Epstein Secrets

80994, 08-80811, 08-80893, 09-80469, 09- 80591, 09-80656, 09-80802,09-81092. 46. Jeffrey Epstein's Deposition testimony and discovery responses in State Court cases LM v. Jeffrey Epstein, Case No. 502008CA028051XXXXMB AB and M . v. Jeffrey Epstein, Case No. 502008CP003626XXXXMB. This is so overbroad th

es, misleading the jury, or needless presentation of cumulative evidence." § 90.403 FLA. STAT. (2016); Dailey v. Multicon Development, Inc., 417 2 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauderdale, FL 33301 EFTA00585421 So. 2d 1106, 1107 (Fla. 4th DCA 1982). 'Unfair prejudice' has been described as '

rue and correct copy of the foregoing was served, via electronic service, to all parties on the attached service list, this September 25, 2017. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE Th Street Suite 301 Fort Lauderdale, Florida 33301 Attorneys for E

, 09-80469, 09-80591, 09-80656, 09-80802, 09- 81092 43. Jeffrey Epstein's Answers and Affirmative Defenses in all civil cases against him. This 5 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauderdale, FL 33301• EFTA00585424 is so overbroad that Epstein cannot possibly make a determination as to whether

f the foregoing was served, via electronic service, to all parties on the attached service list, this September 25, 2017. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE Th Street Suite 301 Fort Lauderdale, Florida 33301 Attorneys for Epstein 24 Tonja Hadd

Epstein. This Court has already ruled that everything post Link & Rockenbach is not a violation of the November 2010 Agreed Order but, rather, is a State Court issue, and will not be considered at the Show Cause hearing. Therefore, there is no further live testimony that can be elicited from Epstein that wo

ite about the disc that was turned over by them to Link & Rockenbach? A. No. Not to the best of my knowledge. Q. Have you ever communicated with Tonja or Fred Haddad about the Fowler White disc? A. Not to the best of my knowledge. Q. Did you ever receive a copy of the disc itself? A. No. 5

Epstein. This Court has already ruled that everything post Link & Rockenbach is not a violation of the November 2010 Agreed Order but, rather, is a State Court issue, and will not be considered at the Show Cause hearing. Therefore, there is no further live testimony that can be elicited from Epstein that wo

ite about the disc that was turned over by them to Link & Rockenbach? A. No. Not to the best of my knowledge. Q. Have you ever communicated with Tonja or Fred Haddad about the Fowler White disc? A. Not to the best of my knowledge. Q. Did you ever receive a copy of the disc itself? A. No. 5