoney@agwpa.com Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein 17 Philip M. Burlington Nichole J. Segal Burlington & Rockenbach, P.A. Courthouse Commons, Suite 350 444 West Railroad A venue West Palm Beach, FL 33401 pmb@FLAppellateLaw.com njs@FLAppellateLaw.com kbt@FLAppellateLaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards Marc S. Nurik Law Offices of Marc S. Nurik One E. Broward Boulevard, Suite 700 Ft. Lauderdale, FL 33301 marc@nuriklaw.com Counsel for Defendant Scott Rothstein Paul Cassell 383 S. University Salt Lake City, UT 84112-0730 cassellp@law. utah. edu Limited Intervenor Co-Counsel for L.M, E.W. and Jane Doe Jay Howell Jay Howell & Associates 644 Cesery Blvd., Suite 250 Jacksonville, FL 32211 jayhowell.com Limited Intervenor Co-Counsel for L.M, E.W. and Jane Doe
NOT A CERTIFIED COPY EXHIBIT A
NOT A CERTIFIED COPY IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, vs. SCOTT ROTHSTEIN, individually; BRADLEY EDWARDS, individually, Defendants/Counter-Plaintiffs. I ------------------ TRANSCRIPT OF PROCEEDINGS DATE TAKEN: TIME: PLACE BEFORE: Thursday, March 8th, 2018 1:30 p.m. - 4:50 p.m. 205 N. Dixie Highway, Room l0D West Palm Beach, Florida Donald Hafele, Presiding Judge This cause came on to be heard at the time and place aforesaid, when and where the following proceedings were reported by: Elaine V. Williams Palm Beach Reporting Service, Inc. 1665 Palm Beach Lakes Boulevard, Suite 1001 West Palm Beach, FL 33401 (561) 471-2995 Palm Beach Reporting Service, Inc. 561-471-2995 1
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THE COURT:
(WeTl::;) (:(Q§) (6157 ection) (i:S, (sustained)
(ill (QI§) {sense)~ GD (rgaTly) @o) {want)~ (as) GD
(lna.icated) (earlier;) (continue)(:@ (as)~ (as) Cw:e) (can)
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(Known) (integrity) (61) ~~(QI§) (attorneys) (here)
(15e:for:e} (_@) QNI) (also) (QI§) (history)~(!@]) (been)
(pervasive) (in) ©I§) (T5Efi) CJ:ITcl_icial) (Circuit).
So I don't
want this to dissolve into an ethical discussion as
to whether or not someone committed some type of
ethical violation.
That's really not my focus
today.
And that focus is better suited for others
perhaps at a different time and even perhaps in a
different forum.
Really what has to be attempted to be divined
today is some type of representation by counsel for
Mr. Epstein as to what the source of these
documents were.
MS. ROCKENBACH:
Yes, your Honor.
THE COURT:
Why were they preserved, how were
they preserved, for what reason were they
preserved, did that preservation violate or come
close to violating an order of the bankruptcy
court, has the privilege been waived?
And then we
get back again to the Binger analysis.
I did a quick word search, and the Fifth
Palm Beach Reporting Service, Inc.
561-471-2995
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NOT A CERTIFIED COPY EXHIBIT B
NOT A CERTIFIED COPY Filing# 64026530 E-Filed 11/09/2017 05:20:40 PM JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG SEVENTH AMENDED AND SUPPLEMENTAL WITNESS LIST OF COUNTER-PLAINTIFF BRADLEY J. EDWARDS Counter-Plaintiff, BRADLEY J. EDWARDS, by and through his undersigned attorneys, hereby supplements his list of witnesses for trial as follows: WITNESSES EXPECTED TO BE PRESENTED 1. Bradley J. Edwards 2.. Jeffrey Epstein 3. Sarah Vickers (formerly Kellen) c/o John Stephenson 1201 W. Peachtree Street Atlanta, Georgia 30339 4. Nadia Marcinkova c/o Erica Dubno 767 Third A venue, Suite 3600 New York, New York 10017 5. Virginia Roberts Guiffre c/o Stan Pottinger 49 Twin Lakes Road, Suite 100 South Salem NY 10590
NOT A CERTIFIED COPY EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley J. Edwards Page 2 of22 6. Maria Farmer c/o Peter Guirguis, Esq. Mintz & Gold LLP 600 Third A venue, 25th Floor, New York 10016 7. Annie Farmer c/o Peter Guirguis, Esq. Mintz & Gold LLP 600 Third Avenue, 25th Floor, New York, 10016 8. Nadia Bjorlin 13701 Riverside Drive, Suite 800 Sherman Oaks, CA 91423-2449 9. Alexandra Hall c/o Robert C. Josefsberg, Esq. Podhurst Orseck, PA One S.E. 3rd Avenue, Suite 2700 Miami, FL 33131 10. Robert C. Josefsberg, Esquire Podhurst Orseck, PA One S.E. 3rd Avenue, Suite 2700 Miami, FL 33131 11. Detective Joseph Recarey Palm Beach Police Depaiiment 345 South County Road Palm Beach, FL 33480 12. Chief Michael Reiter Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 13. John Connolly c/o Simon & Schuster 1230 6th A venue New York, New York 10020
NOT A CERTIFIED COPY EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley J. Edwards Page 3 of22 14. Charles Lichtman, Esquire Berger Singerman 300 East Las Olas Boulevard, Suite 1000 F01i Lauderdale, FL 33301 15. Courtney Wild c/o Adam Horowitz. Horowitz Law 425 North Andrews A venue, Suite 2 Fort Lauderdale FL 33301 16. Antonio Figueroa (Tony) Palm Coast, Florida 17. Records Custodian of Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 18. Records Custodian of United States Attorney's Office for the Southern District of Florida 19. Records Custodian of the Federal Bureau of Investigations 20. Spencer Kuvin, Esquire 1800 S. Australian Avenue, #400 West Palm Beach, Florida 33409 21. Theodore Leopold, Esquire Cohen Milstein 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, Florida 33410 22. Rinaldo Rizzo c/o Robe1i Lewis 228 East 45th Street I 17th Floor New York, NY 10017 23. Adam Horowitz, Esquire 425 N. Andrews Ave., Suite 2 Ft. Lauderdale, FL 33301
NOT A CERTIFIED COPY EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley J. Edwards Page 4 of22 24. Isidro M. Garcia, Esquire Garcia Law Firm, P.A. 224 Datum Street, Suite 900 West Palm Beach, FL, 33401 25. Earleen Cote, Esquire Kubicki Draper One East Broward Boulevard, Suite 1600 Fort Lauderdale, FL 33301 26. Bernard J. Jansen, Ph.D. c/o Jack Scarola Searcy Denney Scarola Barnhart & Shipley 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 27. William Berger, Esquire Weiss, Handler, Cornwell, P.A. 2255 Glades Road, Suite 218A Boca Raton, FL 33431 WITNESSES WHICH MAY BE CALLED IF THE NEED ARISES 28. Adriana Mucinska 1040 South Shore Drive Miami Beach, FL 33141 29. Landon Thomas c/o New York Times 620 Eighth A venue New York, NY 10018 30. Oren Kramer c/o Boston Provident, L.P. 717 5th Avenue #12A New York, NY 10022 31. Lawrence La Vecchio United States Attorney's Office, Southern District of Florida Broward Financial Center Fo1i Lauderdale, Florida
NOT A CERTIFIED COPY EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley J. Edwards Page 5 of22 32. Amanda Laszlo c/o Adam Horowitz. Horowitz Law 425 North Andrews A venue, Suite 2 Fort Lauderdale FL 33301 33. Evgenia Ignatieva 1650 Broadway, #910 New York, NY 10019 34. Anouska DeGeorgiou 536 N. Edinburgh Avenue, Los Angeles, CA 90048 35. Angelique Garcia c/o Adam Horowitz. Horowitz Law 425 North Andrews Avenue, Suite 2 Fort Lauderdale FL 33301 36. Carolyn Andriamo c/o Jack Scarola Searcy Denney Scarola Barnhart & Shipley 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 3 7. Ashley Davis c/o Robert C. Josefsberg, Esq. Podhurst Orseck, PA One S.E. 3rd A venue, Suite 2700 Mian1i, FL 33131 38. Brandy Brenson c/o Spencer Kuvin 1800 South Australian Ave #400 West Palm Beach, Florida, 33409 39. Molly Smythe c/o Robert C. Josefsberg, Esq. Podhurst Orseck, PA One S.E. 3rd Avenue, Suite 2700 Miami, FL 33131
