Epstein Secrets

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

res on improper pleadings, discovery and motion practice by Edwards in the cases he was litigating against Epstein while a Partner at RRA and while the Ponzi Scheme was then in critical need of additional investment and about to unravel, as well as a subsequent Federal court order characterizing one of those mo

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

res on improper pleadings, discovery and motion practice by Edwards in the cases he was litigating against Epstein while a Partner at RRA and while the Ponzi Scheme was then in critical need of additional investment and about to unravel, as well as a subsequent Federal court order characterizing one of those mo

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

res on improper pleadings, discovery and motion practice by Edwards in the cases he was litigating against Epstein while a Partner at RRA and while the Ponzi Scheme was then in critical need of additional investment and about to unravel, as well as a subsequent Federal court order characterizing one of those mo

Lehrman 425 N Andrews Avenue Suite 2 Fort Lauderdale, Florida 33301 Fred Haddad, Esq. 1 Financial Plaza Suite 2612 Fort Lauderdale, FL 33301 Tonja Haddad Coleman, Esquire Law Offices of Tonja Haddad, M. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Attorneys for Jeffrey Epstein 17 EFTA00808221

Lauderdale, Florida 33301 Fred Haddad, Esq. 1 Financial Plaza Suite 2612 Fort Lauderdale, FL 33301 Tonja Haddad Coleman, Esquire Law Offices of Tonja Haddad, M. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Attorneys for Jeffrey Epstein 17 EFTA00808221

rm, which enhanced the credibility of the purported investment opportunity; (d) Rothstein and other co-conspirators utilized funds obtained through the Ponzi Scheme to supplement and support the operation and activities of RRA, to expand Among the allegations in the Razorback Complaint regarding the Epstein cas

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

rm, which enhanced the credibility of the purported investment opportunity; (d) Rothstein and other co-conspirators utilized funds obtained through the Ponzi Scheme to supplement and support the operation and activities of RRA, to expand RRA by the hiring of additional attorneys and support staff, to fund sala

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

ews outlets also reported at that time that the Florida Bar had begun actively investigating dozens of attorneys employed by RRA in connection with the Ponzi Scheme. [Cite Epstein Affidavit]; Miami Herald, Scott Rothstein Scandal: Scott Rothstein Partners Probed (January 14, 2010)("The Florida Bar is investigat

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

time that Rothstein had been disbarred and the Florida Bar had begun actively investigating dozens of attorneys employed by RRA in connection with the Ponzi Scheme. [Cite Epstein Affidavit]; Miami Herald, Scott Rothstein Scandal: Scott Rothstein Partners Probed (January 14, 2010)("The Florida Bar is investigati