Epstein Secrets

le, FL 33301 Br .acHe .LEc .b ls, Es . Fanner Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Fred Haddad, Es 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Ton'a Haddad Coleman, Es . Law Offices of Tonja Haddad, 315 SE 7th Street, Suite 301

AROLA: I am going to object. That calls for attorney-client privilege. Id. at page 98; line 24-25. Q: All right. At the time you began representing E.W. or at any time prior to the filing of the lawsuit against the United States Government in July of '08, did you learn whether she was listed as a, o

reet, Fort Lauderdale, FL 3330I• 954.467.1223 EFTA00799405 lines 20-21. Q: During that time that you have been involved in this case on behalf of E.W., has Mr. Howell participated in the case; that is, has he done work on the case? Id. at page 90; lines 20-23. A: Yes. Id. at page 90; line 24. Q:

le, FL 33301 Br .acHe .LEc .b ls, Es . Fanner Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Fred Haddad, Es 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Ton'a Haddad Coleman, Law Offices of Tonja Haddad, P.A. 315 SE 7th Street, Suite 301

AROLA: I am going to object. That calls for attorney-client privilege. Id. at page 98; line 24-25. Q: All right. At the time you began representing E.W. or at any time prior to the filing of the lawsuit against the United States Government in July of '08, did you learn whether she was listed as a, o

Attorney-Client and work-product privileges. Id. at page 89; lines 20-21. Q: During that time that you have been involved in this case on behalf of E.W., 3 It is significant to note that other jurisdictions have sanctioned counsel for just this behavior during deposition. See e.g. Van Pilsum v. Iow

ale, FL 33301 Bradley J. Edwards, Esq. Fanner Jaffe Weissing Edwards Fistos 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, Esq. Law Offices of Tonja Haddad, P.A. 315 SE 7th Street, Su

in this case, Jack Scarola ("Scarola"), for their flagrant violation of the confidentiality agreements between Epstein and Edwards's clients L.M., E.W., and Jane Doe, as well as enter an Order of entitlement to costs and attorneys' fees in favor of Epstein and against Edwards and Scarola. In support

the disc that was turned over by them to Link & Rockenbach? A. No. Not to the best of my knowledge. Q. Have you ever communicated with Tonja or Fred Haddad about the Fowler White disc? A. Not to the best of my knowledge. Q. Did you ever receive a copy of the disc itself? A. No. 5 EFTA00794250

man, P.L. Paul G. Cassell S.J. Quinney College of Law at the Utah University of Doe Peter E. Shapiro Sha iro Law uite 3000 Counsel for L.M., E.W. and Jane Doe Counsel for L.M., E.W. and Jane Niall T. McLachlan Carlton Fields Jorden Burt, P.A. 200 ounse or ow er ite urnett, P.A. Isaac M.

Counsel for Defendant Scott Rothstein Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards 2 A19 EFTA00798185 Tonja Haddad Coleman Fred Haddad 315 S.E. Seventh Street, Suite 301 Haddad & Navarro, PLLC Ft. Lauderdale, FL 33301 1 Financial Plaza, Suite 2612 Fort Lauderdale FL 33394 Co-Co

IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, -VS- SCOTT individually, EDWARDS, L.M., E.W., Intervenors. ROTHSTEIN, BRADLEY J. individually, and and JANE DOE, Respondents CASE NO. 4D18-0762 APPENDIX TO RESPONSE TO PETITION FOR WRIT

Jaffe Weissing Edwards Fistos & Lehrman, P.L. 425 N Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954)-524-2820 Fax: (954)-524-2822 Fred Haddad, Esquire [email protected]; [email protected] Fred Haddad, P.A. One Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 Phone: (954)4

, Edwards, Fistos & Lehrman PL and/or any other law firm through which you have provided legal services from any other lawyer and/or law firm, L.M., E.W., Jane Doe, any other purported victims, any investigators, paraprofessionals, any other contractors, and any publicity agents, public relations fir

uderdale, FL 33301 Br ...da! Es Es . Fanner Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Fred Haddad, 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Ton'a Haddad Coleman Law Offices of Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort

n related costs, expert costs, etc.) that were incurred by you in the representation of you and/or your law firm in representing Jane Doe, L.M. and E.W. prior to joining RRA. ANSWER: Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence, and is protected by

uderdale, FL 33301 Br ...da! Es Es . Fanner Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Fred Haddad, 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Ton'a Haddad Coleman Law Offices of Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort

n related costs, expert costs, etc.) that were incurred by you in the representation of you and/or your law firm in representing Jane Doe, L.M. and E.W. prior to joining RRA. ANSWER: Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence, and is protected by