Epstein Secrets

dant, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff, JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S OMNIBUS MOTION IN LIMINE Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel, herein moves for an Orde

er-Plaintiff, JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S OMNIBUS MOTION IN LIMINE Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel, herein moves for an Order in Limine precluding Defendant/Counter-Plaintiff Bradley Edwards ("Edwards") a

OUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, vs. Plaintiff/Counter-Defendant, SCOT

laintiff has no evidence, nor can he prove, that Mr. Epstein lacked probable cause at the time he filed his l

his litigation. See Deposition Transcript of Jef•ey Epstein. When Edwards's inquiry turned to questions rega

umbered on Edwards's Trial Exhibit List). 65. MC2 emails involving communications of Jeffrey Epstein, Jeff Puller 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 fro

ior to 2003, I don't know if Jeffrey Epstein ever gave him money. I know that from the longest Jean-Luc was living in an apartment that belongs to Jeffrey Epstein Q. What apartment is that? A. It's in New York. I don't know the address. Q. Is that at 301 East 66th Street? A. Yeah, something like that. I th

A. I don't know her name. But he was with -- with a woman. I don't know. Q. And what is your understanding or what was your understanding that Jeffrey -- in terms of Jeffrey Epstein's involvement with MC Squared? A. Jean-Luc always said that Jeffrey was his friend, that he is a millionaire. And

rey U.S. Legal Support (305) 373-8404 EFTA00181303 8 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 Epstein owns or controls numerous apartments in that -- at that same address; is that right? A. Yes. Yes. Q. And have you ever been to that address? A.

all some things, not all the time. I recall that Mr. Epstein didn't want to sign the papers, but Mellon Bank

n Europe? Q. Yes, or here. A. No, that was related to Q• No, Who works in the MC Squared office here? A. Here, I knew other things, because Amanda Grant and -- I gave you her name more than one time. Amanda was working with them until 2008. And she got a lot of information. And she U.S. Legal Suppo

AO 187 (Rev. 7/87) Wimess List United States District Court SOUTHERN DISTRICT OF FLORIDA JANE DOE, Plaintiff, Vs. JEFFREY EPSTEIN, et al. Defendant. Related Cases: 08-80119,08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 0

Grant 19. Amy Birse 20. i 21. 22. Antonio Figueroa, 23. 24. 25. 26. 27. EFTA00725732 pLAINTIFF DOE. WITNESS LIST CONTINUATION Dos vs. Epstein — CASE NO. 08-CV-80893-CN-PAARRNJOHNSON DEF. NO. PLF. NO. DATE MARKED OFFERED ADMITTED DESCRIPTION OF WITNESSES 28. 29. 30. 31. 32. 33

DISTRICT OF FLORIDA JANE DOE, Plaintiff, Vs. JEFFREY EPSTEIN, et al. Defendant. Related Cases: 08-8

Detective Jose . h Rec Palm Beach Police 14. Chief Michael Ritter Palm Beach Police, 15. Records Custodian of Palm Beach Police, 16. 17. 18. Amanda Grant 19. Amy Birse 20. i 21. 22. Antonio Figueroa, 23. 24. 25. 26. 27. EFTA00725732 pLAINTIFF DOE. WITNESS LIST CONTINUATION Dos vs. Epstein

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 OF

laves 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 mes

N DISTRICT OF FLORIDA JANE DOE, Plaintiff Vs. JEFFREY EPSTEIN, ct al. Defendant. Related Cases: CASE

ein'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 Jef

nformation from Epstein's criminal case and prior civil cases; not one of which is an abuse of process or malicious prosecution case. 4. Video of Jeffrey Epstein's home and route from victim to Epstein's home 9. Documents related to Jeffrey Epstein produced by Alfredo Rodriguez 11. Jeffrey Epstein phone reco

N LIMINE TO PRECLUDE AT TRIAL THE USE OF THE FOLLOWING ITEMS LISTED ON EDWARDS'S REVISED EXHIBIT LIST Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel moves for an Order in Limine precluding Defendant/Counter- Plaintiff Bradley Edwards ("Edwards") and his C

UNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, JUDGE: D

Pinto regarding house island project 65. MC2 emails involving communications of Jeffrey Epstein, Jeff Puller- _, Pappas Suat, Jean Luc Brunel and Amanda Grant 68. Massage Table 69. Lotions taken from Jeffrey Epstein's home during search warrant 70. Computers taken from Jeffrey Epstein's home during sear