EFTA00598330

IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT, IN 
AND FOR PALM BEACH COUNTY, 
FLORIDA 
CASE NO.: 502009CA040800XXXXMBAG 
JEFFREY EPSTEIN, 
Plaintiff/Counter-Defendant, 
JUDGE: 
DAVID CROW 
VS. 
SCOTT ROTHSTEIN, 
individually, BRADLEY J. 
EDWARDS, individually, 
Defendants/Counter-Plaintiff, 
MOTION IN 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 Counsel from making any mention of the 
below-listed matters. In support thereof, Epstein states: 
INTRODUCTION
This motion in limine seeks to prohibit any reference to evidence at trial by first 
having its inadmissibility determined outside the presence of the jury. Rosa v. Fla. Power 
& Light Co., 636 So. 2d 60, 61 (Fla. 2d DCA 1994). The purpose of this motion in limine 
is to prevent Edwards from offering improper evidence at trial, the mere mention of 
which would be prejudicial. Buy-Low Save Ctrs., Inc. v. Glinert, 547 So. 2d 1283, 1284 
(Fla. 4th DCA 1999); Dailey v. Multicon Dev., Inc., 417 So. 2d 1106, 1107 (Fla. 4th 
EFTA00598330

DCA 1982). Accordingly, a motion in limine is proper to exclude any irrelevant and 
immaterial evidence when its probative value is outweighed by prejudice. Devoe v. 
Western Auto Supply Co., 537 So. 2d 188, 189 (Fla. 2d DCA 1989). A motion in limine is 
especially appropriate to preclude inadmissible evidence that will be highly prejudicial to 
the moving party and, if referenced in a question or by counsel, would unlikely be 
disregarded by the jury despite an instruction by the court to do so. Fischman v. Suen, 
672 So. 2d 644, 645 (Fla. 4th DCA 1996). In the case at hand, Epstein requests that this 
Court enter an Order precluding any reference to the below-listed matters/items. 
A. 
All of the Exhibits listed below 
The items listed below appear on Edwards's Amended Trial Exhibit List. 
However, despite Epstein's request for same back in April, they were never turned over 
to Epstein. As such, Edwards should be precluded from utilizing or referencing them at 
trial. Given the sheer volume of the list (91 exhibits) of items that have not been turned 
over, it would be impossible for Epstein to review and evaluate same prior to trial; 
causing unfair prejudice. Escutia v. Greenleaf Products, Inc., 886 So. 2d 1059, 1062 (Fla. 
1st DCA 2004); Agrofollajes, S.A. v. E.I. DU Pont De Nemours & Co., Inc., Nos. 3D07-
2322, 3D07-2318, 3D07-1036, 2009 WL 4828975, at *16 (Fla. 3d DCA Dec. 16, 2009) 
(stating "Florida courts have explained that the rules of discovery are intended to avoid 
surprise and trial by ambush"). Sanction for failure to make discovery may be striking of 
pleadings, prohibition of introduction of evidence at trial, or refusal to permit 
presentation of claim or defense. Mitchem v. Grubbs, 485 So. 2d 891 (Fla. 1st DCA 
1986). 
Furthermore, these items are irrelevant to the case at hand pursuant to § 90.401 of 
EFTA00598331

the Florida Statutes, and to the extent that Edwards could argue that any are relevant, any 
alleged "probative value is substantially outweighed by the danger of unfair prejudice, 
confusion of issues, misleading the jury, or needless presentation of cumulative 
evidence." § 90.403 FLA. STAT. (2013); Dailey v. Multicon Development, Inc., 417 So.2d 
1106, 1107 (Fla. 4th DCA 1982). "'Unfair prejudice' has been described as 'an undue 
tendency to suggest decision on an improper basis, commonly, though not necessarily, an 
emotional one.' This rule of exclusion 'is directed at evidence which inflames the jury or 
appeals improperly to the jury's emotions."' Wright v. State, 19 So. 3d 277 (Fla. 2009). 
Here, the below-listed items undeniably have no bearing on Edwards's abuse of process 
or malicious prosecution claims. In fact, the repeated references to "victim" prove that. 
While it is clear from Edwards's Exhibit List that Edwards would like to re-litigate his 
previous cases against Epstein, these items undeniably are irrelevant and intended to do 
little more than unfairly inflame and prejudice the jury with irrelevant information 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 records 
12. 
phone records 
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. 
Victims' statements to the FBI related to criminal investigation of Jeffrey Epstein 
EFTA00598332

