Epstein Secrets

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

, and throughout this litigation has been, actively pursuing a quasi-criminal matter, Doe v. United States, in the United States District Court for the Southern District of Florida. In the Doe Case, claimants, through Edwards, are seeking to rescind Mr. Epstein's non-prosecution agreement. Mr. Edwards's stated goal i

ng at RRA during the time in question, establish the requisite cause to defeat Edwards's claims. Respectfully submitted, /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 954.337.3716 (facsimil

d upon which he will rely in prosecution of his case, Edwards stated: "every pleading, motion, notice and discovery request served by the Plaintiff Tonja Haddad, • 315 SE 7th Street, Fort Lauderdale, FL 33301. 954.467.1223 EFTA00597313 on Bradley Edwards in this case." When Epstein asked for the dates upo

" and what was occurring at RRA during the time in question, establish the requisite cause to defeat Edwards's claims. Respectfully submitted, /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

ave inside information due to its representation of one of Epstein's alleged victims in a civil case styled Jane Doe v. Jeffrey Epstein, pending in the Southern District of Florida. Representatives of D3 were offered Tonja Haddad?... • 315 SE 7th Street, Fort Lauderdale, FL 33301. 954.467.1223 EFTA00597314 "the

33301• 954.467.1223 EFTA_R1_00012253 EFTA01734353 such as those alleged in the Razorback Complaint, intensified drastically in the short six (6) Tonja Haddad, P.A. • 315 SE 7" Street, Fort Lauderdale, FL 33301. 954.467.1223 EFTA_R1_00012254 EFTA01734354

d upon which he will rely in prosecution of his case, Edwards stated: "every pleading, motion, notice and discovery request served by the Plaintiff Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301. 954.467.1223 EFTA_R1_00012251 EFTA01734351 on Bradley Edwards in this case." When Epstein a

ave inside information due to its representation of one of Epstein's alleged victims in a civil case styled Jane Doe v. Jeffrey Epstein, pending in the Southern District of Florida. Representatives of D3 were offered Tonja Haddad, P.A. • 315 SE 7" Street, Fort Lauderdale, FL 33301. 954.467.1223 EFTA_R1_00012252 EFT

ff [email protected] Fred Haddad, Esq. 1 Financial Plaza Suite 2612 Pnrt 1 sinrionrinle Ft 111A1 Tonja Haddad Coleman, Esq. Law Offices of Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 W. Chester Brewer, Esq. 250 Australian Avenue South Suite 1400 West Palm Beach, FL

te 2 Fort Lauderdale. Florida 33301 staff [email protected] Fred Haddad, Esq. 1 Financial Plaza Suite 2612 Pnrt 1 sinrionrinle Ft 111A1 Tonja Haddad Coleman, Esq. Law Offices of Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 W. Chester Brewer, Esq. 250 Australian Avenue Sou

ounter-Defendant, JEFFREY EPSTEIN, has been Mr. Epstein's primary defense counsel for ten years. 2. Pending in the United States District Court for the Southern District of Florida is a quasi- criminal matter Doe v. United States Case No. 08-cv-80736-KAM. 3. In that quasi-criminal matter the attorney, Bradley J. Edwa

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

ve inside information due to its representation of one of Epstein's alleged victims in a civil case styled Jane Doe v. Jeffrey Epstein, pending in the Southern District of Florida. Representatives of D3 were offered "the opportunity" to invest in a pre-suit Jeffrey Epstein. R. 810, citing pleadings in LM v.

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

orida, and the Defendant will be served by the following procedure; THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for the Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor of prosecution by the State of Florida, provided that Epstein

White 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. Q Do

rsement) By: /s/ Paul G. Cassell r N' Pro Hac Vice -AND — I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule 2090-1(A). SHAPIRO LAW By:

Lauderdale, Florida 33301 Fred Haddad, Es . 1 Financial Plaza Suite 2612 Fort Lauderdale, FL 33301 Toria Haddad Coleman, Es uire Law Offices of Tonja Haddad, 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Attorneys for Jeffrey Epstein 30 EFTA00583981

ed Complaint in Razorback 1 The following facts are well documented by media reports, criminal case files from the United States District Court for the Southern District of Florida, civil case filings from the Florida circuit courts and the pleadings and discovery in the instant case. 2 Although Epstein's subjective