Epstein Secrets

407 A: I'm not going to answer based on privilege. Id. at page 142; line 25. The subject matter of the deposition turned to the subpoena served on Ghislaine Maxwell: Q: Do you, is she neither would you agree that neither Jane Doe nor L.M. have testified to any, that they had any connection whatsoever with Ghisl

nd what, what was, what is the purpose; that is, with regard to your three clients and only your three clients is they — what connection if any, did Ghislaine Maxwell have to those individuals? Id. at page 155; line 19-23. MR. SCAROLA: Objection, work-product. Instruct you to not answer. Id. at 155; line

at was, what is the purpose; that is, with regard to your three clients and only your three clients is they — what connection if any, did Ghislaine Maxwell have to those individuals? Id. at page 155; line 19-23. MR. SCAROLA: Objection, work-product. Instruct you to not answer. Id. at 155; line 24-25.

objection again, Edwards was asked if he would assert the same objections to the questions, and both he and his counsel answered affirmatively. 2 Tonja Haddad, P.A. • 315 SE 7" Street, Fort Lauderdale, FL 33301• 954.467.1223 EFTA00799403 examination when a lawyer improperly uses speaking objections to pr

ort Lauderdale, FL 3330I• 954.467.1223 EFTA00799425 electronic service, to all parties on the attached service list, this September 25, 2017. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Suite 301 301 25 Attorneys for Epstein Tonja Haddad, M. • 315 SE 7th Street, Fort Lauderdal

dwards responded: "My objection to those previous questions would be my objection today." Deposition of Edwards dated 2013, page 98, lines 8-12. 3 Tonja Haddad. P.A. • 315 SE 7th Street, Fort Lauderdale, FL 3330I• 954.467.1223 EFTA00799404 question."). Edwards has impermissibly hidden behind unavailing p

0I• 954.467.1223 EFTA00799425 electronic service, to all parties on the attached service list, this September 25, 2017. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Suite 301 301 25 Attorneys for Epstein Tonja Haddad, M. • 315 SE 7th Street, Fort Lauderdale, FL 3330I• 954.467.1

ims of his sexual molestations. 145. Phone journal taken from Epstein's home and produced to the FBI by Alfredo Rodriguez. 146. Photo depicting Ghislaine Maxwell, and Prince Andrew. 147. Al flight logs for any Epstein owned or controlled aircraft. This is so overbroad that Epstein cannot possibly make a det

edo Rodriguez. 146. Photo depicting Ghislaine Maxwell, and Prince Andrew. 147. Al flight logs for any

BI by Alfredo Rodriguez. 146. Photo depicting Ghislaine Maxwell, and Prince Andrew. 147. Al flight logs

es, misleading the jury, or needless presentation of cumulative evidence." § 90.403 FLA. STAT. (2016); Dailey v. Multicon Development, Inc., 417 2 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauderdale, FL 33301 EFTA00585421 So. 2d 1106, 1107 (Fla. 4th DCA 1982). 'Unfair prejudice' has been described as '

rue and correct copy of the foregoing was served, via electronic service, to all parties on the attached service list, this September 25, 2017. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE Th Street Suite 301 Fort Lauderdale, Florida 33301 Attorneys for E

, 09-80469, 09-80591, 09-80656, 09-80802, 09- 81092 43. Jeffrey Epstein's Answers and Affirmative Defenses in all civil cases against him. This 5 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauderdale, FL 33301• EFTA00585424 is so overbroad that Epstein cannot possibly make a determination as to whether

f the foregoing was served, via electronic service, to all parties on the attached service list, this September 25, 2017. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE Th Street Suite 301 Fort Lauderdale, Florida 33301 Attorneys for Epstein 24 Tonja Hadd

-23. A: I'm not going to answer based on privilege. Id. at page 142; line 25. The subject matter of the deposition turned to the subpoena served on Ghislaine Maxwell: 6 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301• EFTA00585399 Q: Do you, is she neither would you agree that neither Jane D

nd what, what was, what is the purpose; that is, with regard to your three clients and only your three clients is they — what connection if any, did Ghislaine Maxwell have to those individuals? Id. at page 155; line 19-23. MR. SCAROLA: Objection, work-product. Instruct you to not answer. Id. at 155; line

at was, what is the purpose; that is, with regard to your three clients and only your three clients is they — what connection if any, did Ghislaine Maxwell have to those individuals? Id. at page 155; line 19-23. MR. SCAROLA: Objection, work-product. Instruct you to not answer. Id. at 155; line 24-25.

objection again, Edwards was asked if he would assert the same objections to the questions, and both he and his counsel answered affirmatively. 2 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00585395 examination when a lawyer improperly uses speaking objections to prevent meaningf

ties on the attached service list, this September 25, 2017. 24 Tonja Haddad. P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00585417 Is/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 Attorneys for

dwards responded: "My objection to those previous questions would be my objection today." Deposition of Edwards dated 2013, page 98, lines 8-12. 3 Tonja Haddad. P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00585396 question."). Edwards has impermissibly hidden behind unavailing privileges and o

ervice list, this September 25, 2017. 24 Tonja Haddad. P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00585417 Is/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 Attorneys for Epstein 25 Tonja Had

tle 243 Riverside, Dr. New York, NY 10025 141' Ghislaine Maxwell Address Currently Unknown 142 Records Custodia

iverside, Dr. New York, NY 10025 141' Ghislaine Maxwell Address Currently Unknown 142 Records Custodia

tle 243 Riverside, Dr. New York, NY 10025 141' Ghislaine Maxwell Address Currently Unknown 142 Records

