Epstein Secrets

l parties hereto, via electronic service, this August 15, 2017. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: LAW OFFICES OF TONJA HADDAD, PA 315 SE 7'h Street Suite 301 Fort Lauderdale, Florida 33301 facsimile) EFTA00806672 SERVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Sc

ERS TO DEFENDANT BRADLEY EDWARDS'S INTERROGATORIES Plaintiff Jeffrey Epstein, by and through his undersigned counsel and pursuant to Rule 1.340 of the Florida Rules of Civil Procedure, hereby certifies that the original answers to Defendant's Interrogatories was served upon Defendant and all parties hereto, via electronic service

ached service list, via electronic and US Mail, this July , 2012. EFTA00589552 Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 LAW OFFICES OF TONJA HADDAD, PA 524 South Andrews Avenue Suite 200N 2 EFTA00589553 SERVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Scarola, Esq. Searcy Denney Scarola

E TO DEFENDANT BRADLEY EDWARDS' REOUEST TO PRODUCE Plaintiff Jeffrey Epstein, by and through his undersigned counsel and pursuant to Rule 1.340 of the Florida Rules of Civil Procedure, hereby files his response to Bradley Edwards' Request to Produce as follows: No such requested document is in the possession of Plaintiff. WE HER

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 of the foregoing was served upon all parties listed below,

Accordingly, and as demonstrated more fully below, denial of Edwards's Motion for Protective Order is mandated. MEMORANDUM OF LAW Rule 1.280(c) of the Florida Rules of Civil Procedure affords the Court discretion to grant protective orders "for good cause shown" and "to protect a party from annoyance embarrassment, oppression, or

essment as delineated below, and do not agree that you have completed production in accordance with Judge Crow's Order. Tonja Haddad Coleman, Esq. TONJA HADDAD, P.A. Justice Building 524 South Andrews Avenue Suite 200 North Fort Lauderdale, Florida 33301 (954) 467-1223 (954) 337-3716 facsimile www.ton

ON TO COMPEL DISCOVERY RESPONSES AND FOR SANCTIONS Plaintiff Jeffrey Epstein, by and through his undersigned counsel and pursuant to Rule 1.380 of the Florida Rules of Civil Procedure, hereby moves this Court to enter an order compelling the Defendant Bradley Edwards, yet again, to provide responses to Plaintiff's Request for Pro

d upon all parties listed below, via Electronic Service, this August 21, 2017. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: TONJA HADDAD, PA EFTA00599636 Fort Lauderdale, Florida 33301 (facsimile) 2 EFTA00599637 SERVICE LIST CASE NO. 502009CA0408003OOOCMBAG Jack Scarola, Esq.

QUEST FOR PRODUCTION Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, hereby responds to Defendant/Counter-Plaintiff Bradley Edward's Request for Production to Counter-Defendant as follows: 1. Any and all documents

vide the responsive documents or have them available for copying within the time parameters as delineated in the Order. Tonja Haddad Coleman, Esq. TONJA HADDAD, P.A. Justice Building 524 South Andrews Avenue Suite 200 North Fort Lauderdale, Florida 33301 acsimile The information contained in this trans

i, 10 Aug 2012 13:27:39 +0000 Mr. Scarola: Your letter and "supplemental response to discovery" are neither permissible nor acceptable pursuant to the Florida Rules of Civil Procedure. The fact that your client purportedly produced these documents in another case in which my client was not even a party is irrelevant and, indeed, n

onic service to the attached Certificate of Service List, this , 2015. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 TONJA HADDAD, PA 315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 954.337.3716 (facsimile) 9 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderda

SUBPOENA Jeffrey Epstein (hereinafter "Epstein"), a non-party to this action, by and through his undersigned counsel and pursuant to Rule 1.530 of the Florida Rules of Civil Procedure, hereby moves this Court for Reconsideration regarding its not yet final ruling' denying Epstein's Motion to Quash the Subpoena Duces Tecum issued

AND WILL UPDATE THESE INTERROGATORIES ACCORDINGLY. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 LAW OFFICES OF TONJA HADDAD, PA 315 SE 7'h Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 954.337.3716 (facsimile) EFTA00583070 SERVICE LIST CASE NO. 5020

PERT INTERROGATORIES Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.340 of the Florida Rules of Civil Procedure hereby serves the following responses to Defendant/Counter-Plaintiff Bradley Edwards's ("Edwards") Expert Interrogatories as follows:. EXPERT INTE