From: Darren Indyke <

From: Darren Indyke < To: Jeffrey Epstein <[email protected]> Subject: Fwd: Edwards adv. Epstein Date: Fri, 01 Jun 2012 MA:09 +0000 Darren'. Indyke Darren . Indyke, PLLC 301 East 66th Street, 10B New York, New York 10065 Telephone: (212) 517-2052 Direct: Fax: (212) 517-7779 email: The information contained in this communication is confidential, may be attorney-client privileged, and is intended only for the use of the addressee. It is the property of Darren I. Indyke, PLLC. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If ou have received this communication in error, please notify us immediately by return , and destroy this communication and all copies thereof, including all attachments. Copyright of Darren I. Indyke, PLLC - © 2011 Darren I. Indyke, PLLC - All rights reserved. Begin forwarded message: From: "Tonja Haddad Coleman" <a Date: June 1, 2012 10:21:57 AM EDT To: "'Mary E. Pirrotta'" Cc: "'Jack Scarola"' < Subject: RE: Edwards adv. E stein Reply-To: Mr. Scarola: "'Brad Edwards - When responding to a Request for Production, one is required to put, in writing (not in an insulting email), a proper response; to wit: 1) that the documents responsive to the request are provided; 2) state an objection and the grounds therefor (including providing a privilege log, etc.); 3) state that no such documents responsive to the request exist. As quoted in our Motions to Compel and for Sanctions, failure to provide a complete response is deemed non-responsive by the courts. We could obviate the need for the hearing on June 11- and the sarcasm from you- by your simple compliance with the Rules and years of precedent-setting jurisprudence. As such, please put, in writing, a response to the following request as Court-ordered. I will break it down for you: Are there any e-mails, data, correspondence, and similar documents dated April 1, 2008 through August 1, 2010 that mention Mr. Epstein between (meaning to or from) Bradley J. Edwards and any of the following PROT0 people? a) Scott W. Rothstein (no response yet) b) Marc Nurik (no response yet) c) Cam Holmes (no response yet) d) Mike Fisten (no response yet) e) the U.S. Attorney's Office (no response yet) f) the State Attorney's Office (no response yet) g) the Federal Bureau of Investigation (no response yet) h) '(you have provided some responses to this request) i) any other news employees or reporters (you have provided some responses to this as well). Please respond by either providing the documents, objecting and citing therein the proper reasons and/or privilege asserted with the accompanying log, or stating that no such documents exist. Tonja Haddad Coleman, Esq. TONJA HADDAD, P.A. Justice Building 524 South Andrews Avenue Suite 200 North Fort Lauderdale, Florida 33301 (954) 467-1223 (954) 337-3716 facsimile www.tonjahaddadpa.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. PROT1