ne: (954)467-6767 Fax: (954)-467-3599 Attorneys for Jeffrey Epstein Tonja Haddad Coleman, Esquire [email protected]; [email protected] Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Phone: (954)467-1223 Fax: (954)-337-3716 Attorneys for Jeffrey Epstein EFTA0079804

d Haddad, P.A. One Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 Phone: (954)467-6767 Fax: (954)-467-3599 Attorneys for Jeffrey Epstein Tonja Haddad Coleman, Esquire [email protected]; [email protected] Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Phone: (954)46

shared with any non-lawyer) which communication references directly or indirectly Bradley Edwards, this pending litigation or litigation involving Ghislaine Maxwell. ANSWER: No responsive documents exist. WE HEREBY CERTIFY that a true and correct copy of the foregoing was served upon all parties listed below,

ing litigation or litigation involving Ghislaine Maxwell. ANSWER: No responsive documents exist. WE HER

this pending litigation or litigation involving Ghislaine Maxwell. ANSWER: No responsive documents exist.

Y CERTIFY that a true and correct copy of the foregoing was served 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 L

and correct copy of the foregoing was served 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. 502009CA

he background as he navigated New York high society. When he first attracted notice in the early 1990s, it was on account of the woman he was dating: Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell. In a lengthy article, headlined "The Mystery of Ghislaine Maxwell’s Secret Love,” the Brit

s beau was a CIA spook, a math teacher, a concert pianist or a corporate headhunter, "But what is the truth about him?” the newspaper wondered. "Like Maxwell, Epstein is both flamboyant and intensely private.” The media frenzy did not begin in full until a decade later. In September 2002, Epstein was flung

0s, it was on account of the woman he was dating: Ghislaine Maxwell, daughter of the late British media tycoo

paid to three of the young woman came last:week in documents filed for a hearing Tuesday in preparation for a December trial on the lawsuit. Attorney Tonja Haddad Coleman, who represents Epstein, on Tuesday sought a delay ofthe trial, in part, because she claimed she has been unable to talk to her client since his esta

background as he navigated New York high society. When he first attracted notice in the early 1990s, it was on account of the woman he was dating: Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell. In a lengthy article, headlined "The Mystery of Ghislaine Maxwell's Secret Love," the Bri

beau was a CIA spook, a math teacher, a concert pianist or a corporate headhunter. "But what is the truth about him?" the newspaper wondered. "Like Maxwell, Epstein is both flamboyant and intensely private." The media frenzy did not begin in full until a decade later. In September 2002, Epstein was fl

s, it was on account of the woman he was dating: Ghislaine Maxwell, daughter of the late British media tycoo

id to three of the young woman came last week in documents filed for a hearing Tuesday in preparation for a December trial on the lawsuit. Attorney Tonja Haddad Coleman, who represents Epstein, on Tuesday sought a delay of the trial, in part, because she claimed she has been unable to talk to her client since his es

these additional names. Not sure that the USA or the Bureau has them.) 2. I will be receiving a copy of Judge Sweet's confidentiality order in v. Maxwell and will forward it to you when I get it. (Vacations this week are slowing things a bit.) 3. With regard to lawyers who represent, or did at one ti

CA DUBNO. JOHN STEPHENSON. (Make a note to discuss Erica Dubno, NYC attorney, when we talk. I wonder if she might not be of some help.) LAWYERS FOR GHISLAINE MAXWELL: REPRESENTED BY COHEN GRESSER FIRM FIRST, THEN LAURA MENNINGER, DENVER, COLO. OTHER ATTORNEYS PAID BY EPSTEIN WHO TO REPRESENT VARIOUS WITNESSES: M

WEINBERG. BOB CRITTON. MIKE PIKE. SCOTT LINK. REID WEINGARTEN. GERRY LEFCOURT. JAY LEFKOWITZ. KEN STARR. CHET BREWER. JACK GOLDBERGER. FRED HADDAD. TONJA HADDAD. LIKLY SANCHEZ. JOE ACKERMAN. CHRIS KNIGHT. MICHAEL MILLER. JUSTIN CHU. THERE WERE A COUPLE MORE INSIGNIFICANT ONES. LAWYERS FOR PILOTS, JE HOUSE S

ut I am just going through the questions that refused to be answered at this time. Next it discusses the deposition of the subpoena served on Ms. Maxwell. And Mr. Edwards is asked, "Do you -- is she neither -- would you agree that neither Jane Doe nor LM" -- who are, again, Mr. Edwards' two clients

scusses the deposition of the subpoena served on Ms. Maxwell. And Mr. Edwards is asked, "Do you -- is she ne

23 24 25 THE COURT: Have we settled upon the next motion we would like to have heard? MS. HADDAD COLEMAN: Yes, Judge. We will be proceeding -- Tonja Haddad Coleman on behalf of Jeffrey Epstein. We will be proceeding with our motion to overrule objections and compel Defendant/ Counter-Plaintiff Bradley Edward

24 18:16 11:8 42:22 13:2 14:4,17 Madam (1) matters (1) LatAin (1) level (1) 14:22 15:2,9 61:16 8:19 39:25 52:16 16:9 17:1 maintain (1) Maxwell (3) latch (1) Levin (23) 18:20 19:21 40:10 1:24 62:8,18 40:5 11:10,25,25 21:6,9,10,19 malting (3) mean (2) late (2) 12:6,19 13:6 21:22,2

r Scott Rothstein Jack Goldberger, Esq. ATTERBURY, GOLDBERGER & WEISS, P.A. 250 S. Australian Ave., Ste. 1400 O1 Attorneys for Jeffrey Epstein Tonja Haddad Coleman, Esq. TONJA HADDAD, P.A. 5315 SE 7th Street., Ste. 301 Fort Lauderdale, FL 33301 ttorneys or e rey pstein Bradley J. Edwards, Esq. FARMER, JAFF