EFTA01003639.pdf

From: Tonja Haddad Coleman To: Jack Scarola CC: Mary McCann < . Maria Kclljchian Fred Haddad , jgoldberger Goldberger Subject: RE: Epstein v. Edwards Date: Tue, 26 Sep 2017 18:46:12 +0000 Importance: high Mr. Scarola: On our witness list we listed two attorneys-as possible rebuttal witnesses- to address whether, based on the information known at the time, there was probable cause for Epstein to file suit against Edwards and Rothstein. As much as you would like to make this a criminal case, it is not. These witnesses are listed as possible witnesses, depending on your case in chief - to establish probable cause. That is all. Additionally, we are still awaiting dates on which you are available for us to depose Fisten, Jenne, Tatum, Corte and Villegas. Please advise. Tonja Haddad Coleman, Esq. TONJA HADDAD, P.A. Advocate Building 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 direct dial facsimile www.TonjaHaddad.com The information contained in this transmission may contain privileged and confidential information. It is intended only for the use of the person(s) named above. If you are not the intended recipient, you are hereby notified that any review, dissemination, distribution or duplication of this communication is strictly prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. From: Jack Scarola [mailtc Sent: Tuesday, September 26, 2017 12:54 PM To: Tonja Haddad Coleman Cc: Mary McCann ; Fred Haddad ; jgoldberger Goldberger Subject: Re: Epstein v. Edwards May I please have a response to the below email. Is your client intending to waive attorney-client privilege to enable us to depose his listed trial witnesses and others with information relevant to any testimony they may present? On Sep 20, 2017, at 8:30 PM, Jack Scarola wrote: EFTA01003639 The notices of deposition referenced in your email were sent in direct response to your having listed two of Epstein's attorneys as trial witnesses. As communicated in letters to each of the subpoenaed witnesses, the dates chosen for the depositions will be adjusted to suit their schedules to the extent that can be done within the discovery limitations imposed by the Court. More significantly, they were also told that there would be no need to depose any of them if Epstein continues to assert the protection of the attorney-client privilege. However, he (and you) cannot attempt to call Epstein's lawyers to testify on his behalf while restricting our right to full and complete cross-examination. Which do you choose? On Sep 20, 2017, at 9:03 AM, Tonja Haddad Coleman t ) wrote: Mr. Scarola: I am in receipt of your notices regarding your intent to serve subpoenas duces tecum to non-parties, as well as your deposition notices for them. All of the non-parties you intend to serve either are currently or were attorneys of my client and have represented him in connection with matters arising out of state and federal criminal prosecutions/investigations against him. Although I will formally address these issues with the Court, I am sure you must know that you are seeking irrelevant information that is undeniably privileged. As such, I offer you the opportunity to withdraw these notices before we bring this before the Court. Additionally, you failed to clear any of these dates or times with my office, or the offices of my co-counsel before unilaterally noticing them. As you well know, yesterday we requested dates to depose five more witnesses; to wit: Mike Fisten, Ken Jenne, William Corte, and Debra Villegas. Acceptable deposition dates for these individuals must be part of any deposition schedule to which we ultimately agree. Accordingly, please provide dates on which you are available for these depositions. Tonja Haddad Coleman, Esq. TONJA HADDAD, P.A. Advocate Building 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 direct dial facsimile www.TonjaHaddad.com The information contained in this transmission may contain privileged and confidential information. It is intended only for the use of the person(s) named above. If you are not the intended recipient, you are hereby notified that any review, dissemination, distribution or duplication of this communication is strictly prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. I Privileged and Confidential I Electronic communication is not a secure mode of communication and may be accessed by unauthorized persons. This communication originates from the law firm of Searcy Denney Scarola Barnhart & Shipley, P.A. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. S2510- 2521. The information contained in this E-mail message is privileged and confidential under Fla. R. Jud. Admin. 2.420 and information intended only for the use of the individual(s) named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, or copy of this communication is strictly prohibited. Personal messages express views solely of the sender and shall not be attributed to the law firm. If you received this communication in error, please notify the sender immediately by e-mail or by telephone at (800) 780-8607 and destroy all copies of the original message. Thank you. EFTA01003640