NOT A CERTIFIED COPY EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley J. Edwards Page 6 of22 40. Com1ney Langley c/o Spencer Kuvin 1800 South Australian Ave #400 West Palm Beach, Florida, 3 3409 41. William Scherer, Esquire 633 S Federal Hwy #800 Fort Lauderdale, FL 33301 42. Paul Cassell, Esq. 383 S. University Street Salt Lake City Utah, UT 84112 43. Faith Pentek c/o Adam Horowitz. Horowitz Law 425 North Andrews Avenue, Suite 2 Fort Lauderdale FL 33301 44. Teala Davies 1212 N. Clark Street West Hollywood, CA 90069 45. Felicia Esposito Cartwright c/o Robert C. Josefsberg, Esq. Podhurst Orseck, PA One S.E. 3rd Avenue, Suite 2700 Miami, FL 33131 46. Jennifer Amenold c/o Robert C. Josefsberg, Esq. Podhurst Orseck, PA One S.E. 3rd A venue, Suite 2700 Miami, FL 33131 47. Jennifer Pitts Catino c/o Robert C. Josefsberg, Esq. Podhurst Orseck, PA One S.E. 3rd A venue, Suite 2700 Miami, FL 33131
NOT A CERTIFIED COPY EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley J. Edwards Page 7 of22 48. Prince Andrew Albert Christian Edwards Duke of York, Buckingham Palace Road London SWlA lAA 49. Frederic Fekkai Address Currently Unknown 50. Kara Henderson c/o Robert C. Josefsberg, Esq. Podhurst Orseck, PA One S.E. 3rd A venue, Suite 2700 Miami, FL 33131 51. Lesley Groff c/o Mike Miller 1114 A venue of the Americas New York, NY 10036 52. Dave Rogers c/o Bruce Reinhart 505 S. Flagler Drive, Ste 300 West Palm Beach, FL 33401 53. Lauren Murphy c/o Adam Horowitz. Horowitz Law 425 North Andrews A venue, Suite 2 Fort Lauderdale FL 33301 54. Leigh Skye Patrick c/o Robert C. Josefsberg, Esq. Podhurst Orseck, PA One S.E. 3rd A venue, Suite 2700 Miami, FL 33131 55. Meagan Dorshel c/o Robert C. Josefsberg, Esq. Podhurst Orseck, PA One S.E. 3rd Avenue, Suite 2700 Miami, FL 33131
NOT A CERTIFIED COPY EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley J. Edwards Page 8 of22 56. Michelle Licata c/o Adam Horowitz. Horowitz Law 425 N01ih Andrews A venue, Suite 2 F01i Lauderdale FL 33301 57. Molly Smythe c/o Robe1i C. Josefsberg, Esq. Podhurst Orseck, PA One S.E. 3rd Avenue, Suite 2700 Miami, FL 33131 58. Tod Meister 101 Seminole A venue Palm Beach, FL 38480 59. Rhiannon Schwegel c/o Robert C. Josefsberg, Esq. Podhurst Orseck, PA One S.E. 3rd Avenue, Suite 2700 Miami, FL 33131 60. Sabrina Ewart c/o Robert C. Josefsberg, Esq. Podhurst Orseck, PA One S.E. 3rd A venue, Suite 2700 Miami, FL 33131 61. Saige Gonzales c/o Spencer Kuvin 1800 South Australian Ave #400 West Palm Beach, Florida, 33409 62. Johanna Sjoberg c/o Marshall Dore Louis 40 NW third Street, Suite 200 Miami, FL 33128 63. Jason Richards Federal Bureau of Investigation 16320 NW 2nd AVE., Miami, FL 33169
NOT A CERTIFIED COPY EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley J. Edwards Page 9 of22 64. Shawna Rivera c/o Bradley Edwards, Esq. Edwards Pottinger LLC 425 North Andrews Avenue, Suite 2 Fort Lauderdale FL 33301 65. Tatum Miller c/o Bradley Edwards, Esq. Edwards Pottinger LLC 425 North Andrews Avenue, Suite 2 Fort Lauderdale FL 33301 66. Vanessa Zalis c/o Adam Horowitz. Horowitz Law 425 North Andrews Avenue, Suite 2 Fort Lauderdale FL 33301 67. Virginia Alvarez c/o Adam Horowitz. Horowitz Law 425 North Andrews A venue, Suite 2 Fort Lauderdale FL 33301 68. Yolanda Lopez c/o Adam Horowitz. Horowitz Law 425 North Andrews A venue, Suite 2 Fort Lauderdale FL 33301 69. Nezbitt Kurkendall Federal Bureau of Investigation 16320 NW 2nd Ave. Miami, FL 3 3169 70. Daynia Nida c/o Isidro M. Garcia Garcia Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL, 33401
NOT A CERTIFIED COPY EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley J. Edwards Page 10 of22 71. Igor Zinoview Address Currently Unknown 72. Pralaya Cuomo Address CmTently Unknown 73. Svetlana Pozhidaeva 9 East 71 Street New York, NY 10021 74. Seth Lehrman 425 North Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 7 5. Matt W eissing 425 North Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 76. Maria Villafana 500 S. Australian Avenue, #400 West Palm Beach, FL 33401 77. Any additional individuals identified as victims by the United States Attorney's Office and whose identities were conveyed to Jeffrey Epstein as part of a list supplied as it related to the NP A. 78. Leslie Wexner Three Limited Parkway Columbus, Ohio 43206 79. President Donald J. Trnmp cl o Alan Garten, Esq. 725 Fifth A venue New York, NY 10022 80. LaiTy Visoski 1131 Pine Point Road Riviera Beach, FL 33401 81. Maritza Vasquez 1293 SW 2l51 Terrace Miami, FL 33145
NOT A CERTIFIED COPY EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley J. Edwards Page 11 of22 82. Maximilia Cordero c/o William Unroch, Esquire 140 West End, Apt. 30-BW New York, NY 10023 83. Brittany Beale c/o Spencer Kuvin 1800 S. Australian Avenue, #400 West Palm Beach, Florida 33409 84. Melissa Eaton 2915 Share Rd. 111 Tallahassee, FL 31312 85. Danielle Hendrick Dicenso c/o Robert C. Josefsberg, Esq. Podhurst Orseck, PA One S.E. 3rd A venue, Suite 2700 Miami, FL 33131 86. David Copperfield (David Seth Kokin) 11675 Glowing Sunset Lane Las Vegas, NV 89135 87. Haley Robson 12247 72ND CTN West Palm Beach, FL 33412 88. Michael Fisten Weston, FL 89. Russell Adler Delray Beach, FL 90. Marie Alessi 6791 Fairway Lakes Dr. Boynton Beach, FL 33472 91. Janusz Banasiak 358 El Brillo Way Palm Beach, FL, 33480
NOT A CERTIFIED COPY EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley J. Edwards Page 12 of22 92. Beata Banasiak 358 El Brillo Way Palm Beach, FL, 33480 93. Juan Alessi 6791 Fairway Lakes Dr. Boynton Beach, FL 33472 94. Michael Friedman 53320 A venida Madero La Quinta, CA 92253 95. Jeny Goldsmith 13285 Silver Fox Lane West Palm Beach, FL 33418-7942 96. Rosalie Freedman 53320 Avenida Madero La Quinta, CA 92253 97. V aldson Cotrin Address Currently Unknown 98. Dana Burns 301 East 66TH Street, Apt. 1 lP New York, NY 10065 99. Cecelia Stein Unknown, South Africa 100. Glenn Dubin 1040 5th Ave. Unit 15A New York, NY 10028-0137 101. Abigail Wexner Three Limited Parkway Columbus, Ohio 43206 102. Officer Munyan Palm Beach Police Department 345 South County Road
NOT A CERTIFIED COPY EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley J. Edwards Page 13 of22 Palm Beach, FL 33480 103. Officer Minot Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 104. Sgt. Sorge Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 105. Christina V enero Address CmTently Unknown 106. Joseph Pagnano 1217 S Flagler Drive, Suite 301 West Palm Beach, FL 33401 107. Stephan Kosslyn 28 Garfield Street Cambridge, MA 02138-1802 108. Cecile Dejongh 23 8 Estate Mafolie St. Thomas VI 00802 109. Tommy Mottola 302 Caribbean Road Palm Beach, FL 33480-3012 110. Mike Sanka 449 S Beverly Drive, Suite 101 Beverly Hills, CA 90212 111. Cecilia Steen SI A Witness # 108 112. William "Bill" Riley 5645 Coral Ridge Drive# 391 Coral Springs, FL 33076
NOT A CERTIFIED COPY EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley J. Edwards Page 14 of22 113. Howard Rubenstein 1345 A venue of the Americas New York, NY 10105 114. Robe1i Meister 101 Seminole Ave. Palm Beach, FL 33480 115. Todd Meister 101 Seminole Ave Palm Beach, FL 33480 116. President William J. Clinton 117. William Hammond 2965 Fontana Place Royal Palm Beach, FL 118. Robert Roxburgh 5600 North Flagler Dr, #250 West Palm Beach, Florida 119. Michele Pagan Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 120. Michele Dawson Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 121. Amy F01iimer 12309 North Old Country Road Wellington, FL 33414 122. Anna Skidan 545 East 5th Street, Apt. 6E New York, NY 10009
