Epstein Secrets

e attached service list, via electronic service, this October 11, 2017. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 Tonja Haddad, PA 5315 SE 70, Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 954.337.3716 facsimile EFTA00582842 SERVICE LIST CASE NO. 50200

and correct copy of this Response was served on all parties listed on the attached service list, via electronic service, this October 11, 2017. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 Tonja Haddad, PA 5315 SE 70, Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 95

is Response was served on all parties listed on the attached service list, via electronic service, this October 11, 2017. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 Tonja Haddad, PA 5315 SE 70, Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 954.337.3716 facsimile

orida 33301 Fred Haddad, Esq. EFTA00582843 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Ton'a Haddad Coleman, Es uire Law Offices of Tonja Haddad, 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Attorneys for Jeffrey Epstein EFTA00582844

as "government privilege," notwithstanding that it is he who is prosecuting this matter and who bears the burden of proof. As such, not only should Edwards's Motion to preclude evidence be denied, but Edwards should also be precluded from presenting any evidence or testimony for which he has asserted any privil

s Motion was argued before this Court on January 27, 2014, at which time this Court, after extensive argument and review of all written submissions Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00613837 and case law, granted Epstein's Motion. Days later, Edwards filed a Motion for

copy of the foregoing was served, via electronic service, to all parties on the attached service list, this May II, 2014. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7'h Street Suite 301 Fort Lauderdale, Florida 33301 facsimile) Attorneys for Epstein 6

2007), as well as reviewing the application and analysis of those cases in Wolfe v. Foreman, 38 Fla. L. Weekly D1540 (July 17, 2013), correctly 2 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00613838 concluded that all actions occurring during the course of a judicial proceeding,

at a true and correct copy of the foregoing was served, via electronic service, to all parties on the attached service list, this May II, 2014. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7'h Street Suite 301 Fort Lauderdale, Florida 33301 facsimile) At

fifty states and the District of Columbia," which are inapposite to this matter. See Edwards's Motion for Reconsideration, p. 2. The remainder of Edwards's Motion reiterates cases that he already presented, briefed, and argued to this Court; arguments that this Court rejected. Accordingly, the Court should ne

s Motion was argued before this Court on January 27, 2014, at which time this Court, after extensive argument and review of all written submissions Tonja Haddad, • • 315 SE 7th Street, Fort Lauderdale, FL 33301. 954.467.1223 EFTA00583040 and case law, orally granted Epstein's Motion. Days later, Edwards f

copy of the foregoing was served, via electronic service, to all parties on the attached service list, this May 11, 2014. /s/ Ionia Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7'h Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 954.337.3716 (facsimil

in fifty states and the District of Columbia," which are inapposite to this matter. See Edwards's Motion for Reconsideration, p. 2. The remainder of Edwards's Motion reiterates cases that he already presented, briefed, and argued to this Court; arguments that this Court rejected. Accordingly, the Court should no

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

either good cause or any law in support thereof, fails to satisfy the heightened requisite showing for an order of protection, mandating denial of Edwards's Motion. Third, Edwards asserts that a protective order is warranted because the production requested "is unnecessarily intrusive into the financial privac

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

Ponzi Scheme was becoming urgent. Depositions taken of Scott W. Rothstein in In re: Rothstein Rosenfeld: Adler, PA; 09-34791-RBR. The court rejected Edwards's Motion, calling it "devoid of evidence." See Order in Jane Doe No. 2 v. Epstein Dated November 5, 2009, 08-cv-80119. The connection between many of these