EFTA00655529.pdf

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JUDGE: CROW Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S LIST OF TRIAL EXHIBITS, TRIAL WITNESSES AND EXPERT WITNESSES PURSUANT TO THE COURT'S ORDER DATED APRIL 2, 2013 Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") hereby files his list of trial exhibits, trial witnesses, and expert witnesses pursuant to this Court's Order Setting Jury Trial and Directing Pretrial and Mediation Procedures dated April 2, 2013 as follows: TRIAL EXHIBITS I. Information Charging Scott W. Rothstein in United States of America v. Stott W. Rothstein, 09-60331-CR-COHN; dated December 1, 2009. EFTA00655529 2. Plea Agreement between United States of America and Scott W. Rothstein, 09-60331-CR-COHN; filed December 1, 2009. 3. Amended Complaint in Razorback Funding, LLC, ET AL v. Scott W. Rothstein, et al., in the Circuit Court of the Seventeenth Judicial Circuit, in and for Broward County, Florida, Case No. 09-062943 (19); Lawsuit filed November 20, 2009. 4. All Videotaped Depositions taken of Scott W. Rothstein in In re: Rothstein Rosenfeldt Adler, PA; 09-34791-RBR. 5. All exhibits as referenced/used in the Deposition of Scott W. Rothstein taken by Epstein on June 14, 2012. 6. Privilege Log of Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, Dated February 23, 2011 as filed in this matter and in In re: Rothstein Rosenfeldt Adler, M.; 09-34791-RBR. 7. Docket from Doe v. United States, 08-80736-CIV-MARRA. 8. Any and all exhibits listed by Edwards. 9. Videotaped Deposition of Bradley J. Edwards, including all exhibits used/referenced therein, which was taken by Epstein on May 15, 2013. [QUESTION - WOULD THIS INCLUDE THE FEDERAL LM COMPLAINT. IF NOT WE SHOULD MENTION THE LM COMPLAINT) 10. All documents provided to date by Bradley J. Edwards in response to Jeffrey Epstein's Second Request for Production served on December 9, 2011 (the only discovery, to date, to which Edwards has actually responded as far as we know, as everything else seems to be objections). JAS I RECALL DIDN'T EDWARDS PROVIDE TWO SETS OF DISCOVERY - ONE SET WAS THE DOCUMENTS CONSTITUTING EMAILS WITH HIM AND MEMBERS OF THE PRESS AND THE OTHER SET WAS HIS "DAMAGES DOCUMENTS1 II. Transcripts of all depositions taken in this cause and exhibits marked at said depositions. 12. Edwards's answers to interrogatories and response to requests for production, and response to requests for admissions. The Defendants reserve the right to produce any newly discovered evidence upon proper notice. 2 EFTA00655530 The Defendants reserve the right to produce any exhibits used for impeachment or rebuttal. The Defendants reserve the right to amend and/or supplement this Exhibit List as information becomes available upon proper notice. All exhibits expected to be offered at trial by the Defendants, except those used for impeachment, will be made available for inspection at the offices of the undersigned at a mutually convenient time and date. TRIAL WITNESSES (WE HAVE TO PROVIDE ADDRESSES FOR ALL) JDQ WE HAVE TO PROVIDE THE ADDRESSES NOW OR CAN WE SAY ADDRESSES TO BE PROVIDED?[ I. Scott W. Rothstein 2. Ken Jenne 3. William Scherer The following people are listed in the privilege log unless otherwise noted: 4. Spencer Kuvin 5. Katherine Ezell 6. Ami Eden 7. Kikka Claudio 8. Paul Cassell 9. Margaret Berk 10. Mercedes Estrada 11. Jacquie Johnson 12. Adam Horowitz 13. Stuart Mermelstein 14. Lisa Rivera 3 EFTA00655531 15. Jack Kill 16. Carolyn Edwards 17. Robert Josefberg 18. Richard Willits 19. William J. Berger 20. Bert Patton 21. Susan K. Stirling 22. !liana Yarzabal 23. Barry Stone 24. Alan Garten 25. Elizabeth Kim 26. Christina Fitch 27. Gary Farmer 28. Denis Kleinfeld 29. "Investigators" (from privilege log???) THIS IN THIS ROUND?) 