NOT A CERTIFIED COPY EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley J. Edwards Page 15 of22 123. Christina Venero 971 NW Fresco Way, Apt. 208 Jensen Beach, FL 34957 124. Dara Gehringer (Dara Preece) 3139 Kingston Court, West Palm Beach, Florida 125. Juliana Barbosa 9 Pinta Road Miami, FL 33133-2607 126. Latasha Lowe 127. 128. 129. 130. 131. 132. c/o Adam Horowitz. Horowitz Law 425 North Andrews Avenue, Suite 2 Fmi Lauderdale FL 33301 Melissa Hanes 115 Sunshine Blvd West Palm Beach, Florida Zack Bryan 1150 Larch Way Wellington, Florida Zinta Braukis 925 W Avenue 37 Los Angeles, CA 90065-3241 Larry Morrison 11148 Cobblefield Dr.. Wellington, FL 33449 Story Cowles 801 S Olive Ave., Unit 201S West Palm Beach, FL 33401 Michael Dawson Palm Beach Police Department 345 South County Road Palm Beach, FL 33480
NOT A CERTIFIED COPY EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley J. Edwards Page 16 of22 133. Salaam Kahlid Monroe 119 Menores Ave., Apt. 3 Coral Gables, FL 33134 134. Jelitza Negrette 503 Chandlers Warf Portland, ME 04101 135. Sergia Cordero 825 Brickell Bay Drive, # 1141 Miami, FL 33131 136. Cassandra Rivera 5011 El Claro Circle West Palm Beach, FL 33415 137. Randee Speciale Palm Beach Victim Services 205 North Dixie Highway, #5.1100 West Palm Beach, FL 33401 138. Nicole Hesse Address Cunently Unknown 139. Steven Hoffenberg Address Currently Unknown 140. Michael Stroll Address CmTently Unknown 141. Douglas Shoettle 243 Riverside, Dr. New York, NY 10025 142. Ghislaine Maxwell Address Cunently Unknown 143. Amazon Records Custodian 144. Yellow Cab Records Custodian
NOT A CERTIFIED COPY EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley J. Edwards Page 17 of22 145. Citrix Systems, Inc. Records Custodian 146. Federal Bureau oflnvestigation Records Custodian 147. Milton Girls Juvenile Facility Records Custodian 5770 East Milton Road Milton, FL 148. School District of Palm Beach County Records Custodian 3344 Forest Hill Blvd., Suite C-124 West Palm Beach, FL 33406 149. St. Mary's Medical Center Records Custodian 901 45th Street West Palm Beach, FL 33401 150. Wellington Reginal Hospital Records Custodian 10104 Forrest Hill Blvd. Wellington, FL 33414 151. All witnesses that Defendants have listed on their Witness List not objected to by Plaintiff 152. All rebuttal witnesses. 153. All People on Jeffrey Epstein's Inmate Visitor Log while he was in jail. WITNESS TESTIMONY EXPECTED TO BE PRESENTED BY MEANS OF DEPOSITION 154. Mark Epstein 30 Vandam Street New York, NY 10013 155. Adriana Ross (Adriana Mucinska) c/o Alan S. Ross, Esq. 156. Louella Rabuyo 358 El Brillo Way Palm Beach, FL 33480 157. Alfredo Rodriguez
NOT A CERTIFIED COPY EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley J. Edwards Page 18 of22 c/o Federal Public Defender or Bureau of Prisons 11349 SW 86TH Lane Miami, FL 158. Scott Rothstein c/o Mark Nurik One East Broward Boulevard, Suite 700 Fort Lauderdale, Florida 33301 159. Jeffrey Epstein 160. Courtney Wild c/o Adam Horowitz. Horowitz Law 425 North Andrews A venue, Suite 2 Fo11 Lauderdale FL 33301 EXPERT WITNESSES 161. Bernard J. Jansen, Ph.D. c/o Jack Scarola Searcy Denney Scarola Barnhai1 & Shipley 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 The following witnesses are attorneys that are not retained or specially employed to provide expert testimony, but may provide opinions relating to the propriety of Brad Edward's conduct of discovery in the prosecution of the Epstein claims. 162. Robert C. Josefsberg, Esquire Podhurst Orseck, PA One S.E. 3rd A venue, Suite 2700 Miami, FL 33131 163. Charles Lichtman, Esquire Berger Singerman 300 East Las Olas Boulevard, Suite 1000 Ft. Lauderdale, FL 33301
NOT A CERTIFIED COPY EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley J. Edwards Page 19 of22 164. Spencer Kuvin, Esquire 1800 S. Australian Avenue, #400 West Palm Beach, Florida 33409 165. Theodore Leopold, Esquire Cohen Milstein 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, Florida 33410 166. Adam Horowitz, Esquire 425 N. Andrews Ave., Suite 2 Ft. Lauderdale, FL 33301 167. Isidro M. Garcia, Esquire Garcia Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL, 33401 168. Earleen Cote, Esquire Kubicki Draper One East Broward Boulevard, Suite 1600 Fort Lauderdale, FL 33301 169. William Berger, Esquire Weiss, Handler, Cornwell, P.A. 2255 Glades Road, Suite 218A Boca Raton, FL 33431 Plaintiff reserves the right to amend this list.
NOT A CERTIFIED COPY EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley J. Edwards Page 20 of22 I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all Counsel on the attached list, this ~ day of f00t-eMW2011. Florida Bar No.: 169440 Attofey ~;Mail(s): jsx@searcylaw.com and me~@secylaw.com Pri a E-Mail: _scarolateam@searcylaw.com Se y Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9451 Attorneys for Bradley J. Edwards
NOT A CERTIFIED COPY EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counterplaintiff Bradley J. Edwards Page 21 of22 COUNSEL LIST Jack Scarola, Esquire _ scarolateam@searcylaw.com; Searcy Denney Scarola Barnhart & Shipley PA 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Phone: (561) 686-6300 Fax: (561) 383-9451 Attorneys for Bradley J. Edwards Scott J. Link, Esq. Link & Rockenbach, P.A. Scott@linkrocklaw.com Kara@linkrocklaw.com 1555 Palm Beach Lakes Boulevard, Suite 301 West Palm Beach, FL 33401 Phone: 561-727-3600 Fax: 561-727-3601 Attorneys for Jeffrey Epstein William Chester Brewer, Esquire wcblaw@aol.com; wcblawasst@gmail.com 250 S Australian A venue, Suite 1400 West Palm Beach, FL 33401 Phone: (561)-655-4777 Fax: (561)-835-8691 Attorneys for Jeffrey Epstein Jack A. Goldberger, Esquire jgoldberger@agwpa.com; smahoney@agwpa.com Atterbury Goldberger & Weiss, P.A. 250 Australian A venue S, Suite 1400 West Palm Beach, FL 33401 Phone: (561)-659-8300 Fax: (561)-835-8691 Attorneys for Jeffrey Epstein
NOT A CERTIFIED COPY EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List ofCounterplaintiffBradley J. Edwards Page 22 of22 Bradley J. Edwards, Esquire staff.efile@pathtojustice.com Fanner Jaffe Weissing Edwards Fistos & Lehrman, P.L. 425 N Andrews A venue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954)-524-2820 Fax: (954)-524-2822 Tonja Haddad Coleman, Esquire tonja@tonjahaddad.com; efiling@tonjahaddad.com Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Phone: (954)-467-1223 Fax: (954)-337-3716 Attorneys for Jeffrey Epstein Marc S. Nurik, Esquire marc@nuriklaw.com One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: (954)-745-5849 Fax: (954)-745-3556 Attorneys for Scott Rothstein
NOT A CERTIFIED COPY EXHIBIT C
NOT A CERTIFIED COPY JEFFREY EPSTEIN, Plaintiff(s), vs. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800:XXXXMBAG SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant(s). I --------------- NOTICE OF SERVING ANSWERS TO INTERROGATORIES PROPOUNDED BY COUNTER-DEFENDANT JEFFREY EPSTEIN Bradley J. Edwards, by and through his undersigned counsel, hereby files this Notice of Serving Answers to Interrogatories with the Court propounded by the Counter-Defendant, Jeffrey Epstein, on July 12, 2017, which have been furnished to the attorneys for the Counter-Defendant. E-Mail(s): jsx@searcylaw.com; and cann@searcylaw.com Primary E-Mail: _scarolateam@searcylaw.com Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: 561-383-9451 Attorneys for Bradley J. Edwards
