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

n. Epstein subsequently dismissed his Complaint without prejudice. The counter- claim proceeded, undergoing several amendments. As it now stands, the Fourth Amended Counterclaim has two causes of action: abuse of process and malicious prosecution. Epstein moved for summary judgment arguing that the litigation p

Seventh Street, Suite 301 2139 Palm Beach Lakes Boulevard Ft. Lauderdale, FL 33301 West Palm Beach, FL 33409 By: By: Jack Scarola (FBN 169440 Tonja Haddad Coleman (FBN 0176737) Primary: Primary: Primary: Secondary: Primary: Counsel for Bradley J. Edwards. - and — Jack A. Goldberger (FBN 262013) ATTERBU

ipley 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Primary: Primary: Primary: Counsel for Bradley J. Edwards 2 Tonja Haddad Coleman Tonja Haddad, P.A. 5315 S.E. Seventh Street, Suite 301 Ft. Lauderdale, FL 33301 Primary: Secondary: Co-counsel for Jef•ey Epstein Jack A. Goldberger Atterb

Primary: Primary: Counsel for Bradley J. Edwards TONJA HADDAD, P.A. 5315 S.E. Seventh Street, Suite 301 Ft. Lauderdale. Florida 33301 By: /s/ Tonja Haddad Coleman (FBN 0176737) Primary: Secondary: - and — Jack A. Goldberger (FBN 262013) ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Avenue S., Suite 1

roposal. e. Amount Proposed to Settle Claim for Punitive Damages, If Any: Edwards has asserted a claim against Epstein for punitive damages in his Fourth Amended Counterclaim. The Total Amount set forth in paragraph 2(d) above includes payment of $100,000 for Edwards' claim for punitive damages . The total a

ley J. Edwards TONJA HADDAD, P.A. 5315 S.E. Seventh Street, Suite 301 Ft. Lauderdale, Florida 33301 (954) 467-1223; (954) 337-3716 [fax] By: /s/ Tonja Haddad Coleman Tonja Haddad Coleman (FBN 0176737) Primary: Secondary: - and — Jack A. Goldberger (FBN 262013) ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Austral

pley 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Primary: Primary: Primary: Counsel for Bradley .I. Edwards 2 Tonja Haddad Coleman Tonja Haddad, P.A. 5315 S.E. Seventh Street, Suite 301 Ft. Lauderdale, FL 33301 Primary: Secondary: Co-counsel for Jeffrey Epstein Jack A. Goldberger Atter

HADDAD, P.A. 5315 S.E. Seventh Street, Suite 301 Ft. Lauderdale, Florida 33301 (954) 467-1223; (954) 337-3716 [fax] By: /s/ Tonja Haddad Coleman Tonja Haddad Coleman (FBN 0176737) Primary: Secondary: - and — Jack A. Goldberger (FBN 262013) ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Avenue S., Suite 1

roposal. e. Amount Proposed to Settle Claim for Punitive Damages, If Any: Edwards has asserted a claim against Epstein for punitive damages in his Fourth Amended Counterclaim. The Total Amount set forth in paragraph 2(d) above includes payment of $10,000 for Edwards' claim for punitive damages. The total amo

ce, to all parties on the attached service list, this June 2, 2014. /s/ Ionia I laddad 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) Attorneys for Epstein Tonja Haddad, M. •

ey J. Edwards, Esq. 425 N. Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 Fred Haddad, Esq. 1 Financial Plaza, Ste. 2612 Ft. Lauderdale„FL 33301 Tonja Haddad Coleman, Esq. 315 SE 7th Si, Ste. 301 Ft. Lauderdale, FL 33301 William B. King, Esq. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Burlington &

n. Epstein subsequently dismissed his Complaint without prejudice. The counter- claim proceeded, undergoing several amendments. As it now stands, the Fourth Amended Counterclaim has two causes of action: abuse of process and malicious prosecution. Epstein moved for summary judgment arguing that the litigation p

st Palm Beach, FL 33409 Primary: Primary: Primary: Counsel for Bradley J. Edwards TONJA HADDAD, •. 5315 S.E. Seventh Street, Suite 301 By: /s/ Tonja Haddad Coleman Tonja Haddad Coleman (FBN 0176737) Primary: Secondary: - and — Jack A. Goldberger (FBN 262013) ATTERBURY, GOLDBERGER & WEISS, •. 250 Australia

9 Primary: Primary: Primary: Counsel for Bradley J. Edwards TONJA HADDAD, •. 5315 S.E. Seventh Street, Suite 301 By: /s/ Tonja Haddad Coleman Tonja Haddad Coleman (FBN 0176737) Primary: Secondary: - and — Jack A. Goldberger (FBN 262013) ATTERBURY, GOLDBERGER & WEISS, •. 250 Australian Avenue S., Suite 140

roposal. e. Amount Proposed to Settle Claim for Punitive Damages, If Any: Edwards has asserted a claim against Epstein for punitive damages in his Fourth Amended Counterclaim. The Total Amount set forth in paragraph 2(d) above includes payment of $20,000 for Edwards' claim for punitive damages. The total amo

iff Bradley Edwards's Request for a Protective Order, and grant such other and further relief as deemed necessary and proper. 6 EFTA00691828 /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 LAW OFFICES OF TONJA HADDAD, PA 315 SE 7th Street Suite 301 ' 301 WE HEREBY CERTIFY that a t

Request for a Protective Order, and grant such other and further relief as deemed necessary and proper. 6 EFTA00691828 /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 LAW OFFICES OF TONJA HADDAD, PA 315 SE 7th Street Suite 301 ' 301 WE HEREBY CERTIFY that a true and correct copy o

d factually deficient Motion for Protective Order. In support thereof, Epstein states: INTRODUCTION On or about January 9, 2013, Edwards filed his Fourth Amended Counterclaim against Epstein, asserting therein that he suffered the following damages: "a) injury to his reputation; b) mental anguish, embarrassm

t 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 26 EFTA00799364

n. Epstein subsequently dismissed his Complaint without prejudice. The counter- claim proceeded, undergoing several amendments. As it now stands, the Fourth Amended Counterclaim has two causes of action: abuse of process and malicious prosecution. Epstein moved for summary judgment arguing that the litigation p

23 24 25 THE COURT: Have we settled upon the next motion we would like to have heard? MS. HADDAD COLEMAN: Yes, Judge. We will be proceeding -- Tonja Haddad Coleman on behalf of Jeffrey Epstein. We will be proceeding with our motion to overrule objections and compel Defendant/ Counter-Plaintiff Bradley Edward

rocess claim has been disposed of. It was successfully won on the summary judgment and is no longer an issue. So the only operative portion of the Fourth Amended Counterclaim is count two, malicious prosecution. In that complaint, Judge, against Mr. Epstein, Mr. Edwards asserts in paragraph 24, "While pro

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

n. Epstein subsequently dismissed his Complaint without prejudice. The counter- claim proceeded, undergoing several amendments. As it now stands, the Fourth Amended Counterclaim has two causes of action: abuse of process and malicious prosecution. Epstein moved for summary judgment arguing that the litigation p