Epstein Secrets

Department prior to the deposition of Detective Recarey. 128. Photographs of all persons listed on Vict

to Jeffrey Epstein. 126. Jeffrey Epstein criminal records. 127. All documents produced by Palm Beach Police Department prior to the deposition of Detective Recarey. 128. Photographs of all persons listed on Victims' Witness Lists Edwards is the only alleged victim in this case. 10 Tonja Haddad, P.A. • 315 S

r, RRA's Ponzi Scheme: 2. 21 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00585440 3. 4. 5. 6. 7. • 8. Detective Joseph Recarey 9. Chief Michael Reiter 10. John Connolly II. Charles Lichtman, Esquire 12. Antonio Figueroa (Tony) 13. Records Custodian of Palm Beach Police D

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

Haddad. P.A. • 315 SE 7th Street, Fort Lauderdale, FL 3330I• 954.467.1223 EFTA00799415 Counsel for Epstein then examines Edwards regarding Officer Recarey: Q: What was the purpose of your conversation? Transcript of Deposition dated March 23, 2010, page 288; line 13-14. MR. SCAROLA: To the extent tha

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

s is protected by a privilege. I instruct him not to answer. Id. at page 287; line 3-6. Counsel for Epstein then examines Edwards regarding Officer Recarey: Q: What was the purpose of your conversation? Transcript of Deposition dated 14 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301

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

rey Epstein's home: 358 El Brillo Way, Palm Beach FL 33480 127. All documents produced by Palm Beach Police Department prior to the deposition of Detective Recarey 128. Photographs of all persons listed on Victims' Witness Lists 129. Statements, deposition transcripts, videotaped depositions and transcripts

Department prior to the deposition of Detective Recarey 128. Photographs of all persons listed on Victi

rue and correct copy of the foregoing was served, via electronic service, to all parties on the attached service list, this September 27, 2013. Is/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Ton'a Haddad, PA (facsimile) Attorneys for Epstein EFTA00598340 SERVICE LIST CASE NO. 502

f the foregoing was served, via electronic service, to all parties on the attached service list, this September 27, 2013. Is/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Ton'a Haddad, PA (facsimile) Attorneys for Epstein EFTA00598340 SERVICE LIST CASE NO. 502009CA040800XXXXMBAG J

PA Marc Nurik, Esq. Brac lwards, E . Farmer Jaffe Weissing Edwards Fistos Lehrman Fred Haddad, Es Tonja Haddad Coleman, Esquire Law Offices of Tonja Haddad, P.A. EFTA00598341

as contacted by- s9m~body vih9 was still in touch with Epstein. That person told her she would be compensated if she ·didn't cooperate with_ police, Rgcarey's report says. Those https//yM'Y'.,P.a.lm_b:~i3c:(1gailyn_~ws.c:oily<!rt]cJe/20Q60729/~EWS/.1 fl091757~ CA/ Aronberg-000162 FILED: PALM BEACH COUN

research. 1 I By th~n, r~fo.ti'ons betwe~JJ. police and. pro~ecutors were fraying; At a key meeting: with prosecutors and· the defense, Detective Joseph R.ecarey, the le_ad iny~stigatqr, w::1.s a,no·-~how, according to Epstein's attorney. "The elllbar.rassnient on the prosecutor's face was evident when the p

man said she was told. Fh 1one records 1·· . •. show the woman talked with the person who allegedly:intimiaat~g her:around the tin;te she :said, .Recarey reported. Phone records. also s_how that. the person said to have made the threat: then place·d a eali to Epstein's personal assistant, who iil tur

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

riety of Edwards' actions. 10. Detective Joseph Recarey Palm Beach Police Department 345 South County R

being prosecuted by Edwards at the time, including on the issue of punitive damages. Will confirm the propriety of Edwards' actions. 10. Detective Joseph Recarey Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 2-3 Expected to testify about the malicious prosecution elements of absen

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

during their research. By theni relations between police and prosecutors were fraying. At a key meeting with prosecutors and the defensei Detective Joseph Recarey, the lead investigator, was a no-showi according to Epstein's attorney. "The embarrassment on the prosecutor's face was evident when the police off

sment on the prosecutor's face was evident when the police officer never showed up for the meeting/' attorney Jack Goldberger said. Later in Aprili Recarey walked into a prosecutor's office at the state attorney's office and learned the case was taking an unexpected turn. The prosecutori Lanna Belohlav

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