NOT A CERTIFIED COPY EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Notice of Serving Answers to Interrogatories William Chester Brewer, Esquire wcblaw@aol.com; wcblawasst@gmail.com 250 S Australian Avenue, Suite 1400 West Palm Beach, FL 33401 Phone: (561)-655-4777 Fax: ( 561)-835-8691 Attorneys for Jeffrey Epstein COUNSEL LIST Jack A. Goldberger, Esquire jgoldberger@agwpa.com; smahoney@agwpa.com Atterbury Goldberger & Weiss, P.A. 250 Australian A venue S, Suite 1400 West Palm Beach, FL 33401 Phone: (561)-659-8300 Fax: (561)-835-8691 Attorneys for Jeffrey Epstein Bradley J. Edwards, Esquire staff. efil e@pathto justice. com Farmer Jaffe Weissing Edwards Fistos & Lehrman, P.L. 425 N Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954)-524-2820 Fred Haddad, Esquire Dee@FredHaddadLaw.com; Fred@FredHaddadLaw.com Fred Haddad, P.A. One Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 Phone: (954)-467-6767 Fax: (954)-467-3599 Attorneys for Jeffrey Epstein Tonja Haddad Coleman, Esquire tonja@tonjahaddad.com; efiling@tonjahaddad.com Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Phone: (954)-467-1223 Fax: (954)-337-3716 Attorneys for Jeffrey Epstein
NOT A CERTIFIED COPY Marc S. Nurik, Esquire marc@nuriklaw.com One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: (954)-745-5849 Fax: (954)-745-3556 Attorneys for Scott Rothstein 3
NOT A CERTIFIED COPY INTERROGATORIES As to every individual identified on your List of Trial Witnesses, and each category/group of witnesses listed thereon, please provide with particularity the following: 1. The proper name, address, telephone number, electronic mail address, or other means of contact for each witness: ANSWER: DESCRJPTION OF WITNESSES WITNESSES EXPECTED TO BE PRESENTED 1. Jeffrey Epstein 2-3 (Ex,.pected to refuse to testify on each element of the claim for Malicious Prosecution). Consistent with prior assertions of privilege. 2. Sarah Vickers (formerly Kellen) c/o John Stephenson 1201 W. Peachtree Street Atlanta, Georgia 30339 2-3 Expected to testify about each element of malicious prosecution except bonafide termination and damages. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages) Subject to assertions of privilege 3. Nadia Marcinkova c/o Erica Dubno 767 Third Avenue, Suite 3600 New York, New York 10017 2-3 Expected to testify about each element of malicious prosecution except bonafide termination and damages. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages) Subject to assertions of privilege 4. Virginia Robe11s c/o Stan Pottinger
NOT A CERTIFIED COPY 5. 6. 7. 8. 49 Twin Lakes Road, Suite 100 South Salem NY 10590 DESCRIPTION OF WITNESSES 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages through her own knowledge and experiences with Epstein. Maria Farmer c/o Peter Guirguis, Esq. MINTZ & GOLD LLP 600 Third A venue, 25th Floor, New York 10016 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant info1mation to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages through her own knowledge and experiences with Epstein. Annie Fanner c/o Peter Guirguis, Esq. MINTZ & GOLD LLP 600 Third Avenue, 25th Floor, New York, 10016 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of pw1itive damages through her own knowledge and experiences with Epstein. Nadia Bjorlin 13701 Riverside Drive, Suite 800 She1man Oaks, CA 91423-2449 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claim...
NOT A CERTIFIED COPY 9. 10. 11. 12. DESCRIPTION OF WITNESSES 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant info1mation to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages through her own knowledge and experiences with Epstein. Robert Josefsberg, Esquire PODHURST ORSECK, PA, 25 W FLAGLER STREET, STE 800, MIAMI, FL 33131 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant infonnation to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of ptmitive damages. Will confirm the propriety of Edwards' actions. Detective Joseph Recarey Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages. Chief Michael Reiter Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have r...
NOT A CERTIFIED COPY DESCRIPTION OF WITNESSES the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages. 13. Charles Lichtman, Esquire 350 East Las Olas Boulevard I Suite 1000 Fort Lauderdale, FL 33301 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify as to the falsity of the claims made by Epstein against Edwards and the propriety of Edwards' actions. 14. William Scherer, Esquire 633 S Federal Hwy #800 Fort Lauderdale, FL 33301 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify as to the falsity of the claims made by Epstein against Edwards. 15. Antonio Figueroa (Tony) Palm Coast, Florida 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages through his own knowledge and experiences with Epstein. 16. Records Custodian of Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 17. Records Custodian of United States Attorney's Office for the Southern District of Florida 18. Records Custodian of the Federal Bureau oflnvestigations 19. Spencer Kuvin, Esquire 1800 S. Australian Avenue, #400 West Palm Beach, Florida 33409 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecut...
NOT A CERTIFIED COPY DESCRIPTION OF WITNESSES 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages. Will also confirm the leadership role played by Edwards in the prosecution of civil claims against Epstein and the propriety of Edwards' actions. 21. Rinaldo Rizzo c/o Robe1i Lewis 228 East 45th Street I 17th Floor New York, NY 10017 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages through his own knowledge and experiences with Epstein. 22. Adam Horowitz, Esquire 425 N ANDREWS A VE., SUITE 2 FT. LAUDERDALE, FL 33301 2-3 Expected to testify about the malicious prosecution elements of absence of probable cause and malice. Will testify to the truth of the claims prosecuted by Edwards against Epstein, the likelihood that the discovery conducted by Edwards would have resulted in relevant information to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages. Will also confinn the leadership role played by Edwards in the prosecution of civil claims against Epstein and the propriety of Edwards' actions. 23. Isidro M. Garcia, Esquire Garcia Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL, 33401 2-3 Expected to testify about th...
NOT A CERTIFIED COPY DESCRIPTION OF WITNESSES punitive damages. Will also confirm the leadership role played by Edwards in the prosecution of civil claims against Epstein and the propriety of Edwards' actions. WITNESSES WHICH MAY BE CALLED IF NEED ARISES 2-3. Each of the witnesses listed below as numbered 25-157 (with the exception of records custodians) has infom1ation pertaining to the malicious prosecution elements of absence of probable cause and malice. If called, each could provide information regarding the truth of the claims prosecuted by Edwards against Epstein, and the likelihood that the discovery conducted by Edwards would have resulted in relevant infonnation to proving aspects of the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages. 25. Adriana Mucinska 1040 South Shore Drive Miami Beach, FL 3 3141 26. Landon Thomas c/o New York Times 620 Eighth A venue New York, NY 10018 27. Oren Kramer c/o Boston Provident, L.P. 717 5th Avenue #12A New York, NY 10022 28. Lawrence La Vecchio United States Attorney's Office Southern District of Florida Broward Financial Center Fort Lauderdale, Florida. Will also confinn the leadership role played by Edwards in the prosecution of civil claims against Epstein and the propriety of Edwards' actions. 29. Amanda Laszlo c/o Brad Edwards, Farmer Jaffe Weissing 425 N01ih Andrews Avenue Fort Lauderdale FL 33301 30. Evgenia lgnatieva 1650 Broadway, #910 New York, NY 10019 31. Anouska DeGeorgiou 536 N. Edinburgh Avenue, Los Angeles, CA 90048 32. Angelique Garcia c/o Adam Horowitz FARMER, JAFFE, WEISSING, ET AL. 425 N ANDREWS A VE., SUITE 2 FT. LAUDERDALE, FL 33301 33. Carolyn Andriamo c/o Jack Scarola SEARCY DENNEY, ET AL.
