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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
s personal financial information at issue, courts will compel production of personal financial information. Friedman, 863 So. 2d at 194; Woodward v. Berkey, 714 So. 2d 1027, 1036 (Fla. 4th DCA 1998). A party's finances, if relevant to the disputed issues of the underlying action, are not excepted from
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
s personal financial information at issue, courts will compel production of personal financial information. Friedman, 863 So. 2d at 194; Woodward v. Berkey, 714 So. 2d 1027, 1036 (Fla. 4th DCA 1998). A party's finances, if relevant to the disputed issues of the underlying action, are not excepted from
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
s personal financial information at issue, courts will compel production of personal financial information. Friedman, 863 So. 2d at 194; Woodward v. Berkey, 714 So. 2d 1027, 1036 (Fla. 4th DCA 1998). A party's finances, if relevant to the disputed issues of the underlying action, are not excepted from
Entities connected to both Tonja Haddad Coleman and Berkey

Jeffrey Epstein
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSONFred Haddad
PERSONJack Scarola
PERSONScott Rothstein
PERSONAtterbury
ORGANIZATION
George W. Bush
PERSONPalm Beach Lakes Blvd
LOCATIONSearcy Denney Scarola
PERSONMarc Nurik
PERSONW. Chester Brewer
PERSONJane Doe
PERSONTHE CIRCUIT COURT
ORGANIZATIONHaddad Coleman
PERSONFanner Jaffe Weissing Edwards
PERSON
Scarlett Johansson
PERSON
Jack Goldbe
PERSONE.W.
PERSONthe Florida Rules of Civil
ORGANIZATION