EFTA00728817.pdf

AO 187 (Rev. 7/87) Witness List United States District Court SOUTHERN DISTRICT OF FLORIDA JANE DOE, Plaintiff Vs. JEFFREY EPSTEIN, ct al. Defendant. Related Cases: CASE NUMBER: 08-CV-80893-CIV MARRA/JOHNSON PLAINTIFF JANE DOE'S EXHIBIT LIST 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 PRESIDING JUDGE Hon. Judge Marra PLAINTIFFS ATTORNEY Bradley J. Edwards, Esq. DEFENDANTS' ATTORNEY Robert Craton, Esq. TRIAL DATE(S) July 19 — July 30, 2010 COURT REPORTER COURTROOM DEPUTY DEF. NO. PLF. NO. DATE OFFERED MARKED ADMITTED DESCRIPTION OF EXHIBITS EXHIBITS EXPECTED TO BE USED I. All applicable criminal statutes 2. All applicable Florida Statutes 3. All applicable Rules of Evidence 4. Video of Defendant, Jeffrey Epstein's home and route from Plaintiff to Defendant's home 5. Order confirmation from Amazon.com for purchase of books "SM 101: A Realistic Introduction," "Slave Craft: Roadmap for Erotic Servitude-Principles. Skills and Tools" and "Training Miss Abernathy: A Workbook for Erotic Slaves and Their Owners" 6. Non-Prosecution Agreement 7. Jane Doe 102 Complaint EFTA00728817 PLAINTIFF DOE. EXHIBIT LIST CONTINUATION Dos vs. Epstein - CASE NO. 08-CV-501393•CIV-MARRAMOHNSON DEF. NO. PLF. NO. DATE OFFERED MARKED ADMITTED DESCRIPTION OF EXHIBITS 8. Messages taken from message pads found at Defendant's home 9 Documents related to Jeffrey Epstein produced by Alfredo Rodriguez 10. Jeffrey Epstein flight logs 11. Jeffrey Epstein phone records 12. phone records 13. Jail Visitation Logs 14. Jeffrey Epstein's probation file 15. All probable cause affidavits related to criminal investigation of Jeffrey Epstein 16 All evidence, information and documents taken or possessed by FBI related to criminal investigation of Jeffrey Epstein 17. Plaintiffs and other victims' statements to the FBI related to criminal investigation of Jeffrey Epstein 18. Video of Search Warrant of Jeffrey Epstein's home being executed 19. Application for Search Warrant of Jeffrey Epstein's home 20. Complaint Jane Doe v. Epstein and all subsequent Amended Complaints 21 All records of homes, properties, bank accounts and any and all records related to Jeffrey Epstein's assets 22. Jeffrey Epstein's passport (or copy) 23. Jeffrey Epstein's driver's license (or copy) 24. List of corporations owned by Jeffrey Epstein 25 All documents evidencing relationship between Jeffrey Epstein and Jean Luc Brunel 26 All documents evidencing relationship between Jeffrey Epstein and MC2 or any modeling agencies 27. Yearbooks of plaintiff, Jane Doe 28. 29. 30. 31. Affidavit and Application for Search Warrant on Jeffrey Epstein's home EFTA00728818 PLAINTIFF DOE. EXHIBIT LIST CONTINUATION Do* vs. Epstein —CASE NO. 08-CV-10393-CIV-MARRAUOHNSON DEF. NO. PLF. NO. DATE OFFERED MARKED ADMITTED DESCRIPTION OF EXHIBITS 32 Tape recording or transcript of recording of conversation between Jeffrey Epstein and George Rush 33. Notepads found in Jeffrey Epstein's home and/or during trash pulls outside of his home during criminal investigation 34. The Palm Beach State Attorney's Criminal file against Jeffrey Epstein 35. All documents related to Jeffrey Epstein's 6/30/08 conviction 36. Jeffrey Epstein's criminal plea colloquy 37. Public records from the Department of Corrections related to Jeffrey Epstein 38 Records from the Florida Department of Law Enforcement related to Jeffrey Epstein 39. All statements made by Jeffrey Epstein 40. List of properties and vehicles in Larry Visoski's name 41 All of Jeffrey Epstein's Responses to Requests for Production, Requests for Admission, Answers to Interrogatories in this matter, and cases 08-80119, 08-80232, 08-80380, 08-80381, 08- 80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09- 80802, 09-81092 42 All discovery related responses of Jeffrey Epstein in this matter and cases 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469. 