NOT A CERTIFIED COPY DESCRIPTION OF WITNESSES 2139 PALM BEACH LAKES BLVD. West Palm Beach, FL 33409 34. Ashley Davis c/o Robe11 Josefsberg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 35. Brandy Brenson c/o Spencer Kuvin 1800 South Australian Ave #400 West Palm Beach, Florida, 33409 36. Molly Smythe c/o Robert Josefsberg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 37. Courtney Langley c/o Spencer Kuvin 1800 South Australian Ave #400 West Palm Beach, Florida, 33409 38. Courtney Wild c/o Bradley Edwards, Esq. FARMER, JAFFE, WEIS SING, ET AL. 425 N ANDREWS AVE., SUITE 2 FT. LAUDERDALE, FL 33301 39. Paul Cassell, Esq. 383 S. University Street Salt Lake City Utah, UT 84112 40. Faith Pentek c/o Adam Horowitz FARMER, JAFFE, WEISSING, ET AL. 425 N ANDREWS A VE., SUITE 2 FT. LAUDERDALE, FL 33301 41. Teala Davies 1212 N. Clark Street West Hollywood, CA 90069 42. Felicia Esposito Cartwright c/o Robert Josefsberg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 43. Jennifer Amenold c/o Robert Josefsberg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800
NOT A CERTIFIED COPY DESCRIPTION OF WITNESSES MIAMI, FL 33131 44. Jennifer Pitts Catino c/o Robert Josefsberg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 45. Prince Andrew Albert Christian Edwards Duke of York, Buckingham Palace Road London SWlA lAA 46. Frederic Fekkai Address Currently Unknown 47. Kara Henderson c/o Robert Josefsberg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 48. Lesley Groff c/o Mike Miller 1114 Avenue of the Americas New York, NY 10036 49. Dave Rogers c/o Bruce Reinhart 505 S. Flagler Drive, Ste 300 West Palm Beach, FL 33401 50. Lauren Murphy c/o Adam Horowitz FARMER, JAFFE, WEISSING, ET AL. 425 N ANDREWS A VE., SUITE 2 FT. LAUDERDALE, FL 33301 51. Leigh Skye Patrick c/o Robert Josefsberg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 52. Meagan Dorshel c/o Robert Josefsberg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 53. Michelle Licata c/o Adam Horowitz FARMER, JAFFE, WEISSING, ET AL. 425 N ANDREWS A VE., SUITE 2 FT. LAUDERDALE, FL 33301
NOT A CERTIFIED COPY DESCRIPTION OF WITNESSES 54. Molly Smythe c/o Robert Josefsberg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 55. Tod Meister 101 Seminole Avenue Palm Beach, FL 38480 56. Rhiaimon Schwegel c/o Robert Josefsberg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 57. Sabrina Ewart c/o Robert Josefsberg, Esq. PODHURST ORSECK, PA, 25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 58. Saige Gonzales c/o Spencer Kuvin 1800 South Australian Ave #400 West Palm Beach, Florida, 33409 59. Johanna Sjoberg c/o Marshall Dore Louis 40 NW third Street, Suite 200 Miami, FL 33128 60. Jason Richards Federal Bureau of Investigation 16320 NW 2nd AVE., MIAMI, FL 33169 61. Shawna Rivera c/o Bradley Edwards, Esq. FARMER, JAFFE, WEISSING, ET AL. 425 N ANDREWS A VE., SUITE 2, FT. LAUDERDALE, FL 33301 62. Tatwn Miller c/o Bradley Edwards FARMER, JAFFE, WEISSING, ET AL. 425 N ANDREWS AVE., SUITE 2, FT. LAUDERDALE, FL 33301 63. Vanessa Zalis c/o Adam Horowitz FARMER, JAFFE, WEIS SING, ET AL. 425 N ANDREWS A VE., SUITE 2 FT. LAUDERDALE, FL 33301
NOT A CERTIFIED COPY DESCRIPTION OF WITNESSES 64. Virginia Alvarez c/o Adam Horowitz FARMER, JAFFE, WEISSING, ET AL. 425 N ANDREWS A VE., SUITE 2 FT. LAUDERDALE, FL 33301 65. Yolanda Lopez c/o Adam Horowitz FARMER, JAFFE, WEISSING, ET AL. 425 N ANDREWS A VE., SUITE 2 FT. LAUDERDALE, FL 33301 66. Nezbitt Kurkendall Federal Bureau of Investigation 16320 NW 2nd A VE. MIAMI, FL 33169 67. Daynia Nida cl o Isidro M. Garcia Garcia Law Fi1m, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL, 33401 68. Igor Zinoview Address Crrently Unknown 69. Pralaya Cuomo Address Currently Unknown 70. Svetlana Pozhidaeva 9 East 71 Street New Yark, NY 10021 71. Seth Lehrman 425 N ANDREWS A VE., SUITE 2 FT. LAUDERDALE, FL 33301 72. Matt Weissing 425 N ANDREWS A VE., SUITE 2 FT. LAUDERDALE, FL 33301 73. Maria Villafana 500 S. Australian A venue, #400 West Palm Beach, FL 33401. Will also confi1111 the leadership role played by Edwards in the prosecution of civil claims against Epstein and the propriety of Edwards' actions. 74. Any additional individuals identified as victims by the United states Attorney's Office and whose identities were conveyed to Jeffrey Epstein as part of a list supplied as it related to the NPA 75. Leslie Wexner Three Limited Parkway Columbus, Ohio 43206. Subject to assertions of privilege 76. Donald Trump c/o Alan Gaiien, Esq. 725 Fifth A venue
NOT A CERTIFIED COPY DESCRIPTION OF WITNESSES New York, NY 10022. Subject to the assertions of privilege 77. LaJTy Visoski 1131 PINE POINT ROAD RIVIERA BEACH, FL 33401 78. Maritza Vasquez 1293 SW 2l51 Ten-ace Miami, FL 33145 79. Max:imilia Cordero C/O ATTORNEY WILLIAM UNROCH 140 WEST END, APT 30-BW NEW YORK, NY 10023 80. Brittany Beale c/o Spencer Kuvin 1800 S. Australian A venue, #400 West Palm Beach, Florida 33409 81. Melissa Eaton 2915 SHARE RD 111 TALLAHASSEE, FL 31312 82. Danielle Hendrick Dicenso c/o Robert Josefsberg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 83. David Copperfield (David Seth Kokin) 11675 GLOWING SUNSET LN LAS VEGAS, NV 89135 84. Haley Robson 12247 72ND CTN WEST PALM BEACH, FL 33412 85. Michael Fisten Weston, FL 86. Russell Adler Delray Beach, FL 87. Marie Alessi 6791 FAIRWAY LAKES DR. BOYTON BEACH, FL 33472 88. Janusz Banasiak 358 EL BRILLO WAY PALM BEACH FL, 33480 89. Beata Banasiak 358 EL BRILLO WAY PALM BEACH, FL 33480
NOT A CERTIFIED COPY DESCRIPTION OF WITNESSES 90. Juan Alessi 6791 FAIRWAY LAKES DR. BOYTON BEACH, FL 33472 91. Michael Friedman 53320 A VENIDA MADERO LA QUINTA CA 92253 92. Jerry Goldsmith 13285 SILVER FOX LN WEST PALM BEACH, FL 33418-7942 93. Rosalie Freedman 53320 A VENIDA MADERO LA QUINTA CA 92253 94. V aldson Cotrin Address Currently Unknown 95. Dana Bums 301 E 66TH ST APT 11P NEW YORK, NY 10065 96. Cecelia Stein Unknown, South Africa 97. Glenn Dubin 1040 5TH A VE UNIT 1 SA NEW YORK, NY 10028-0137 98. Abigail Wexner Tlu·ee Limited Parkway Columbus, Ohio 43206 99. Officer Munyan Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 100. Officer Minot Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 101. Sgt. Sorge Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 102. Christina Venero S/A Witness #152 103. Arnold Paul Prospari 215 WESTMINSTER RD WEST PALM BEACH, FL 33405-1654
NOT A CERTIFIED COPY DESCRIPTION OF WITNESSES 104. Joseph Pagnano 1217 S FLAGLER DR STE 301 WEST PALM BEACH, FL 33401 105. Stephan Kosslyn 28 GARFIELD ST CAMBRIDGE MA 02138-1802 106. Cecile Dejongh 23 8 ESTATE MAFOLIE ST THOMAS VI 00802 107. Tommy Mottola 302 CARIBBEAN RD PALM BEACH FL 33480-3012 108. Mike Sanka 449 S BEYERL Y DR STE 101 BEYERL Y HILLS, CA 90212 109. Cecilia Steen S/A Witness #105 110. William "Bill" Riley 5645 CORAL RIDGE DR# 391 CORAL SPRINGS FL 33076 1 11. Howard Rubenstein 1345 A VENUE OF THE AMERICAS NEW YORK, NEW YORK 10105 112. Robert Meister 101 SEMINOLE AVE PALM BEACH FL 33480 113. Todd Meister 101 SEMINOLE AVE PALM BEACH, FL 33480 114. President William J. Clinton 115. William Hammond 2965 Fontana Place Royal Palm Beach, FL 116. Robert Roxburgh 5600 Norih Flagler Dr, #250 West Palm Beach, Florida 117. Michele Pagan Palm Beach Police Department 345 South County Road Palm Beach, FL 33480
NOT A CERTIFIED COPY DESCRIPTION OF WITNESSES 118. Michele Dawson Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 119. Amy Fortimer 12309N OLD COUNTRY RD WELLINGTON, FL 33414 120. Anna Skidan 545 E 5TH ST APT 6E NEW YORK, NY 10009 121. Christina Venero 971 NW FRESCO WAY APT 208 JENSEN BEACH, FL 34957 122. Dara Gehringer (Dara Preece) 3139 Kingston Court, West Palm Beach, Florida 123. Juliana Barbosa 9PINTA RD MIAMI FL 33133-2607 124. Latasha Lowe c/o Adam Horowitz FARMER, JAFFE, WEISSING, ET AL. 425 N ANDREWS A VE., SUITE 2 FT. LAUDERDALE, FL 33301 125. Melissa Hanes 115 Sunshine Blvd West Palm Beach, Florida 126. Zack Bryan 1150 Larch Way Wellington, Florida 127. Zinta Braukis 925 W AVENUE 37 LOS ANGELES, CA 90065-3241 128. Larry M01Tison 11148 COBBLEFIELD DR. WELLINGTON, FL 33449 129. Story Cowles 801 S OLIVE AVE UNIT 201 S WEST PALM BEACH, FL 33401 130. Alan Dershowitz 26 RESERVOIR ST CAMBRIDGE, MA 02138 or TUDOR CITY PL
