From: Tonja Haddad Coleman <I

From: Tonja Haddad Coleman <I To: Darren Indyke Cc: Jeffrey Epstein <[email protected]> Subject: Re: Edwards adv. Epstein: Please see attached letter from Jack Scamla, Esq. w/attached Supplemental Response to Request to Produce Date: Fri, 08 Jun 2012 19:56:31 +0000 I am away today so I will defer to you- what do you think? Did he answer all of the questions? Tonja Haddad Coleman, Esq. Sent from my iPhone On Jun 8, 2012, at 3:51 PM, Darren Indyke < > wrote: At the end of Scarola's cover letter he asks that upon review of the attached Supplemental Response to the Request to Produce, "pease inform us whether you intend to proceed with Monday's hearing." PLEASE NOTE THAT, EFFECTIVE JUNE 5, 2012, MY NEW CONTACT INFO WILL BE AS FOLLOWS: DARREN K. INDYKE DARREN K. INDYKE, PLLC 575 Lexington Avenue, 4th Floor, 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 K. Indyke, PLLC. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail, and destroy this communication and all copies thereof, including all attachments. Copyright of Darren K. Indyke, PLLC - m 2011 Darren K. Indyke, PLLC — All rights reserved. On Jun 8, 2012, at 3:26 PM, Tonja Haddad Coleman wrote: There is still the issue of the sanctions but I am sure we won't get them now. Do they ask me to cancel the hearing on Monday? EFTA00937503 Tonja Haddad Coleman, Esq. Sent from my iPhone On Jun 8, 2012, at 3:21 PM, Darren Indyke > wrote: So are you saying no hearing on Monday? PLEASE NOTE THAT, EFFECTIVE JUNE 5. 2012, MY NEW CONTACT INFO WILL BE AS FOLLOWS: DARREN K. INDYKE DARREN K. INDYKE, PLLC 575 Lexington Avenue, 4th Floor, New York, New York 10022 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 you have received this communication in error, please notify us immediately by return e-mail, and destroy this communication and all copies thereof, including all attachments. Copyright of Darren K. Indyke, PLLC - 2011 Darren K. Indyke, PLLC —All rights reserved. ***I'M*** On Jun 8, 2012, at 3:17 PM, Tonja Haddad Coleman wrote: I do not- I specifically said in a footnote that we would address the privilege/work product issue at a later time. I am sure we will have to brief the fact that there is not a privilege - much less work product- between a lawyer and a blogger! Tonja Haddad Coleman, Esq. Sent from my iPhone On Jun 8, 2012, at 3:11 PM, Darren Indyke <a wrote: In the attached Supplemental Response to the Request to Produce, Edwards's claims that other than what he already delivered and what he included on his privilege log he has no other documents in his possession, custody or control. Tonja, don't you still have to deal at the hearing with Edwards's bogus privilege claims (including work product) relating tc docs and the redactions on the docs he produced - e.g., email from George Rush? EFTA00937504 PLEASE NOTE THAT, EFFECTIVE JUNE 5. 2012, MY NEW CONTACT INFO WILL BE AS FOLLOWS: DARREN K. INDYKE DARREN K. INDYKE, PLLC 575 Lexington Avenue, 4th Floor, New York New York 10022 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 K. Indyke, PLLC. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail, and destroy this communication and all copies thereof, including all attachments. Copyright of Darren K. Indyke, PLLC - © 2011 Darren K. Indyke, PLLC —All rights reserved. Begin forwarded message: From: Tonja Haddad Coleman Date: June 8, 2012 2:26:09 PM EDT To: Darren Indyke c >, Debra Fein Subject: Fwd: Edwards adv. Epstein: Please see a ac to e er rom ac Scarola, Esq. w/attached Supplemental Response to Request to Produce Please see attached. I cannot open it on my phone. Tonja Haddad Coleman, Esq. Sent from my iPhone Begin forwarded message: From: "Mary E. Pirrotta" Date: June 8, 2012 2:19:4 To: " Subject: Edwards adv. Epstein: Please see attached letter from Jack Scarola, Esq. w/attached Supplemental Response to Request to Produce < Privileged and Confidential Electronic communication is not a secure mode of EFTA00937505 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. <Scanned File.PDF> EFTA00937506