Epstein Secrets

ited States of America and Scott W. Rothstein, 09-60331-CR-COHN; filed December 1, 2009. 3. Amended Complaint in Razorback Funding, LLC, et al. v. Scott W. Rothstein, et al., in the Circuit Court of the Seventeenth Judicial Circuit, in and for Broward County, Florida, Case No. 09-062943 (19); Lawsuit filed Novemb

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individu

EBY CERTIFY that a true and correct copy of the foregoing was served upon all parties listed below, via Electronic Service, this June 20, 2013. /s/ Tonia Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 TONJA HADDAD, PA 315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 acsimile) 10 EF

T OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and ■1., individually, Defendant(s). RESPONSE TO PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S

MBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually,

33301 Pho Fax: Fred Haddad, Fred Haddad, One Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 Pho Fax: Attorneys for Jeffrey Epstein 4 Tonia Haddad Coleman, Esquire Tonja Haddad, 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Phon Fax: Attorneys for Jeffrey Epstein Marc S. Esquire One E

nited States of America and Scott W. Rothstein, 09-60331-CR-COHN; filed December 1, 2009. 3. Amended Complaint in Razorback Funding, LLC, ET AL v. Scott W. Rothstein, et al., in the Circuit Court of the Seventeenth Judicial Circuit, in and for Broward County, Florida, Case No. 09-062943 (19); Lawsuit filed Novemb

ALREADY SAID INCLUDE HIM AS A WITNESS] MICHAEL LEGAMARO - I BELIEVE HE IS THE ATTORNEY FROM MORGAN LEWIS WHO LOOKED AT THE EPSTEIN CASE FILES IN ROTHSTEIN'S OFFICE 66. Other Investors??? Do we have names? [DON'T NEED THIS NOW DO WE? LOOK AT DISCALA'S DEPO. HE SAYS THAT THANE RITCHIE AND DEAN KRETSC

EBY CERTIFY that a true and correct copy of the foregoing was served upon all parties listed below, via Electronic Service, this June 20, 2013. /s/ Tonia Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 TONJA HADDAD, PA 315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 954

reasonably calculated to lead to the discovery of admissible evidence. b. None. 6. All fee sharing agreements between Bradley J. Edwards, RRA, or Scott W. Rothstein and/or any other attorney or investor relating to any aspect of any Plaintiff's case. ANSWER: Objection, relevance, not reasonably calculated to l

ent to his cause of action. Moreover, discovery relating to Edwards's financial incentives to join RRA and to engage in conduct in cooperation with Rothstein in support of RRA's illicit activities is most certainly relevant to Edward's allegations in this case and Epstein's defense of the same. Accordingl

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/ 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 Hadd

OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800)OOOCMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and M., individually, Defendant(s). SUPPLEMENTAL RESPONSE TO EPSTEIN'S REQUEST FOR PRODUCTION D

MBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually,

Fax: Attorneys for Scott Rothstein The L-S Law Firm 1441 Brickell Avenue, 15th Floor Miami, FL 33131 Phone: Fax Attorneys for Jeffrey Epstein Tonia Haddad Coleman. Esquire Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Phone: Fax: Attorneys ore rey Epstein EFTA00624847

reasonably calculated to lead to the discovery of admissible evidence. b. None. 6. All fee sharing agreements between Bradley J. Edwards, RRA, or Scott W. Rothstein and/or any other attorney or investor relating to any aspect of any Plaintiff's case. ANSWER: Objection, relevance, not reasonably calculated to l

ent to his cause of action. Moreover, discovery relating to Edwards's financial incentives to join RRA and to engage in conduct in cooperation with Rothstein in support of RRA's illicit activities is most certainly relevant to Edward's allegations in this case and Epstein's defense of the same. Accordingl

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/ 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 Hadd

reasonably calculated to lead to the discovery of admissible evidence. b. None. 6. All fee sharing agreements between Bradley J. Edwards, RRA, or Scott W. Rothstein and/or any other attorney or investor relating to any aspect of any Plaintiff's case. ANSWER: Objection, relevance, not reasonably calculated to l

nt to his causes of action. Moreover, discovery relating to Edwards's financial incentives to join RRA and to engage in conduct in cooperation with Rothstein in support of RRA's illicit activities is most certainly relevant to Edward's allegations in this case and Epstein's defense of the same. Accordingl

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/ 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 Hadd