NOT A CERTIFIED COPY DESCRIPTION OF WITNESSES APT7K NEW YORK, NY 10017. Subject to assertions of privilege 131. Michael Dawson Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 132. Salaam Kahlid Monroe 119 MENORES A VE APT 3 CORAL GABLES, FL 33134 133. Jelitza Negrette 503 CHANDLERS WARF PORTLAND, ME 04101 134. Sergia Cordero 825 BRICKELL BAY DR., #1141 MIAMI, FL 33131 135. Cassandra Rivera 5011 EL CLARO CIRCLE WEST PALM BEACH, FL 33415 136. Randee Speciale PALM BEACH VICTIM SERVICES 205 N DIXIE HIGHWAY# 5.1100 WEST PALM BEACH, FL 33401 137. Nicole Hesse Address Cun-ently Unknown 138. Steven Hoffenberg Address Cun-ently Unknown 139. Michael Stroll Address Cun-ently Unknown 140. Douglas Shoettle 243 Riverside, Dr. New York, NY 10025 141. Ghislaine Maxwell Address Currently Unknown 142. Records Custodian Amazon 143. Records Custodian Yellow Cab 144. Records Custodian Citrix Systems, Inc. 145. Records Custodian Federal Bureau of Investigation 146. Records Custodian Milton Girls Juvenile Facility
NOT A CERTIFIED COPY DESCRIPTION OF WITNESSES 5770 EAST MIL TON ROAD MILTON, FL . 147. Records Custodian School District of Palm Beach County - 3344 FOREST HILL BLVD, SUITE C-124 West Palm Beach, FL 33406 148. Records Custodian St. Mary's Medical Center 901 45 th STREET West Palm Beach, FL 33401 149. Records Custodian WELLINGTON REGIONAL HO SPIT AL 10104 FORREST HILL BLVD WELLINGTON, FL 33414 150. All witnesses that Defendants have listed on their Witness List not objected to by Plaintiff, Jane Doe. 151. All rebuttal witnesses. 152. All People on Jeffrey Epstein's Inmate Visitor Log while he was in jail. WITNESS TESTIMONY EXPECTED TO BE PRESENTED BY MEANS OF DEPOSITION 153. Mark Epstein 30 VANDAM STREET NEW YORK, NY 10013 154. Adriana Ross (Adriana Mucinska) c/o Alan S. Ross, Esq. 155. Louella Rabuyo 358 EL BRILLO WAY PALM BEACH, FL 33480 156. Alfredo Rodriguez 11349 SW 86TH LN, Miami, FL C/O Federal Public Defender or Bureau of Prisons 157. Scott Rothstein c/o Mark Nurik One East Broward Boulevard, Suite 700 Fort Lauderdale, Florida 33301
NOT A CERTIFIED COPY 2. Each contested factual issue expected to be addressed by the witness, including identifying with particularity as to which element(s) of your claim for MaliciousProsecution this witness's testimony is applicable: ANSWER: See response to number 1. 3. A detailed description of the testimony expected to be presented at trial by the witness as to each contested factual issue and element of your claim against Epstein: ANSWER: See response to number 1. 4. A description of the Trial Exhibit List number of each exhibit expected to be introduced into evidence by the witness: ANSWER: Unknown at this time which exhibits will be introduced through which witness. 5. A description of the Trial Exhibit List number of each exhibit introduced through other means about which the witness is expected to testify, together with a description of thewitness' expected testimony regarding each exhibit: ANSWER: Unknown at this time the exhibits about which each witness will testify.
NOT A CERTIFIED COPY STATE OF_--'Fi'-----"/4'-"-,(Jl<,_l_r cl-'-°"---' __ COUNTY OF ,7&ol))M cL The foregoing instrument was acknowledged before me this / /~ day of tla?J- ,2017 by J?,c,,./ OwM.d/,J , who-:rersonalll'. ~ to meorwhohasproduced'---__________ as identification and who did/did ~ not takeanoath. (Notary name - print) J NOTARY PUBLIC, State of Florida , "eLWCHIAN 310N # GG 061792 ,: .fl~nuary 11, 2021 . .~lal.• Plilllo lJndelWIID!9 , MARIA W. KW,JCHIAA '\ MV coMMtSSION # 00061792 exPlfU:S: JaOUBIY 11, 2021 l'!Ctldod'lll11No111YP\NJO~
NOT A CERTIFIED COPY EXHIBIT D
NOT A CERTIFIED COPY 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY EDWARDS, individually, Defendants/Counter-Plaintiffs. I ----------------- TRANSCRIPT OF PROCEEDINGS DATE TAKEN: TIME: PLACE BEFORE: Wednesday, November 29th, 2017 10:04 a.m. - 3:55 p.m. 205 N. Dixie Highway, Room l0C West Palm Beach, Florida Donald Hafele, Presiding Judge 1 This cause came on to be heard at the time and place aforesaid, when and where the following proceedings were reported by: Sonja D. Hall Palm Beach Reporting Service, Inc. 1665 Palm Beach Lakes Boulevard, Suite 1001 West Palm Beach, FL 33401 (561) 471-2995 PALM BEACH REPORTING SERVICE, INC. (561)471-2995
NOT A CERTIFIED COPY 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Court is concerned the case that -- strike that. The question and answer that was just provided would be admissible. What we're talking about, Mr. Scarola, are questions that were cited in the motion and that the court has chosen not to read, that are of a graphic, sexual nature, and have, to my recollection, a general form of question, as opposed to specifics: Have you ever done certain things to minors? Have you ever been with prostitutes? Have you ever -- things of that nature. MR. SCAROLA: I don't recall that last question, but I understand the Court's -- I understand the Court's concern. THE COURT: Ms. Rockenbach's question. (Again, I know you understand it, but I) @ant to make sure that the record is clearJ (and that's this.) (I have an obligation, as) (both sides are well aware, to ensure that we) (are working on a level ~ing field to the) @xtent that it is 2ossible.) (I have the obligation, as) ®s. Rockenbach 2oints out, to be thcl 70 PALM BEACH REPORTING SERVICE, INC. (561)471-2995
NOT A CERTIFIED COPY 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (gatekee2er of evidence and to ensure to the) (best of my ability that we are not g-9.i.!lg_!_Q} (be enga_gi,Q_g in ~jorative name-calling _ly~ @l___guestioning, nor are we g2i.Q_g to get into) (inflammatory___ly2es of questioning _just for) (the sole 2ur2ose of information}. Now, I know you wouldn't do that. But at the same time, as advocates, your respective positions have to be clear-cut in favor of your respective clients. However, as I said earlier, it really becomes an issue of drilling down into the specifics before I can make rulings on the actual questions that are being sought to be introduced. So the global aspect of the Court's decision at this time, until I look at the actual questions, is essentially this. And, that is, that I'm going to permit -- and we've already gotten a stipulation on the record by Mr. Epstein's counsel, which I appreciate -- that is, he's not going to be receding from his Fifth Amendment invocations. He's not going to be changing his testimony, so as to necessitate further 71 PALM BEACH REPORTING SERVICE, INC. (561)471-2995
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discovery as it relates to his testimonial
evidence that has already been presented.
Therefore, those questions that deal
with, for example, the question that you
asked and answered, would be admissible.
Those, because of the reasons that I stated
earlier, would seem to make common sense to
me and seems to be the thrust of the
decisions of the court's, whether in Florida
or outside of Florida -- the vast majority
being outside of the state and some from the
federal courts -- and, that is, that the
Fifth Amendment cannot be used to take away
Mr. Edwards' ability to prove his case or
prove the probable cause element.
@o to the extent that it would bcl
(needed to go in front of the j~, any)
{guestions that deal with the issue of)
(Mr. E2stein's lawsuits brought b0
(Mr. Edwards on behalf of the res2ective)
(clients, would be germane.) (And anyj
Unvocation, such as what was illustrateaj
fuere, would be germane and relevant anaj
(found to be admissible.) (That's the core)
(ruling of the Court.)
