Epstein Secrets

and upon Judge Donald Hafele, via hand delivery, this October 12, 2013. 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 (facsimile) Counsel for Epstein EFTA00589665 SERVI

foregoing was served, via electronic service, to all parties listed below, and upon Judge Donald Hafele, via hand delivery, this October 12, 2013. 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

via electronic service, to all parties listed below, and upon Judge Donald Hafele, via hand delivery, this October 12, 2013. 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

aintiff/Counter- Defendant, hereby certifies that this Motion is made in good faith. The undersigned counsel further certifies that the affidavit of the Plaintiff/Counter-Defendant is likewise in good faith, and is based upon his well-founded fear that he cannot receive a fair hearing or trial from Judge Hafele. WE HEREBY CER

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

rey Epstein as to Bradley Edwards through intemet searches. 27. Provide an explanation for your belief that law enforcement is still investigating the Plaintiff/Counter-Defendant Jeffrey Epstein. Identify contacts with govemment/law enforcement, media, other attorneys, or anyone else from which you claim to form this belief,

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

rey Epstein as to Bradley Edwards through intemet searches. 27. Provide an explanation for your belief that law enforcement is still investigating the Plaintiff/Counter-Defendant Jeffrey Epstein. Identify contacts with govemment/law enforcement, media, other attorneys, or anyone else from which you claim to form this belief,

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

rey Epstein as to Bradley Edwards through intemet searches. 27. Provide an explanation for your belief that law enforcement is still investigating the Plaintiff/Counter-Defendant Jeffrey Epstein. Identify contacts with govemment/law enforcement, media, other attorneys, or anyone else from which you claim to form this belief,

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

n related quasi-criminal proceedings. In support thereof Plaintiff/Counter-Defendant, JEFFREY EPSTEIN states as follows: 1. Undersigned counsel for the Plaintiff/Counter-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 Dis