09-80591, 09-80656, 09.80802, 0941092 43. Jeffrey Epstein's Answers and Affirmative Defenses in all civil cases against him 44. All Complaints in which Jeffrey Epstein was a plaintiff or defendant 45. Jeffrey Epstein's Deposition testimony and discovery responses in this case and cases 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 46. Jeffrey Epstein's Deposit. imony and discovery responses in State Court cases v. Jeffr pstein, Case No. 502008CA028051 and v. Jeffrey Epstein, Case No. 502008CP003626XXXXMB 47 Jeffrey Epstein Deposition Testimony and discovery responses in State Court case Jeffrey Epstein v. Scott Rothstein, et al. Case No. 502009CA040800)000CMBAG 48 Any and all newspaper articles, online articles or publications related to Jeffrey Epstein 49. Report and Analysis of Jeffrey Epstein's assets EFTA00728819 PLAINTIFF DOE, EXHIBIT LIST CONTINUATION Doe vs Epstein - CASE NO. 08-CV-110893-CIV-MARRA/JOHNSON DEF. NO. PI,. NO. DATE OFFERED MARKED ADMITTED DESCRIPTION OF EXHIBITS 50. Video footage (DVD) of walk through site inspection of Jeffrey Epstein's home. 51. Photos of all of Jeffrey Epstein's properties, cars, boats and planes 52. Probable Cause Affidavits prepared against Jeffrey Epstein and 53. Audio tape of 54. Photographs, videos and books taken in the search warrant of Jeffrey Epstein's home 55. Documents related to or evidencing Jeffrey Epstein's donations to law enforcement 56. Victim Notification Letter from US Attorney's Office to Plaintiff 57. Expert Dr. L. Dennison Reed's Report of Plaintiff 58. Palm Beach Police Department Incident Report dated 4/20/06 59 All reports and documentation generated by Palm Beach Police Department related to Jeffrey Epstein 60. All Witness Statements generated by Palm Beach Police Department relating to Jeffrey Epstein 61. Passenger Manifests of Jeffrey Epstein's aircraft and private plane flight logs 62 Passenger lists for flights taken by Jeffrey Epstein 63. Letter from Jeffrey Epstein to Alberto Pinto regarding house island project 64. Jeffrey Epstein's bank statements Jeffrey Epstein's tax returns 65. Fuller, mmunications of Jeffrey Epstein, Jeff MC2 all Pappas Suat, Jean Luc Brunel and Amanda Grant 66. DVD of plea and colloquy taken on 6-30-08 67. Transcript of plea and colloquy taken on 6.30-08 68. Massage Table 69. Lotions taken from Jeffrey Epstein's home during search warrant 70 Computers taken from Jeffrey Epstein's home during search warrant 71. Vibrators, dildos and other sex toys taken from Jeffrey Epstein's home during search warrant EFTA00728820 PLAINTIFF DOE. EXHIBIT UST CONTINUATION Do* vs. Epstsln - CASE NO. 08-CV-80893-CIVAIARFLA/JOHNSON DEE. NO. PLF. NO. DATE OFFERED MARKED ADMTITED DESCRIPTION OF EXHIBITS 72. No Contact Orders entered against Jeffrey Epstein 73. Criminal Score Sheet regarding Jeffrey Epstein 74. Documents evidencing Jeffrey Epstein's Community Control and Probation 75. Jeffrey Epstein's Sex Offender Registration 76. Jeffrey Epstein's Booking photograph 77. CAD calls to 358 EL BRILLO WAY, PALM BEACH FL 33480 78. List of Jeffrey Epstein's House contacts 79 Documents related to Jeffrey Epstein's investments 80. Letter from Chief Michael Reiter to Barry Krischler 81 List of planes owned by Jeffrey Epstein 82. Letter from Guy Fronstin to Assistant State Attorney dated 1-11- 06 83. Letter from Guy Fronstin to Assistant State Attorney dated 1-13- 06 84. Letter from Guy Fronstin to Assistant State Attorney dated 2-17- 06 85. Letter from Guy Fronstin to Assistant State Attorney dated 4-6- 06 86. Letter from Guy Fronstin to Assistant State Attorney dated 4-10- 06 87. Letter from Goldberger dated 6-22-06 88. All subpoenas issued to State Grand Jury 89 Documents related to the rental of a vehicle for 90 Ted's Sheds Documents 91. Documents related to property searches of Jeffrey Epstein's properties 92. Arrest Warrant of 93 Police report regarding picking up money dated 11-28-04 94. List of Trilateral Commission Members of 2003 95. Alan Dershowitz Letter dated 4.19-06 and Statute 90.410 EFTA00728821 PLAINTIFF 00E, EXHIBIT LIST CONTINUATION D0 vs. EpaWin — CASE NO. 08-CV480893-C1V-MARRA/JOHNSON DEF. NO. PLF. NO. DATE OFFERED