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NOT A CERTIFIED COPY 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (Now, when it comes to issues of generaD (g~Rhic questioning, such as what has been) ~Rlif ied by ....Yf2.Y. of the) (counter-defendant's motion, those will not) '12.i...2ermitted.) The closer question, and the one that I need to drill down further, is one of because the complaint -- and I appreciate the fact that you brought this with you today and provided it to me -- because the complaint delineates the nature of the allegations at least from a summary perspective of the three claims -- how much are we going to be able to introduce, if those questions were asked? I haven't memorized the deposition testimony. There were at least two depositions, if I'm not mistaken. MS. ROCKENBACH: Yes, Your Honor. THE COURT: Two depositions. I haven't memorized that testimony. But since the complaint -- let me cite to you exactly where we are -- where I am alluding to here. Page 18 and it states, "Rothstein and the litigation team knew or 73 PALM BEACH REPORTING SERVICE, INC. (561)471-2995
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specifically on this aspect of the case,
because one of the things that the defense
is attempting to exclude is any reference to
anything other than L.M., E.W. and Jane Doe
cases.
(Your Honor sug9ested -- and I thoug:@
(that I heard you correctly -- that evidence)
(with regard to other claims actually filed)
@:.gainst E2stein would be relevant and)
(material.) {And clearly it is.)
(THE COURT:) (I believe what I said was)
(those cases filed by Mr. Edwards or anyj
(claims that were made against E2stein by_ii}
@lient re2resented by Mr. Edwards1
Tell me why you think that the
aggregate cases not having anything to do
with Mr. Edwards' representation or
Rothstein firm's representation -- because
Mr. Berger, I think, was involved in some
respects as well.
MR. SCAROLA:
Co-counsel.
THE COURT:
Solely as co-counsel
I
believe that to be the case -- are you
suggesting that the aggregate cases would be
relevant?
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with regard to other child molestations in
any child molestation claim.
(THE COURT:) (So let's talk about that)
Uor a minute.) ®ecause again, what I don'tj
(want this to turn into is a case testing)
(whether or not E2stein was an alleged seriaD
(child molester.) (It would not, in my view,)
(pass muster legally, and I don't want to tr0
(this case twice.)
(I think that we should be extremely)
@ircums2ect when it deals -- when we araj
@ealing with global issues of molestation otj
{g~Rhic descri2tions of any_ty2es of alleg!i4)
(molestation, exce2t where we are dealing)
(with claims that have been brought on behalf)
@f those re2resented by Mr. Edwards.)
@he risk of error, if we go beyond thatj
(intended limitation, is significant.) (And I)
(want to make sure that we, again, araj
(focused on the elements of the claim.) (And)
(whether it be for com2ensatory damagej)
fussociated with Mr. Edwards' claim orj
(punitive damages associated with)
(Mr. Edwards' claim, we are still dealing)
(with a malicious 2rosecution claim, solely_ii}
98
PALM BEACH REPORTING SERVICE, INC.
(561)471-2995
NOT A CERTIFIED COPY 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 @alicious 2rosecution claim.) ~nd so to deviate from that directio~ @ould be 2recarious and concerning to thcl ~ourt, in 2articular, because when we'raj @ealing with issue of 2robable cause, we'raj ffocusing on -- as I've made clear -- notj (Qri1y Mr. E2stein's stated intent, but I) ffully intend to allow circumstantiaD ~vidence, inclusive of the invocation of thcl (Fifth Amendment relevant questions) (pertaining to the 2laintiff's -- the) (counter-2laintiff's, more 2recisely~ (Mr. Edwards' 2osition to ex2lain to the jury] fuhy -- or to the Court -- why Mr. E2stein) ~rought this claim, what were the truaj (motivating factors concerning same.) @o allow this to intrude intcl (allegations of serial molestation is) ~gerous and is concerning:] (You may 2roceed .) MR. SCAROLA: Thank you, Your Honor. I acknowledge the legitimacy of the Court's concern. And I recognize the fact that the Court, appropriately, under Rule 403, must balance probative value against prejudice. 99 PALM BEACH REPORTING SERVICE, INC. (561)471-2995
NOT A CERTIFIED COPY 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 publicize and to sensationalize the circumstances so as to increase the value of at least the claims that were held by the Rothstein firm. MR. SCAROLA: Which I think is what every lawyer is supposed to do within the bounds of propriety, obviously. But our job is to maximize the value of our clients' claims. THE COURT: And on the other side of the coin is Mr. Edwards taking the position that the impetus -- or an impetus for filing the complaint at bar was the exposure of Mr. Epstein, once again, to the ignominy of having to face the publicity of a non-prosecutorial agreement where there were admissions, where there were agreements perhaps not admissions -- but agreements that limited the prosecution of him as it relates to multiple claimants or multiple potential victims. @o again, my ruling on that is if thercl fure questions that have to do with thi~ tissue, globally they will be allowed to bcl fusked subject to further argument as itj 118 PALM BEACH REPORTING SERVICE, INC. (561)471-2995
NOT A CERTIFIED COPY 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (relates to the multi2licity of the numerous) bictims that we are dealing with here as) (allegii4] Same as it goes with this 234-page federal complaint. If there were any questions that were asked of Mr. Epstein where he refused to answer on Fifth Amendment grounds, I find that the information would be relevant. Therefore, his failure to answer would be -- would be able to be utilized if such questions were asked of him regarding the 234-page federal complaint filed on behalf of L.M. by Mr. Edwards. MR. SCAROLA: Let me just clarify one point, and that is, we have been focusing on questions that have already been asked of Mr. Epstein. Obviously, we have the right to call Mr. Epstein as an adverse witness. We have the right to put him in that witness chair in front of the jury and to ask him questions that Your Honor has considered to be appropriate that may not have been asked at the time of his deposition. So I want to make it clear that we 119 PALM BEACH REPORTING SERVICE, INC. (561)471-2995
NOT A CERTIFIED COPY EXHIBIT E
NOT A CERTIFIED COPY IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY EDWARDS, individually, Defendants/Counter-Plaintiffs. I ------------------ TRANSCRIPT OF PROCEEDINGS DATE TAKEN: TIME: PLACE BEFORE: Thursday, December 7th, 2017 10:01 a.m. - 12:57 p.m. 205 N. Dixie Highway, Room llB West Palm Beach, Florida Donald Hafele, Presiding Judge This cause came on to be heard at the time and place aforesaid, when and where the following proceedings were reported by: Sonja D. Hall Palm Beach Reporting Service, Inc. 1665 Palm Beach Lakes Boulevard, Suite 1001 West Palm Beach, FL 33401 (561) 471-2995 Palm Beach Reporting Service, Inc. 561-471-2995 1
NOT A CERTIFIED COPY
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So
that's the decision.
Next issue, please.
Palm Beach Reporting Service, Inc.
561-471-2995
5
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MR. SCAROLA:
Excuse me.
May I also
ask for this clarification, Your Honor?
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MR. SCAROLA:
Thank you, sir.
THE COURT:
Because, again, it tends to
prove or disprove a material fact, i.e.,
probable cause, motive, malice.
Again, whether or not the jury accepts
that -- it's going to be up to the jury to
accept it, reject it, give it the weight it
deserves, or to infer anything that they
reasonably believe would be inferrible as a
result of that information.
The next issue, please.
Palm Beach Reporting Service, Inc.
561-471-2995
6
NOT A CERTIFIED COPY EXHIBIT F
NOT A CERTIFIED COPY
JEFFREY EPSTEIN,
Plaintiff/Counter-Defendant,
v.
SCOTT ROTHSTEIN, individually, and
BRADLEY J. EDWARDS, individually,
Defendants/Counter-Plaintiff.
_________________ !
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY, FLORIDA
Case No. 50-2009CA040800XXXXMBAG
ORDER ON PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S
REVISED OMNIBUS MOTION IN LIMINE SECTION D
{REFERENCES TO CASES NOT LITIGATED BY EDWARDS)
THIS MATTER came before the Court for hearing on December 7, 2017, upon Section D
of the Revised Omnibus Motion in Limine filed by Plaintiff/Counter-Defendant Jeffrey Epstein
("Epstein") seeking to exclude references to any cases against Epstein which were not prosecuted
by Defendant/Counter-Plaintiff Bradley J. Edwards ("Edwards"). [D.E. 1070.] The Court, having
reviewed the Motion and Edwards' Response [D.E. 1089], having heard argument of counsel, and
being otherwise fully advised in the premises, it is hereby
ORDERED AND ADJUDGED that the parties may speak generally about the number of
claims that Epstein was facing at the time he initiated, and during his continuance, of this
proceeding against Edwards. The details, the merits and what may have been discovered in cases
against Epstein which were not prosecuted by Edwards will not be admissible into evidence,
subject to the Court's reconsideration at trial as the evidence is presented. (12/7/17 Tr. 4:25-5:24.)