18. 
Video of Search Warrant of Jeffrey Epstein's home being executed 
19. 
Application for Search Warrant of Jeffrey Epstein's home 
27. 
Yearbooks of Jane Doe 
28. 
2002 Royal Palm Beach High School Year Book 
29. 
2001 Royal Palm Beach High School Year Book 
30. 
2003 Palm Beach Gardens High School Year Book 
31. 
Affidavit and Application for Search Warrant on Jeffrey Epstein's home 
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 
39. 
All statements made by Jeffrey Epstein 
40. 
List of properties and vehicles in Larry Visoski's name 
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 Victim 
57. 
Expert Dr. L. Dennison Reed's Report of Victim 
59. 
All reports and documentation generated by Palm Beach Police Department 
related to Jeffrey Epstein 
EFTA00598333

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 
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 search warrant 
71. 
Vibrators, dildos and other sex toys taken from Jeffrey Epstein's home during 
search warrant 
77. 
CAD calls to 358 El Brillo Way, Palm Beach FL 33480 
80. 
Letter from Chief Michael Reiter to Barry Krischler 
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 
EFTA00598334

92. 
Arrest Warrant of 
a
93. 
Police report regarding 
picking up money dated 11-28-04 
94. 
List of Trilateral Commission Members of 2003 
96. 
Guy Fronstin letter dated 4-17-06 
99. 
Jeffrey Epstein Polygraph Results 
100. 
Victim'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 
108. 
Reiter letter to Krisher dated 5-1-06 
110. 
Police Report dated 11-28-04 
111. 
Compulsory Medial Examination of victim, CMA 
112. 
Victim's school records and transcripts 
113. 
Victim Notification letter dated 7-9-08 
114. 
Victim's employment records from IHOP 
115. 
Police report of Juan Alessi theft at Jeffrey Epstein's home 
116. 
Victim's Medical Records from Milton Girls Juvenile Facility 
117. 
Victim's Medical Records from Dr. Randee Speciale 
118. 
Victim's Medical Records from Wellington Regional Hospital 
119. 
Victim's Medical Records from St. Mary's Medical Center 
120. 
Victim's Medical Records from United Health 
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121. 
All surveillance conducted by law enforcement on Jeffrey Epstein's home 
122. 
Emails 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 
127. 
All documents produced by Palm Beach Police Department prior to the deposition 
of Detective Recarey 
128. 
Photographs of all persons listed on Victims' Witness Lists 
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 
132. 
Curriculum vitae of Dr. Ryan 
133. 
My articles or publications of Dr. Ryan 
134. 
My articles or publications of Dr. Richard 
135. 
My 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 Victims 
138. 
All exhibits to Dr. L. Demlison Reed's Deposition 
139. 
All exhibits to Dr. Richard 
Deposition 
140. 
All items and documents reviewed by Dr. Richard IM 
141. 
All items and documents reviewed by Dr. Ryan 
142. 
Demonstrative aids and exhibits including, but not limited to, anatomical charts, 
diagrams and models, surveys, photographs and similar material including blow-ups of 
the foresaid items.-
143. 
My and all mortality tables 
EFTA00598336

B. 
Any argument, statement, evidence, or comment related to the criminal 
charges to which Epstein plead or any alleged investigation(s). 
Since it is irrelevant and immaterial to this suit, Epstein requests that Edwards be 
precluded from using any pleading, testimony, remarks, questions, documents, exhibits, 
items, investigation results, or arguments related to any criminal investigations or charges 
as related to Epstein that might inform the jury of such facts and that Edwards further 
instruct his witnesses to omit such facts from their testimony. This is improper for trial 
as it is impermissibly being offered as "relevant solely to prove bad character" and would 
unduly inflame and prejudice the minds of the jury against Epstein. § 90.404(2) (a) FLA. 
STAT. (2013). "'Unfair prejudice' has been described as 'an undue tendency to suggest 
decision on an improper basis, commonly, though not necessarily, an emotional one.' 
This rule of exclusion `is directed at evidence which inflames the jury or appeals 
improperly to the jury's emotions."' Wright v. State, 19 So. 3d 277 (Fla. 2009); Byrd v. 
BT Foods, Inc., 26 So. 2d 600 (Fla. 4th DCA 2009). See also Canales v. Compania De 
Vapores Realma, S.A., 564 So. 2d 1212 (Fla. 3d DCA 1990) (Any probative value of 
testimony about marriage proposal plaintiff purportedly made offering money to woman 
to many him so that he could avoid deportation, on issue of plaintiffs credibility, was far 
outweighed by its prejudicial effect); DeSantis v. Acevedo, 528 So. 2d 461 (Fla. 3d DCA 
1988) (Probative value of the defendant's cross-examination of the plaintiff and his main 
witness about prior unrelated incidents that insinuated that both the plaintiff and the 
witness had been dishonest was outweighed by prejudicial nature of questions.). This is 
an abuse of process and malicious prosecution case that Edwards is prosecuting against 
EFTA00598337

