Epstein Secrets

Jeffrey Epstein? Id. at page 101-102; line 24-6. MR. SCAROLA: Same objection and instruction. Id. at page 102; line?-8. Q: Did you ever speak with Marie Villafana during, during the pendency of that litigation which is still pending today? Transcript of Deposition dated March 23, 2010, page 102-03; line 24-1.

dad, P.A. • 315 SE 7'h Street, Fort Lauderdale, FL 3330I• 954.467.1223 EFTA00799406 Q: So, even if; do you — even if you talked about it with Mrs. Villafana, even if your client Mr. Edwards spoke with Mrs. Villafana about a scheduling issue, it's your position that that is what, work-product? Id. at pag

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

Jeffrey Epstein? Id. at page 101-102; line 24-6. MR. SCAROLA: Same objection and instruction. Id. at page 102; line?-8. Q: Did you ever speak with Marie Villafana during, during the pendency of that litigation which is still pending today? Transcript of Deposition dated March 23, 2010, page 102-03; line 24-1.

ction remains the same. The objection remains the same. Id. at page 103; line 14-16.4 Q: So, even if; do you — even if you talked about it with Mrs. Villafana, even if 'The objection is: "If that is information that you obtained in the course of your responsibilities in representation of any client I woul

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

NEY Dated: Dated: Dated: Dated: By: A. MARIE VILLAFANA ASSISTANT U.S. ATTORNEY JEFFREY EPSTEIN GERALD

ATTORNEY Dated: Dated: Dated: Dated: By: A. MARIE VILLAFANA ASSISTANT U.S. ATTORNEY JEFFREY EPSTEIN GERALD

n- Prosecution Agreement and agrees to comply with them. R. ALEXANDER ACOSTA UNITED STATES ATTORNEY Dated: By: Dated: 6/UT'( Dated: Dated: A. MARIE VILLAFAIZIA ASSISTANT U.S. ATTORNEY GERALD LEFCOURT, ESQ. COUNSEL TO JEFFREY EPSTEIN LILLY ANN SANCHEZ, ESQ. ATTORNEY FOR JEFFREY EPSTEIN Page 7 of 7 A10

t. Lauderdale FL 33301 Counsel for Defendant Scott Rothstein Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards 2 A19 EFTA00798185 Tonja Haddad Coleman Fred Haddad 315 S.E. Seventh Street, Suite 301 Haddad & Navarro, PLLC Ft. Lauderdale, FL 33301 1 Financial Plaza, Suite 2612 Fort Lauderdale FL

E., SUITE 2 FT. LAUDERDALE, FL 33301 73. Maria Villafana 500 S. Australian Avenue, #400 West Palm Beach,

Seth Lehrman 425 N ANDREWS AVE., SUITE 2 FT. LAUDERDALE, FL 33301 72 Matt Weissing 425 N ANDREWS AVE., SUITE 2 FT. LAUDERDALE, FL 33301 73. Maria Villafana 500 S. Australian Avenue, #400 West Palm Beach, FL 33401. Will also confirm the leadership role played by Edwards in the prosecution of civil clai

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

e counsel in this matter.” Marra quoted an equally pleasant note then-Palm Beach County State Attorney Barry Krischer sent to Assistant U.S. Attorney Marie Villafana, who was the lead prosecutor in Epstein’s case. “Glad we could get this worked out for reasons: I won’t put in writing,” Krischer wrote, shortly afte

at were exchanged dealt with prosecutors’ and Epstein’s lawyers’ shared desire to keep the deal secret from Epstein’s accusers. In a September email, Villafana asked Lefkowitz for guidance about what she should reveal. “And can wehave a conference call to discuss what I may disclose to ... the girls regardin

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

ounsel in this matter." Marra quoted an equally pleasant note then-Palm Beach County State Attorney Barry Krischer sent to Assistant U.S. Attorney Marie Villafana, who was the lead prosecutor in Epstein's case. "Glad we could get this worked out for reasons I won't put in writing," Krischer wrote, shortly af

were exchanged dealt with prosecutors' and Epstein's lawyers' shared desire to keep the deal secret from Epstein's accusers. In a September email, Villafana asked Lefkowitz for guidance about what she should reveal. "And can we have a conference call to discuss what I may disclose to ... the girls regar

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

12 13 14 15 16 17 18 19 20 21 22 23 24 25 Judge, next we're at page 11. The subject matter turns to Mr. Edwards' communications with Maria Villafana, who is the United States attorney -- assistant United States attorney involved in the Epstein cases. Question: My question is only did you spea

- what specifically are the questions that you believe need to be answered? Discussions that Mr. Edwards may have had with respect to or with Ms. Villafana, the U.S. attorney, I don't know what that has to do with this particular case, other than to suggest that if in fact Mr. Edwards was pursuing th

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

if she had any questions for the agents or AUSA Villafana. [LM] responded: A. No, but I hope — I hope Jeff

Lauderdale, Florida 33301 Fred Haddad, Es . 1 Financial Plaza Suite 2612 Fort Lauderdale, FL 33301 Toria Haddad Coleman, Es uire Law Offices of Tonja Haddad, 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Attorneys for Jeffrey Epstein 30 EFTA00583981

: (954)-745-5849 Attorneys for Jeffrey Epstein Fax: (954)-745-3556 Attorneys for Scott Rothstein Jack A. Goldberger, Esquire [email protected]; Tonja Haddad Coleman, Esquire [email protected] [email protected]; Atterbury, Goldberger & Weiss, P.A. [email protected]; 250 Australian Avenue South, Suite 140

Atterbury, Goldberger & Weiss, P.A. [email protected]; 250 Australian Avenue South, Suite 1400 [email protected] West Palm Beach, FL 33401 Tonja Haddad, P.A. Phone: (561)-659-8300 315 SE 7th Street, Suite 301 Fax: (561)-835-869 1 Fort Lauderdale, FL 33301 Attomeys for Jeffrey Epstein Phone: (954)-467

s and the United States Prosecutors in a jgint attempt to minimize Epstein's civil exposure. For example, on October 3, 2007, Assistant U.S. Attorney Marie Villafafia sent an email (attached hereto as Exhibit “D’’) to Jay Lefkowitz, counsel for Epstein, with attached proposed letter to special master regarding hand