Edwards, however, will be permitted to discuss generally, without testifying about any specific
NOT A CERTIFIED COPY case or claim, his leadership role in coordinating the prosecution of all of the claims. (12/7/17 Tr. 6: 1-24.) DONE AND ORDERED in West Palm Beach, Palm Beach day of January, 2018. Copies provided to: Jack Scarola THEHONO CIRCUITCOU SERVICE LIST Nichole J. Segal Searcy, Denny, Scarola, Barnhart & Shipley, P.A. Burlington & Rockenbach, P.A. 2139 Palm Beach Lakes Boulevard Courthouse Commons, Suite 350 West Palm Beach, FL 33409 444 West Railroad A venue mep@searcvlaw.com West Palm Beach, FL 33401 isx@searcylaw.com njs@FLAppeliateLaw.com scarolateam@searcylaw.com kbt@FLAppellateLaw.com Co-Counsel for Defendant/Counter-Plaintiff Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards Bradley J. Edwards Bradley J. Edwards Marc S. Nurik Edwards Pottinger LLC Law Offices of Marc S. Nurik 425 N. Andrews Avenue, Suite 2 One E. Broward Boulevard, Suite 700 Ft. Lauderdale, FL 33301-3268 Ft. Lauderdale, FL 33301 brad@epllc.com marc@nuriklaw.com staff.efile@pathtojustice.com Counsel for Defendant Scott Rothstein Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards 2
NOT A CERTIFIED COPY Jack A. Goldberger Atterbury, Goldberger & Weiss, P.A. 250 Australian A venue S., Suite 1400 West Palm Beach, FL 33401 jgoldberger(@agwpa.com smahoney@agwpa.com Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein 3 Scott J. Link Kara Berard Rockenbach Angela M. Many Link & Rockenbach, PA 1555 Palm Beach Lakes Boulevard, Suite 30 I West Palm Beach, FL 33401 Scott@linkrocklaw.com Kara@linkrocklaw.com Angela(@linkrocklaw.com Tina@linkrocklaw.com Troy@linkrocklaw.com Tanya@linkrocklaw.com Eservice@linkrocklaw.com Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein
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Objects: Page, Text, Letter | Text: Filing # 71543277 E-Filed 05/02/2018 09:23:26 AM | IN THE CIRCUI
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Objects: Page, Text, Letter | Text: a five-day malicious prosecution trial and to identify the permi
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Objects: Handwriting, Text, Signature | Text: (SEAL | (Notary signature
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Objects: Handwriting, Text, Signature
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Objects: Home Decor, Text
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Objects: Text, Logo | Text: EXHIBIT D
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Objects: Page, Text | Text: 1 | 1 | IN THE CIRCUIT COURT OF THE | FIFTEENTH JUDICIAL CIRCUIT, IN | 2
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Objects: Page, Text | Text: IN THE CIRCUIT COURT OF THE | FIFTEENTH JUDICIAL CIRCUIT, IN | AND FOR P
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Objects: Page, Text | Text: 70 | 1 | Court is concerned the case that - s strike | that. | 2
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Objects: Page, Text, Letter | Text: Court is concerned the case that strike | that. | The question a
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Objects: Page, Text, Chart, Plot | Text: 71 | 1 | gatekeeper of evidence and to ensure to the | 2 |
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Objects: Page, Text | Text: gatekeeper of evidence and to ensure to the | !best of my ability that w
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Objects: Page, Text, Chart, Plot | Text: 72 | 1 | discovery as it relates to his testimonial | 2 | e
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Objects: Page, Text, Letter | Text: discovery as it relates to his testimonial | evidence that has a
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Objects: Page, Text | Text: 73 | 1 | Now, when it comes to issues of general | 2 | (graphic question
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Objects: Page, Text | Text: Now, when it comes to issues of general | graphic questioning, such as w
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Objects: Page, Text | Text: 96 | 1 | specifically on this aspect of the case, | 2 | because one of t
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Objects: Page, Text | Text: specifically on this aspect of the case, | because one of the things tha
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Objects: Page, Text | Text: 98 | 1 | with regard to other child molestations in | 2 | any child mole
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Objects: Page, Text | Text: with regard to other child molestations in | any child molestation claim
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Objects: Page, Text, Chart, Plot | Text: 99 | 1 | malicious prosecution claim. | 2 | And SO to devia
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Objects: Page, Text, Advertisement | Text: malicious prosecution claim. | And so to deviate from tha
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Objects: Page, Text | Text: 118 | 1 | publicize and to sensationalize the | 2 | circumstances so as
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Objects: Page, Text, Letter | Text: publicize and to sensationalize the | circumstances so as to inc
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Objects: Page, Text, Chart, Plot | Text: 119 | 1 | relates to the multiplicity of the numerous | 2 |
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Objects: Page, Text | Text: relates to the multiplicity of the numerous | victims that we are dealin
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Objects: Text | Text: EXHIBIT E
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Objects: Page, Text, Document, Invoice | Text: 1 | IN THE CIRCUIT COURT OF THE | FIFTEENTH JUDICIAL
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Objects: Page, Text, Letter | Text: IN THE CIRCUIT COURT OF THE | FIFTEENTH JUDICIAL CIRCUIT, IN | A
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Objects: Page, Text | Text: 5 | 1 | obviously, what) (may) or (may) (not) (be asked (of | Edwards (a
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Objects: Page, Text, Letter, Advertisement, Poster | Text: obviously, | what | (may) (or | (may) not
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Objects: Page, Text | Text: 6 | 1 | MR. SCAROLA: | Excuse me. | May I also
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Objects: Page, Text, Letter, Advertisement, Poster | Text: MR. SCAROLA: | Excuse me. | May I also |
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Objects: Text | Text: EXHIBIT F
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Objects: Page, Text, Letter | Text: IN THE CIRCUIT COURT OF THE | FIFTEENTH JUDICIAL CIRCUIT IN AND
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Objects: Page, Text | Text: case or claim, his leadership role in coordinating the prosecution of al
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Objects: Page, Text, Advertisement, Poster, Menu | Text: Jack Scarola | Nichole J. Segal | Searcy, D
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Objects: Page, Text | Text: Jack А. Goldberger | Scott J. Link | Atterbury, Goldberger & Weiss, P.A.
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Objects: Page, Text, Advertisement, Poster | Text: Jack A. Goldberger | Scott J. Link | Atterbury, G
- Abigail Wexner (p.33) 95%
- Abigail Wexner (p.59) 95%
- Actual Trial (p.8) 50%
- Adam Horowitz (p.24) 95%
- Adam Horowitz (p.26) 95%
- Adam Horowitz (p.27) 95%
- Adam Horowitz (p.28) 95%
- Adam Horowitz (p.29) 95%
- Adam Horowitz (p.30) 95%
- Adam Horowitz (p.36) 95%
- Adam Horowitz (p.39) 95%
- Adam Horowitz (p.40) 95%
- Adam Horowitz (p.52) 95%
- Adam Horowitz (p.53) 95%
- Adam Horowitz (p.54) 95%
- Adam Horowitz (p.55) 95%
- Adam Horowitz (p.56) 95%
- Adam Horowitz (p.57) 95%
- Adam Horowitz (p.61) 95%
- Adriana Mucinska (p.25) 95%
- ...and 679 more
- 101 Seminole Ave (p.35) address
- 101 Seminole Ave. (p.35) address
- 101 Seminole Avenue (p.56) address
- 10104 Forrest Hill Blvd. (p.38) address
- 1040 South Shore Drive (p.25) address
- 1040 South Shore Drive (p.53) address
- 11148 Cobblefield Dr. (p.36) address
- 1131 Pine Point Road (p.31) address
- 115 Sunshine Blvd (p.36) address
- 115 Sunshine Blvd (p.61) address
- 1150 Larch Way (p.36) address
- 1150 Larch Way (p.61) address
- 11675 Glowing Sunset Lane (p.32) address
- 119 Menores Ave. (p.37) address
- 12309 North Old Country Road (p.35) address
- 13285 Silver Fox Lane (p.33) address
- 13701 Riverside Drive (p.23) address
- 13701 Riverside Drive (p.49) address
- 1555 Palm Beach Lakes Boulevard (p.16) address
- 1555 Palm Beach Lakes Boulevard (p.42) address
- ...and 239 more
- File Path
- additional_files/1338.pdf
- File Size
- 1,664 KB
- Processed
- 2025-12-21 03:03
- Status
- completed
-
1417.pdf
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69 shared people 14 shared places -
1319.pdf
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68 shared people 13 shared places -
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64 shared people 16 shared places -
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64 shared people 16 shared places -
745.pdf
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38 shared people 14 shared places -
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40 shared people 10 shared places -
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37 shared people 12 shared places -
074.pdf
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29 shared people 8 shared places -
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28 shared people 9 shared places -
205.pdf
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28 shared people 8 shared places -
153.pdf
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27 shared people 8 shared places -
146.pdf
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27 shared people 8 shared places -
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20 shared people 9 shared places -
787-01.pdf
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17 shared people 6 shared places