7 Tonja Haddad, PA 5315 SE 71" Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 954.337.3716 (facsimile) Attorneys for Epstein 5 Tonja liaddad, P.A. • 315 SE 7m Street, Fort Lauderdale, FL 33301. 954.467.1223 EFTA00584584 SERVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Scarola

uary 27, 2014, this Honorable Court granted summary judgment in favor of Epstein on both counts. This Court entered an Order reflecting same on May Tonja Haddad, P.A. • 315 SE 7m Street, Fort Lauderdale, FL 33301. 954.467.1223 EFTA00584580 19, 2014. A true and correct copy of the Order is attached hereto a

at a true and correct copy of the foregoing was served, via electronic service, to all parties on the attached service list, this May 22, 2014. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 71" Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223

n's home. Impassible debris from numerous fallen buildings and trees throughout his home make it uninhabitable. Power outage and food and water 2 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301• 954.467.1223 EFTA00586085 shortages throughout the Virgin Islands have created widely report

ERTIFY that a true and correct copy of the foregoing was served upon all parties listed below, via Electronic Service, this September 27, 2017. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 LAW OFFICE OF TOUR HADDAD, PA 315 SE Th Street Suite 301 Fort Lauderdale, Florida 33301 954.4

Fort Lauderdale, Florida 33301 Fred Haddad, 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Tonja Haddad Coleman, Esquire Law Offices of Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Attorneys for Jeffrey Epstein W. Chester Brewer, Jr. One Clearlake Center Suite 14

g at 2:30. Fred is apparently available only in afternoon. He is one we need there. why dont we start at 2:00. I11 get there a little late and then Tonja you can leave when you have to >>> >>> >>> >>> Original Message From: Tonja Haddad Coleman [mail Sent: Friday, May 10, 2013 9:36 >>> To: Les

:58:29 +0000 Let me know what time to be there on Monday- thanks! I will try to push my 4:00 to 4:30 also. Tonja Haddad Coleman,Esq. Law Office of Tonja Haddad, PA 315 SE 7th Street Ft. Lauderdale, FL 33301 Sent from my iPhone .1 On May 10, 2013, at 9:55 AM, "Lesley Groff" wrote: > Terrific thanks. >

ffrey Epstein? Date: Fri, 10 May 2013 13:58:29 +0000 Let me know what time to be there on Monday- thanks! I will try to push my 4:00 to 4:30 also. Tonja Haddad Coleman,Esq. Law Office of Tonja Haddad, PA 315 SE 7th Street Ft. Lauderdale, FL 33301 Sent from my iPhone .1 On May 10, 2013, at 9:55 AM, "Lesley Groff

Lauderdale, Florida 33301 Fred Haddad, Esq. 1 Financial Plaza Suite 2612 Fort Lauderdale, FL 33301 Tonja Haddad Coleman, Esquire Law Offices of Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 W. Chester Brewer, Jr. W. Chester Brewer, Jr., P.A. 250 S. Australian Avenue Suite

at a true and correct copy of the foregoing was served, via electronic service, to all parties on the attached service list, this May 12, 2014. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 71° Street Suite 301 e, Florida 33301 (facsimile) Attorneys for E

copy of the foregoing was served, via electronic service, to all parties on the attached service list, this May 12, 2014. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 71° Street Suite 301 e, Florida 33301 (facsimile) Attorneys for Epstein 3 Tonja Hadda

e attached service list, via electronic service, this October 11, 2017. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 Tonja Haddad, PA 5315 SE 70, Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 954.337.3716 facsimile EFTA00582842 SERVICE LIST CASE NO. 50200

and correct copy of this Response was served on all parties listed on the attached service list, via electronic service, this October 11, 2017. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 Tonja Haddad, PA 5315 SE 70, Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 95

orida 33301 Fred Haddad, Esq. EFTA00582843 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Ton'a Haddad Coleman, Es uire Law Offices of Tonja Haddad, 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Attorneys for Jeffrey Epstein EFTA00582844

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

ay, May 29, 2012 9:37 AM » To: Tonja Haddad Coleman; haddadfm@aol; Jack Goldberger >> Cc: Darren Indyke; >> Subject: Jeffrey Epstein >> >> Hello Tonja, Fred and Jack. Jeffrey would like to have a conference >> call today with you all sometime between 12-2:30. Would 12:30 work for everyone? » If no

ote: >> Good morning- >> I am just heading back from my trip and will not be in today- will >> tomorrow work? >> >> Tonja Haddad Coleman, Esq. » Tonja Haddad, III. >> Justice Building >> 524 South Andrews Avenue >> Suite 200 North >> Fort Lauderdale, Florida 33301 >> (954) 467-1223 >> (954) 337-3716

