Epstein Secrets

on » is not >a >> secure mode of communication and may be accessed by unauthorized persons. >> This communication originates from the law firm of Searcy Denney >> Scarola Barnhart & Shipley, P.A. and is protected under the >> Electronic > Communication >> Privacy Act, 18 U.S.C. S2510-2521. The informatio

Case 9:08-cv-80736-KAM Document 177-1 Entered on FLSD Docket 06/06/2012 Page 1 of 22 Tonja Haddad Coleman From: Sent: To: Subject: Thank you. Jack Scarola Tuesday, May 08, 2012 3:41 PM Re: Epstein discovery On May 8, 2012. at 3:27 PM. "Tonja Hadd

y, May 08, 2012 3:41 PM Re: Epstein discovery On May 8, 2012. at 3:27 PM. "Tonja Haddad Coleman" MINIMI > > Fine. > Tonja Haddad Coleman. Esq. > Tonja Haddad, P.A. > Justice Building > Fort Lauderdale. Florida 33301 > www.tonjahaddadpa.com > The information contained in this transmission may contain pr

ad Coleman From: Sent: To: Subject: Thank you. Jack Scarola Tuesday, May 08, 2012 3:41 PM Re: Epstein discovery On May 8, 2012. at 3:27 PM. "Tonja Haddad Coleman" MINIMI > > Fine. > Tonja Haddad Coleman. Esq. > Tonja Haddad, P.A. > Justice Building > Fort Lauderdale. Florida 33301 > www.tonjahaddadpa.com

asonably calculated to lead to the discovery of admissible evidence and protected by the work-product privilege. 23. The written fee agreement with Searcy Denney firm for their representation of you in this case. ANSWER: Objection. Edwards objects to the above-cited Requests to Produce on the purported gro

responded to, but this Motion deals exclusively with those delineated above. The other outstanding discovery is addressed in a separate Motion. 2 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00799382 Florida Law permits litigants ample latitude in discovery. Rule 1.280 of the Flor

igation, travel expenses, deposition related costs, expert costs, etc.) that were incurred by RRA in its representation of Jane Doe, M. and E.W. 5 Tonja Haddad, P.A. • 315 SE 7" Street, Fort Lauderdale, FL 33301• EFTA00799385 during the time you were employed by RRA (or that is being claimed by the trust

f the foregoing was served, via electronic service, to all parties on the attached service list, this September 25, 2017. /s/ Tonia Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 19 Tonja Haddad, P.A. • 315 SE 7'h

asonably calculated to lead to the discovery of admissible evidence and protected by the work-product privilege. 23. The written fee agreement with Searcy Denney firm for their representation of you in this case. ANSWER: Objection. Edwards objects to the above-cited Requests to Produce on the purported gro

responded to, but this Motion deals exclusively with those delineated above. The other outstanding discovery is addressed in a separate Motion. 2 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00585353 Florida Law permits litigants ample latitude in discovery. Rule 1.280 of the Flor

ation, travel expenses, deposition related costs, expert costs, etc.) that were incurred by RRA in its representation of Jane Doe, L.M. and E.W. 5 Tonja Haddad, P.A. • 315 SE 7" Street, Fort Lauderdale, FL 33301 EFTA00585356 during the time you were employed by RRA (or that is being claimed by the truste

f the foregoing was served, via electronic service, to all parties on the attached service list, this September 25, 2017. /s/ Tonia Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 19 Tonja Haddad, P.A. • 315 SE 7'h

asonably calculated to lead to the discovery of admissible evidence and protected by the work-product privilege. 23. The written fee agreement with Searcy Denney firm for their representation of you in this case. ANSWER: Objection. Edwards objects to the above-cited Requests to Produce on the purported gro

responded to, but this Motion deals exclusively with those delineated above. The other outstanding discovery is addressed in a separate Motion. 2 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00585374 Florida Law permits litigants ample latitude in discovery. Rule 1.280 of the Flor

ation, travel expenses, deposition related costs, expert costs, etc.) that were incurred by RRA in its representation of Jane Doe, L.M. and E.W. 5 Tonja Haddad, P.A. • 315 SE 7" Street, Fort Lauderdale, FL 33301 EFTA00585377 during the time you were employed by RRA (or that is being claimed by the trustee

f the foregoing was served, via electronic service, to all parties on the attached service list, this September 25, 2017. /s/ Tonia Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 19 Tonja Haddad, P.A. • 315 SE 7'h

attorneys have cancelled the following video deposition: NAME AND ADDRESS Jeffrey Epstein DATE AND TIME February 18, 2015 9:30 a.m. LOCATION Searcy Denney 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 VIDEOGRAPHER: Above & Beyond Reprographics, Inc. upon oral examination before Palm Bea

one: (954)467-6767 Fax: (954)467-3599 Attorneys for Jeffrey Epstein Tonja Haddad Coleman, Esquire [email protected]; [email protected] Tonja Haddad, M. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Phone: (954)467-1223 Fax: (954)-337-3716 Attorneys for Jeffrey Epstein EFTA00714829

Fred Haddad, M. 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 [email protected]; [email protected] Tonja Haddad, M. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Phone: (954)467-

TONJA HADDAD, PA 315 SE 7th Street Suite 301 Fort Lauderdale, FL 33301 June 28, 2017 Via Electronic Mail Jack Scarola, Esq. Searcy Denney et at. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Re: Epstein v. Edwards et aL Good morning Mr. Scarola: elephone facsimile In ant

ert witness lists, and once you do, discovery may ensue regarding the actual persons you list thereon. Thank you. Sincerely, TONJA HADDAD, PA /s/ Tonja Haddad Coleman Tonja Haddad Coleman for the firm cc: Parties on Service List EFTA00809609