30. Carl Linder 31. Cara Holmes 32. Jonathan Birkman 33. Robert C. Buschel 34. Beth Williamson 35. Mike Fisten 36. Susan K. Stirling [DO YOU NEED TO INCLUDE 4 EFTA00655532 37. Robin T. Kempner 38. Pat Roberts 39. Amy Swan 40. Pat Diaz 41. Jeffrey Sonn (Fort Lauderdale Attorney- NOT IN PRIVILEGE LOG) [WHERE DID THIS NAME COME FROM?1 42. Tami Wolfe 43. Steven Jaffee 44. Marc Nurik 45. Nora Batian 46. Priscilla Nascimento (Reserving conference rooms for 7/23/09 re: Epstein) WHY IS THIS IN BOLD FACE. SHE DID RESERVE THE ROOMS ACCORDING TO THE PRIVILEGE LOG?1 47. Maribel Matiska 48. Michael Wheeler 49. Bradley Berger 50. Shawn Gilbert 51. Ronald Wise 52. Wayne Black 53. Susan Stirling 54. Kendall Coffey 55. Seth Lehrman 56. Phaedra Xanthos 5 EFTA00655533 57. Scott Goldstein 58. Alfredo (?) [THIS IS ALFREDO RODRIGUEZ. THE GUY WHO TRIED TO SELL THE "HOLY GRAIL" TO EDWARDS'S TEAMI 59. Earleen Cote 60. Josh Roberts 61. Carolyn, Legal Assistant to Jay Howell, Co-Counsel 62. Jay Howell (?) [WHAT ARE YOU ASKING HERE? WHETHER WE SHOULD INCLUDE HIM? IF SO ASK JE SPECIFICALLY] 63. Jack Scarola (communications between Scarola and Edwards as noted (Bates 04355-04358) in Privilege Log Dated February 23, 2011 — Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman). TASK JE IN EMAIL 64. Alan Sakowitiz LOG) [ASK JE IN EMAIL1 (Investor/Whistleblower to FBI- NOT IN PRIVILEGE 65. A. J. Discala (NOT IN PRIVILEGE LOG) [JE ALREADY SAID INCLUDE HIM AS A WITNESS] MICHAEL LEGAMARO - I BELIEVE HE IS THE ATTORNEY FROM MORGAN LEWIS WHO LOOKED AT THE EPSTEIN CASE FILES IN ROTHSTEIN'S OFFICE 66. Other Investors??? Do we have names? [DON'T NEED THIS NOW DO WE? LOOK AT DISCALA'S DEPO. HE SAYS THAT THANE RITCHIE AND DEAN KRETSCHMAR WERE AT THE MEETING AT RRA WHERE ROTHSTEIN SHOWED THEM THE EPSTEIN FILES.1 67. Any and all witnesses listed by Bradley J. Edwards. 68. Any and all witnesses whose names appear in depositions, interrogatories, or requests for production provided by Bradley J. Edwards. 69. Epstein reserves the right to list and/or call any and all newly discovered witnesses upon proper notice. 70. Epstein reserves the right to call and/or produce any and all witnesses necessary for impeachment or rebuttal. EFTA00655534 71. Epstein reserves the right to amend and/or supplement this Witness List upon proper notice to the Parties and this Court. EXPERT WITNESSES 1. Unknown at this time. WE HEREBY CERTIFY that a true and correct copy of the foregoing was served upon all parties listed below, via Electronic Service, this June 20, 2013. /s/ Tonia Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 TONJA HADDAD, PA 315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 954.337.3716 (facsimile) 7 EFTA00655535 Electronic Service List Jack Scarola, Esq. Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldberger, Esq. Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esq. 1 East Broward Blvd. Suite 700 Fort Lauderdale, FL 33301 Bradley J. Edwards, Esq. Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Avenue Suite 2 Fort Lauderdale, Florida 33301 Fred Haddad, Esq. 1 Financial Plaza Suite 2612 Fort Lauderdale, FL 33301 EFTA00655536 Lo EFTA00655537