Epstein Secrets

a timely response to our outstanding financial discovery requests and receipt by tomorrow of responses to our surveillance discovery. Sincerely, Jack Scarola Cc: Bradley Edwards, Esq. From: Fred Haddad a Sent: January 10, 2013 8:55 AM To: Tonja Haddad Coleman Cc: Ma E. Pirrotta• e e em; Subject: Re: E

2013 9:51 AM To: Ma E. Pirrotta Cc Subject: Re: EDWARDS ADV. EPSTEIN—SERVICE OF COURT DOCUMENTS - 502009CA040800)000(MBAG (File #: 291874) Mr. Scarola- I believe even you would have to concede that we are entitled, and even required, to file a timely response to your fourth amended counterclaim. As

notice that pursuant to Rule 1.340(e), Florida Rules of Civil Procedure, that Net Worth Interrogatories numbered 1 through 13 have been directed to Counterdefendant, JEFFREY EPSTEIN, this ti day of December, 2012. I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all Counse

t, BRADLEY J. EDWARDS, moves this Honorable Court to compel timely responses to his financial discovery requests and in support would show that the Counterdefendant, through counsel, in the email attached has expressed an intention to delay the provision of responses beyond the time provided by the applicable Ru

169440 E-mail: ndary E-mail(s): Searcy Denney Scarola art p ey, .A. 2139 Palm Beach Lakes Boulevard

notice that pursuant to Rule 1.340(e), Florida Rules of Civil Procedure, that Net Worth Interrogatories numbered 1 through 13 have been directed to Counterdefendant, JEFFREY EPSTEIN, this ti A clay of December, 2012. I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all Coun

ry, 2012. Jack Flori.: No.: 169440 Se• enney Scarola Barnhart & Shipley, P.A. 21.9 alm Beach Lakes Bo

ntiff, Bradley J. Edwards (hereinafter EDWARDS), by and throligh his undersigned attomeys, respectfully responds in opposition to Plan tiff/Counterdefendant, Jeffrey Epstein's (hereinafter EPSTELN) motion for a protective orde[ and to terminate his deposition. The motion is ffivolous and should be denied