Goldberger wrote: > Today not so great for me unless after 5pm • Original Message > From: [mailto: > Sent: Tuesday, May 29, 2012 9:58 AM > To: Tonja Haddad Coleman; > Cc: Jack Goldberger; Darren Indyke; > Subject: Re: Jeffrey Epstein > • I will find out..thanks.. > On May 29, 2012, at 9:53 AM, Tonja Haddad

of this and Jack and I are having a telephonic conference with Jeffery regarding same today or tomorrow. EFTA00411631 Tonja Haddad Coleman, Esq. Tonja Haddad, P.A. Justice Building 524 South Andrews Avenue Suite 200 North The information contained in this transmission may contain privileged and confid

We have already taken care of this and Jack and I are having a telephonic conference with Jeffery regarding same today or tomorrow. EFTA00411631 Tonja Haddad Coleman, Esq. Tonja Haddad, P.A. Justice Building 524 South Andrews Avenue Suite 200 North The information contained in this transmission may contain pr

rday and sent an email to Tonja and cc'd Jack and feed, asking if a call was Scheduled for today and If so what time and it sparked conversation ...Tonja emailed back saying she never did say there would be a conf call today and she is not available ... Then jack said he could do one today late but Mo

e and correct copy of the foregoing was served upon all parties listed below, via Electronic Service, this March 7, 2016. Is/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 LAW OFFICES OF TONJA HADDAD, PA 315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 954.337.37

delay by the first court, that warrant the denial of a stay. Thus, absent any such special circumstances, a trial court abuses its discretion in 2 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301• 954.467.1223 EFTA00611632 refusing to grant a stay based on the principle of priority." Spac

EBY CERTIFY that a true and correct copy of the foregoing was served upon all parties listed below, via Electronic Service, this March 7, 2016. Is/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 LAW OFFICES OF TONJA HADDAD, PA 315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 95

of the foregoing was served, via electronic service, to all parties on the attached service list, this October 14, 2013. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7ih Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 954.337.3716 (facsimil

Lauderdale, Florida 33301 Fred Haddad, Esq. 1 Financial Plaza Suite 2612 Fort Lauderdale, FL 33301 Tonja Haddad Coleman, Esquire Law Offices of Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Attorneys for Jeffrey Epstein EFTA00611768

, to all parties on the attached service list, this October 14, 2013. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7ih Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 954.337.3716 (facsimile) Attorneys for Epstein EFTA00611767 SER

s Motion was argued before this Court on January 27, 2014, at which time this Court, after extensive argument and review of all written submissions Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00613837 and case law, granted Epstein's Motion. Days later, Edwards filed a Motion for

copy of the foregoing was served, via electronic service, to all parties on the attached service list, this May II, 2014. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7'h Street Suite 301 Fort Lauderdale, Florida 33301 facsimile) Attorneys for Epstein 6

at a true and correct copy of the foregoing was served, via electronic service, to all parties on the attached service list, this May II, 2014. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7'h Street Suite 301 Fort Lauderdale, Florida 33301 facsimile) At

made in bad faith." Florida Gas Transmission Co. v. Lauderdale Sand & Fill. Inc., 813 So. 2d 1013,1014 (Fla. 4th DCA 2002). Accordingly, if the 2 Tonja Haddad, P.A. • 315 SE 70, Street, Fort Lauderdale, FL EFTA00584026 moving party satisfies the above requisites, the court has very limited discretion to

o accept Epstein's Offer. On January 27, 2014, this Honorable Court granted summary judgment in favor of Epstein on both counts. This Court entered Tonja Haddad, P.A. • 315 SE 70, Street, Fort Lauderdale, FL 33301 EFTA00584025 an Order reflecting same on February , 2014. A true and correct copy of the Or

FY that a true and correct copy of the foregoing was served, via electronic service, to all parties on the attached service list, this , 2014. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 6 Tonja Hadda

correct copy of the foregoing was served upon all parties listed below, via Electronic Service, this September 27, 2017. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 LAW OFFICE OF TOUR HADDAD, PA 315 SE Th Street Suite 301 Fort Lauderdale, Florida 33301 facsimile) 5 Tonja Haddad

n's home. Impassible debris from numerous fallen buildings and trees throughout his home make it uninhabitable. Power outage and food and water 2 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301• 954.467.1223 EFTA00584755 shortages throughout the Virgin Islands have created widely report

ERTIFY that a true and correct copy of the foregoing was served upon all parties listed below, via Electronic Service, this September 27, 2017. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 LAW OFFICE OF TOUR HADDAD, PA 315 SE Th Street Suite 301 Fort Lauderdale, Florida 33301 facsi

