Epstein Secrets

the central issue of Epstein's liability in the case at hand. Consequently, it would be a waste of judicial resources to proceed to trial prior to the Supreme Court's resolution of this issue. CONCLUSION For all of the reasons above, and in reliance upon the case law cited above, Epstein respectfully requests th

delay by the first court, that warrant the denial of a stay. Thus, absent any such special circumstances, a trial court abuses its discretion in 2 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301• 954.467.1223 EFTA00611632 refusing to grant a stay based on the principle of priority." Spac

EBY CERTIFY that a true and correct copy of the foregoing was served upon all parties listed below, via Electronic Service, this March 7, 2016. Is/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 LAW OFFICES OF TONJA HADDAD, PA 315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 95

Court's ruling as to his Malicious Prosecution count to the Fourth District Court of Appeal. The issue was fully briefed, and on November 12, 2015, Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301• 954.467.1223 EFTA00611631 the Fourth District Court of Appeal reversed this Court's ruling a

e and correct copy of the foregoing was served upon all parties listed below, via Electronic Service, this March 7, 2016. Is/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 LAW OFFICES OF TONJA HADDAD, PA 315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 954.337.37

SE 7th Street, Fort Lauderdale, FL 33301. 954.467.1223 EFTA00583042 that the Third District Court of Appeal committed error in Wolfe. The Florida Supreme Court, however, stated unequivocally that a "trial court may not overrule or recede from the controlling decision of an appellate court. See System Compon

s Motion was argued before this Court on January 27, 2014, at which time this Court, after extensive argument and review of all written submissions Tonja Haddad, • • 315 SE 7th Street, Fort Lauderdale, FL 33301. 954.467.1223 EFTA00583040 and case law, orally granted Epstein's Motion. Days later, Edwards f

copy of the foregoing was served, via electronic service, to all parties on the attached service list, this May 11, 2014. /s/ Ionia Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7'h Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 954.337.3716 (facsimil

rotected by the litigation privilege. As unequivocally stated in the decision of Wolfe v. Foreman, 128 So. 3d 67 (Fla. 3d DCA 2013), and the Florida Supreme Court cases cited therein, Florida's litigation privilege provides to all persons involved in judicial proceedings an absolute privilege from civil liabil

32302) Tallahassee, FL 32301 Telephone: Facsimile: ( (secondary) /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7'h Street Suite 301 Fort Lauderdale, Florida 33301 I l 26 EFTA00589646

05419 AUSLEY & MCMULLEN, P.A. 123 South Calhoun Street P.O. Box 391 (zip 32302) Tallahassee, FL 32301 Telephone: Facsimile: ( (secondary) /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7'h Street Suite 301 Fort Lauderdale, Florida 33301 I l 26 EFTA00

rotected by the litigation privilege. As unequivocally stated in the decision of Wolfe v. Foreman, 128 So. 3d 67 (Fla. 3d DCA 2013), and the Florida Supreme Court cases cited therein, Florida's litigation privilege provides to all persons involved in judicial proceedings an absolute privilege from civil liabil

2301 Telephone: (850) 224-9115 Facsimile: 5 222-7560 (secondary) /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 54.337.3716 facsimile 25 EFTA00714948

EN, M. 123 South Calhoun Street ■. Box 391 (zip 32302) Tallahassee, FL 32301 Telephone: (850) 224-9115 Facsimile: 5 222-7560 (secondary) /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223

. vs. Henry, 839 So2d. 702 at Note 4, 18 Third DCA opinion in 2000, both of which both 19 Judge Cope and the panel in the SCI case note that 20 the Supreme Court's citation in Levin to Wright 21 vs. Yurko, which I cited in the memorandum, which 22 was a Fifth DCA decision back in 1984, implicitly 23 24 25

OURT: Off the record for one second. 21 MR. KING: Yes. 22 (Discussion off the record.) 23 MR. KING: And I cited the Taylor case, 24 which was a Supreme Court of Idaho decision, which 25 discusses that issue and which shows that for www.phippereporting.com 888 811-3408 001241 EFTA00613538 32 1 tho

r Scott Rothstein Jack Goldberger, Esq. ATTERBURY, GOLDBERGER & WEISS, P.A. 250 S. Australian Ave., Ste. 1400 O1 Attorneys for Jeffrey Epstein Tonja Haddad Coleman, Esq. TONJA HADDAD, P.A. 5315 SE 7th Street., Ste. 301 Fort Lauderdale, FL 33301 ttorneys or e rey pstein Bradley J. Edwards, Esq. FARMER, JAFF

the central issue of Epstein's liability in the case at hand. Consequently, it would be a waste of judicial resources to proceed to trial prior to the Supreme Court's resolution of this issue. CONCLUSION For all of the reasons above, and in reliance upon the case law cited above, Epstein respectfully requests th

HEREBY CERTIFY that a true and correct copy of the foregoing was served upon all parties listed below, via Electronic Service, this May 2016. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 LAW OFFICES OF TONJA HADDAD, PA 315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 (f

n set before the Florida Supreme Court on the Debrincat case for August 31, 2016. A true and correct copy of the Order granting and setting Oral 2 Tonja Haddad. P.A. • 315 SE 7th Street, Fort Lauderdale, FL 3330I• 954.467.1223 EFTA00584797 Argument is attached hereto as "Exhibit A." Accordingly, as demons

who says he had_ ~~-x w1ih her: when :she wa_s lfand had sought his :help becoming a model. The laws"[Jit,. filed fate Tuesciay in Manha~an's state SlJpreme Court, s'1ys fi11~uwier Jeffrey Epstein had the teen perform.a.sex act when she brought photographs of herself for him.to review in his Upper East Sid~ma

paid to three of the young woman came last:week in documents filed for a hearing Tuesday in preparation for a December trial on the lawsuit. Attorney Tonja Haddad Coleman, who represents Epstein, on Tuesday sought a delay ofthe trial, in part, because she claimed she has been unable to talk to her client since his esta

recoveries against Epstein from various civil actions. Shortly before Epstein's complaint was filed, Edwards' partner, Rothstein, was disbarred by the Supreme Court of Florida, and charged by the United States Government with various federal crimes arising out of the scheme. Epstein eventually narrowed his claims

hilip M. Burlington Burlington & Rockenbach, P.A. Imo Tonja Haddad Coleman -18- EFTA00612500 W. Chester Brewer, Jr. W. Chester Brewer. Jr P.A. Tonja Haddad Coleman, P.A. Bradley J. Edwards Fanner, Jaffe, Weissing, Edwards, Fred Haddad Fred Haddad, P.A. Mark Nurik Law Offices of Mark S. Nurik Jack Goldberg

stantive filings in this case until June 2017, after the Supreme Court declined jurisdiction. Defendant noticed this matter for trial shortly before the Supreme Court's decision and, in July 2017, the Court entered its trial order, special setting a ten-day trial less than five months away. INTRODUCTION The trial

t. Lauderdale FL 33301 Counsel for Defendant Scott Rothstein Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards 2 A19 EFTA00798185 Tonja Haddad Coleman Fred Haddad 315 S.E. Seventh Street, Suite 301 Haddad & Navarro, PLLC Ft. Lauderdale, FL 33301 1 Financial Plaza, Suite 2612 Fort Lauderdale FL