MARKED ADMITTED DESCRIPTION OF EXHIBITS 96. Guy Fronstin letter dated 4-17-06 97 Jeffrey Epstein Account Information 98. Jeffrey Epstein Criminal Closeout Sheet 99. Jeffrey Epstein Polygraph Test and Results 100. Plaintiff's GED testing information and results 101. JEGE, Inc. Passenger Manifest 102. Hyperion Air Passenger Manifest 103. Flight information for 104. Passenger List Palm Beach flights 2005 105. Jeffrey Epstein notepad notes 106. Pleadings of Jane Doe 1 and 2 v. US case 107. Jeffrey Epstein 5th Amendment Speech 108. Reiter letter to Krisher dated 5-1-06 109. Jail receipts of Jeffrey Epstein 110. Police Report dated 11-28-04 111. Compulsory Medial Examination of victim, 112. Plaintiff's school records and transcripts 113. Victim Notification letter dated 7-9-08 114. Plaintiff's employment records from IHOP 115. Police report of.luan Alessi theft at Jeffrey Epstein's home 116. Plaintiff's Medical Records from Juvenile Facility 117. Plaintiff's Medical Records from 118. Plaintiff's Medical Records from Wellington Regional Hospital 119. Plaintiffs Medical Records from St. Mary's Medical Center EFTA00728822 PLAINTIFF DOE. EXHIBIT LIST CONTINUATION Dos vs Epstein — CASE NO. 08-CV-110893-CIV-MARRA/JOHNSON DEF. NO. PLF. NO. DATE OFFERED MARKED AumurrED DESCRIPTION OF EXHIBITS 120. Plaintiff's Medical Records from United Health 121. All surveillance conducted by law enforcement on Jeffrey Epstein's home 122 Entails received from Palm Beach Records related to Jeffrey Epstein 123. All items listed on the Palm Beach Police Property Report Lists 124 All items taken in the execution of the search warrant of Jeffrey Epstein's home: 358 EL BRILLO WAY, PALM BEACH FL 33480 125. All copies of convictions related to Jeffrey Epstein 126. Jeffrey Epstein criminal records 127 All documents produced by Palm Beach Police Department prior to the deposition of Detective Recarey 128. Photographs of all persons listed on Plaintiff's Witness List 129 Statements, deposition transcripts, videotaped depositions and transcripts taken in connection with this and all related cases and exhibits thereto 130. Any and all expert witness reports and/or records generated in preparation for this litigation by any party to this cause 131. Curriculum vitaes of any and all listed experts 132. Curriculum vitae of Dr. Ryan Hall 133. Any articles or publications of Dr. Ryan Hall 134. Any articles or publications of Dr. Richard Hall 135. Any articles or publications of Dr. L. Dennison Reed 136. All items and documentation review by Dr. L. Dennison Reed 137 Transcript and video (DVD) of IME of Plaintiff 138. All exhibits to Dr. L. Dennison Reed's Deposition 139. All exhibits to Dr. Richard Hall's Deposition 140. All items and documents reviewed by Dr. Richard Hall 141. All items and documents reviewed by Dr. Ryan Hall 142. All exhibits listed on the Defendant's Exhibit List EFTA00728823 PLAINTIFF DOE. EXHIBIT LIST CONTINUATION Doe vs Epstein — CASE NO. 08-CV-80893-ClIbMARRA/JOHNSON DEF. NO. PLF. NO. DATE OFFERED MARKED ADMITTED DESCRIPTION OF EXHIBITS 143. Demonstrative aids and exhibits including, but not limited to, anatomical charts, diagrams and models, surveys, photographs and similar material including blow-ups of the aforesaid items. 144. Any and all mortality tables 145. Plaintiffs reserve all objections to Defendant's Exhibits 146. Plaintiffs reserve the right to supplement and/or amend this Exhibit List 147 By listing an Exhibit, Plaintiff is not waiving their right to object to same at trial and does not waive their right to amend same. Plaintiff reserves the right to amend this list. CERTIFICATE OF SERVICE I HEREBY CERTIFY that the original of the above and a copy of the foregoing has been provided this '$ day of June 2010 via U.S. Mail and email transmittal to all those on the attached service Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075 E-mail: and Paul G. Cassell Pro Hac Vice 332 S. 1400 E. Salt Lake City, UT 84112 Telephone: 801-585-5202 Facsimile: 801-585-6833 E-Mail: EFTA00728824