Epstein Secrets

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

z, 785 So. 2d 589, 591 (Fla. 5th DCA 2001) ("[M]erely attaching an unswom document ... does not . . . satisfy the procedural strictures inherent in Florida Rule of Civil Procedure 1.510(e)."). Scarola and Edwards are veteran trial attorneys, are well aware of these Rules, and are more than familiar with the signific

it Judge Copies furnished to: F F F F F F F F F F F F F F F F F F F F F Andrew A. Harris (~~) Bradley James Edwards (ffillia Fred Haddad an) John Scarola irsETPH \CKERMAN JR Maria Kelchian ~la) Matthew D Weissing II~M) Pi 4IMP M RUM INC- roN [email protected] Russell S, Adler

ement. If a settlement is reached, it shall be the responsibility of the attorneys or parties to reduce the agreement to writing and to comply with Florida Rule of Civil Procedure 1.730(6), unless waived. B. The Plaintiff's attorney shall be responsible for scheduling mediation. The parties should agree on a mediat

h, of November, 2013. DAVID F.TR9W Circuit Court Judge Copies famished via e-mail per attached list. ty, Florida this /--) day EFTA00597397 Fred Haddad, One Financial Plaza, Suite 2612 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG COUNSEL LIST Jack Scarola Es Esquire Searcy Denney Scar

stricken from the trial calendar, pleadings may be stricken, and other sanctions may be imposed. D. Any party opposing mediation may proceed under Florida Rule of Civil Procedure 1,700(b). IV. NONCOMPLIANCE NONCOMPLIANCE WITH ANY PORTION OF THIS ORDER MAY RESULT IN THE STRIKING OF THE CASE, WITNESSES, OR EXHIBITS

Jeffrey Epstein Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, FL 425 North Andrews Avenue, Suite 2 Fort 33301 Pho Fax: F Haddad E it Fred Haddad, P.A. One Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 Pho Fax: Attorneys for Jeffrey Epstein Mar i c S. Nurik, Es uire Law Offices

ndant, REQUEST FOR PRODUCTION TO COUNTER-DEFENDANT (PUNITIVE DAMAGES) BRADLEY J. EDWARDS, by and through his undersigned counsel, and pursuant to Florida Rule of Civil Procedure 1.350, hereby requests Production from JEFFREY EPSTEIN of the documents and things described below for the purpose of inspection, copying,

rik, Esq. 1 East Broward Blvd., Ste. 700 Ft. Lauderdale, FL 33301 Bradley 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

ntitled to fees and costs. H. ANALYSIS The requirements for a valid proposal for settlement are set forth in section 768.79, Florida Statutes, and Florida Rule of Civil Procedure 1.442. The offer of judgment statute and rule must be strictly construed, as they are in derogation of the common law rule that each party

furnished to: , 2015. 4 HAFELE CIRC Ai JUDGE EFTA00308356 Jack Svamla Fyn Jack Goldberger, Esq. Marc Nurik, Esq. Bradley J. Edwards, Esq. Fred Haddad, Esq. Tonja Haddad Coleman, Esq. William B. King, Esq. Burlington & Rockenbach, P.A. 5 EFTA00308357

titled to fees and costs. II. ANALYSIS The requirements for a valid proposal for settlement are set forth in section 768.79, Florida Statutes, and Florida Rule of Civil Procedure 1.442. The offer of judgment statute and rule must be strictly construed, as they are in derogation of the common law rule that each party

Copies furnished to: HAFELE CIRC JUDGE 4 EFTA00308361 Jack Scarola. Esa. Jack Goldberner, Esa. Marc Nurik, Esq. Bradley J. Edwards, Esq. Fred Haddad, Esq. Tonja Haddad Coleman, Esq. William B. King, Esq. Burlington & Rockenbach, P.A. 5 EFTA00308362

ntitled to fees and costs. IL ANALYSIS The requirements for a valid proposal for settlement are set forth in section 768.79, Florida Statutes, and Florida Rule of Civil Procedure 1.442. The offer of judgment statute and rule must be strictly construed, as they are in derogation of the common law rule that each party

Lehrman, FL 425 North Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954) 524-2820 Fax: (954) 524-2822 Attorneys for Jeffrey Epstein Fred Haddad, Esquire [email protected]; [email protected] Fred Haddad, One Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 Phone: (954)-467-6767

ndant, REQUEST FOR PRODUCTION TO COUNTER-DEFENDANT (PUNITIVE DAMAGESI BRADLEY J. EDWARDS, by and through his undersigned counsel, and pursuant to Florida Rule of Civil Procedure 1.350, hereby requests Production from JEFFREY EPSTEIN of the documents and things described below for the purpose of inspection, copying,