Epstein Secrets

ct that throughout his defense of this action, Epstein maintained that he had no liability to Edwards and that Edwards's actions were barred by, 3 Tonja liaddad, PA. • 315 SE 7* Street, Fort Lauderdale, FL 33301• EFTA00805512 among other things, the litigation privilege. Accordingly, an award of a

uary 27, 2014, this Honorable Court granted summary judgment in favor of Epstein on both counts. This Court entered an Order reflecting same on May Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, EL 33301 EFTA00805510 19, 2014. A true and correct copy of the Order is attached hereto as "Exhibit B.

at a true and correct copy of the foregoing was served, via electronic service, to all parties on the attached service list, this June 2, 2014. /s/ Tonja Haddad Coleman Tonja Haddad Coleman Esq. Florida Bar No.: Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 facsimile) Attorneys

2 Fort Lauderdale, Florida 33301 Fred Haddad Es I Financial Plaza Suite 2612 Fort Lauderdale, FL 33301 Ton'itHa dColeman uire Law Offices of Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 W. Chester Brewer, Jr. W. Chester Brewer, Jr., P.A. 250 S. Australian Avenue Suite

copy of the foregoing was served, via electronic service, to all parties on the attached service list, this June 2, 2014. /s/ Tonja Haddad Coleman Tonja Haddad Coleman Esq. Florida Bar No.: Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 facsimile) Attorneys for Epstein 5 . Tonja Had

f the award. Equitable remedies are not relinquished by virtue of this provision; nor does either Party relinquish the right to pursue any other 2 Tonja Haddad, P.A. • 315 SE t h Street, Fort Lauderdale, FL 33301 EFTA00805502 legal or equitable damages to which (s)he may be entitled as a result of the ot

iprocal Confidentiality. The Parties agree that the amount of this settlement shall be kept strictly confidential and shall not be disclosed at any Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301• EFTA00805501 time to any third party, except: (a) to the extent required by law or rule; (b)

a true and correct copy of the foregoing was served, via electronic service, to all parties on the attached service list this October 5, 2017. /s/ Tonja Haddad Coleman Tonja Haddad Coleman Esq. Florida Bar No.: Tonja Haddad, PA 5315 SE 7th Street Suite 301 1111, Florida 33301 facsimile) S Tonja Haddad, P.A

py of the foregoing was served, via electronic service, to all parties on the attached service list this October 5, 2017. /s/ Tonja Haddad Coleman Tonja Haddad Coleman Esq. Florida Bar No.: Tonja Haddad, PA 5315 SE 7th Street Suite 301 1111, Florida 33301 facsimile) S Tonja Haddad, P.A. • 315 SE 7th Street, For

REBY CERTIFY that a true and correct copy of the foregoing was served upon all parties listed below, via Electronic Service, this June 2, 2017. /s/ Tonja Haddad Coleman Tonja Haddad Coleman Esq. Fla. Bar No.i.Min LAW OFFICES OF IONIA HADDAD, PA 315 SE 7ih Street Suite 301 Fort Lauderdale, Florida 33301 facsimi

27 (Fla. 4th DCA 1980) (holding that "[a]bsent extraordinary circumstances, proper notice should include written notice served a reasonable time 2 Tonja Haddad. P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301• UM= EFTA00805471 before the time specified for the hearing."). While there are no hard rules

ue and correct copy of the foregoing was served upon all parties listed below, via Electronic Service, this June 2, 2017. /s/ Tonja Haddad Coleman Tonja Haddad Coleman Esq. Fla. Bar No.i.Min LAW OFFICES OF IONIA HADDAD, PA 315 SE 7ih Street Suite 301 Fort Lauderdale, Florida 33301 facsimile) 4 Tonja Haddad. P.A.