, 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

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

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

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

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

at a true and correct copy of the foregoing was served, via electronic service, to all parties on the attached service list, this June 2, 2014. /s/ Tonja Haddad Coleman Tonja Haddad Coleman Esq. Florida Bar No.: Tonja Haddad, PA 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 facsimile) Attorneys

2 Fort Lauderdale, Florida 33301 Fred Haddad Es I Financial Plaza Suite 2612 Fort Lauderdale, FL 33301 Ton'itHa dColeman uire Law Offices of Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 W. Chester Brewer, Jr. W. Chester Brewer, Jr., P.A. 250 S. Australian Avenue Suite

ct that throughout his defense of this action, Epstein maintained that he had no liability to Edwards and that Edwards's actions were barred by, 3 Tonja liaddad, PA. • 315 SE 7* Street, Fort Lauderdale, FL 33301• EFTA00805512 among other things, the litigation privilege. Accordingly, an award of a

From: Lesley Groff To: Tonja Haddad Coleman , Fred Haddad , Jack Goldberger Darren Indyk Cc: Jack GoIdb Subject: Re: 2:30 Monday w/Jeffrey Epstein? Date: Fri, 10 May 2013 13:55:10 +0000

"Lesley Groff" > wrote: >> >>> So, if I understand correctly, this means you are free to meet with Jeffrey on Monday at 2:30? >>> >>> Jack and Tonja, are you both still available to meet in Monday at 2:30 in PS at Jeffrey's home? >>> >>> Sent from my iPhone >>> >>> On May 10, 2013, at 9:03 AM

g at 2:30. Fred is apparently available only in afternoon. He is one we need there. why dont we start at 2:00. I11 get there a little late and then Tonja you can leave when you have to >> >> Original Message >> From: Tonja Haddad Coleman (mailto: >> Sent: Friday, May 10, 2013 9:36 AM >> To: Lesl

From: Lesley Groff < To: Tonja Haddad Coleman Indyke , Fred Hale, Jack Goldberger , Darren Cc: Jack Goldbe Subject: Re: 2:30 Monday w/Jeffrey Epstein? Date: Fri, 10 May 2013 17:20:32 +0000

rote: > Let me know what time to be there on Monday- thanks! I will try to push my 4:00 to 4:30 also. > Tonja Haddad Coleman,Esq. > Law Office of Tonja Haddad, PA > 315 SE 7th Street > Ft. Lauderdale, FL 33301 > Sent from my iPhone > On May 10, 2013, at 9:55 AM, "Lesley Groff" wrote: >> Terrific thank

ey Groff" wrote: >>>> >>>>> So, if I understand correctly, this means you are free to meet with Jeffrey on Monday at 2:30? >>>>> >>>>> Jack and Tonja, are you both still available to meet in Monday at 2:30 in PB at Jeffrey's home? >>>>> >>>>> Sent from my iPhone >>>>> >>>>> On May 10, 2013, at

ll happening? On Jul 19, 2012, at 3:46 PM, Darren Indyke > wrote: EFTA00552259 Please make sure that this is on JE's schedule for July 27, 2012. Tonja Haddad Coleman and Debbie Fein will be coming to JE's house in Palm Beach to meet with him at 1PM. Thanks. PLEASE NOTE THAT, EFFECTIVE JUNE 5. 2012, MY NEW CONTAC

reminder to JE and although JE did not respond saying the meeting was still on, JE did not tell to cancel, which is why confirmed the meeting with Tonja today. Then Tonja emailed me that both JE and got back to her. But of course, Tonja did not say what JE said when he got back to her today. Based

sent me an email this morning asking if the meeting is still on. Then, emailed me and phoned me to say that confirmed the meeting is still on with Tonja this morning. said that she sent a reminder to JE and although JE did not respond saying the meeting was still on, JE did not tell to cancel, whic

oldber er , Tonja Haddad .M.IMa , Fred Haddad Cc: Darren Indyke Subject: 1:30 Conf. Call THurs. Aug. 29th Date: The, 27 Aug 2013 18:54:30 +0000 Tonja, Fred and Darren are all available for a 1:30 call this Thursday Aug. 29th. I will double check with Jeffrey re 1:30 on Thurs, Jack, are you availab

From: Lesley Groff To: Jack Goldber er , Tonja Haddad .M.IMa , Fred Haddad Cc: Darren Indyke Subject: 1:30 Conf. Call THurs. Aug. 29th Date: The, 27 Aug 2013 18:54:30 +0000 Tonja, Fred and Darren ar

reserved. ********************************************* ******* tit ******** ** ******************************* Begin forwarded message: From: Tonja Haddad Coleman Date: August 27. 2013 2:51:27 PM EDT EFTA00384933 To: Darren Indyke < >, Jeffrey Epstein <[email protected]> Cc: Jack Goldberger < >, Fred