Epstein. This information has no probative value whatsoever to the elements necessary 
to prove either claim, or Epstein's defense. 
C. 
Any reference to Epstein's Assertion of his Fifth Amendment Privilege to 
questions that are not directly related to the issues in this case. 
Epstein asserted his Fifth Amendment Privilege in response to discovery in this 
matter when the requested information concerned allegations of sexual exploitation of 
minors. Said allegations are undeniably irrelevant to the case at hand pursuant to § 
90.401 of the Florida Statutes, and to the extent that Edwards could possibly try to 
establish that this line of discovery is relevant, any alleged "probative value is 
substantially outweighed by the danger of unfair prejudice, confusion of issues, 
misleading the jury, or needless presentation of cumulative evidence." § 90.403 FLA. 
STAT. (2013); Dailey v. Multicon Development, Inc., 417 So.2d 1106, 1107 (Fla. 4th 
DCA 1982). "'Unfair prejudice' has been described as 'an undue tendency to suggest 
decision on an improper basis, commonly, though not necessarily, an emotional one.' 
This rule of exclusion 'is directed at evidence which inflames the jury or appeals 
improperly to the jury's emotions."' Wright v. State, 19 So. 3d 277 (Fla. 2009); Byrd v. 
BT Foods, Inc., 26 So. 2d 600 (Fla. 4th DCA 2009). Were any of the above facts made 
known to the jury, it would be highly improper and prejudicial to Epstein. Moreover, this 
evidence is being offered, impermissibly, as "solely to prove bad character." 
D. 
The use of any derogating adjectives when referencing Epstein. 
Edwards has continually referenced Epstein by the use of provoking and offensive 
misnomers, such as "billionaire pedophile" or "convicted child molester." 
Such 
commentary is inappropriate, and if Edwards did so at trial it would irrefutably be done 
EFTA00598338

solely to impermissibly "inflame[] the jury or appeal[] improperly to the jury's 
emotions."' Wright v. State, 19 So. 3d 277 (Fla. 2009). 
E. 
Any reference to any and all cases against Epstein in which Edwards was not 
counsel of record. 
While a limited amount of the information regarding Edwards's prosecution of 
cases against Epstein is germane to the issues in this case, any mention of or use of 
information from any other case is not. 
Such information is unfairly prejudicial. 
Honeywell Intern., Inc. v. Guilder, 23 So. 3d 867 (Fla. 3d DCA 2009). As seen from 
Edwards's trial exhibit list items above, it is apparent that he intends to use as much 
information from other cases as possible. This evidence is undeniably irrelevant to this 
cause of action and is solely being used in an effort to impermissibly "inflame[] the jury 
or appeal[] improperly to the jury's emotions," or "solely to prove bad character." 
Wright v. State, 19 So. 3d 277 (Fla. 2009); Byrd v. BT Foods, Inc., 26 So. 2d 600 (Fla. 
4th DCA 2009). "(I)f the introduction of the evidence tends in actual operation to 
produce a confusion in the minds of the jurors in excess of the legitimate probative effect 
of such evidence if it tends to obscure rather than illuminate the true issue before the jury 
then such evidence should be excluded." City of Miami v. Calandro, 376 So. 2d 271, 272 
(Fla. 3d DCA 1979) (citing Perper v. Edell, 44 So. 2d 78 (Fla. 1949)). 
See also 
Agrofollajes, S.A. v. E.I. Du Pont De Nemoum & Co., Inc., 48 So. 3d 976 (Fla. 3d DCA 
2010) (probative value outweighed by prejudicial effect when evidence improperly 
becomes focus of trial); Maldonado v. Allstate Ins. Co., 789 So. 2d 464 (Fla. 2d DCA 
2001) (probative value of bicyclist's status as an illegal alien was outweighed by unfair 
prejudice, confusion of the issues, and misleading of the jury, as the evidence and 
EFTA00598339

instruction concerning status as an illegal alien improperly changed the focus of the 
jury's attention). 
WE HEREBY CERTIFY that a true and correct copy of the foregoing was served, 
via electronic service, to all parties on the attached service list, this September 27, 2013. 
Is/ Tonja Haddad Coleman 
Tonja Haddad Coleman, Esq. 
Florida Bar No.: 176737 
Ton'a Haddad, PA 
(facsimile) 
Attorneys for Epstein 
EFTA00598340

SERVICE LIST 
CASE NO. 502009CA040800XXXXMBAG 
Jack Scarola, Es . 
Searcy Denney Scarola et al. 
Jack Goldber er Es . 
Atterbury, Goldberger, & Weiss, PA 
Marc Nurik, Esq. 
Brac
lwards, E
. 
Farmer Jaffe Weissing Edwards Fistos Lehrman 
Fred Haddad, Es 
Tonja Haddad Coleman, Esquire 
Law Offices of Tonja Haddad, P.A. 
EFTA00598341