From: Tonja Haddad Coleman

From: Tonja Haddad Coleman To: Sigrid McCawle CC: Jack Scarola Subject: Re: Epstein Date: Tue, 26 Sep 2017 21:00:59 +0000 Chester Brewer Hello- Thank you for your response. However, I am not the attorney who will be taking that deposition, and I have been informed that due to your last email, the date no longer works for us. Please either you or Mr. Pottinger provide alternate dates. Thank you. Tonja Haddad Coleman, Esq. Tonja Haddad, PA Advocate Building 315 SE 7th Street Suite 301 Fort Lauderdale, FL 33301 On Sep 26, 2017, at 4:21 PM, Sigrid McCawley wrote: Hello Tonja, I understand your position. We can proceed with the deposition as scheduled on October 5, 2017. If it is easier for you to take the deposition in our NY office, we are happy to accommodate. Thank you, Sigrid Sigrid McCawley Partner BOIES SCHILLER FLEXNER LLP 401 E. Las Olas Blvd. Suite 1200 Fort Lauderdale, FL, 33301 (t) (m www. s p.com From: Tonja Haddad Coleman [I Sent: Tuesday, September 26, 2017 2:41 PM To: Sigrid McCawley; Jack Scarola Cc: Brad Edwards; Chester Brewer; EFTA01003719 Subject: RE: Epstein Importance: High Hi Sigrid- At your request, we have postponed deposition while you reconsider the specific nature and extent of the confidential treatment, if any, you would be seeking. In that regard, we note that has been very public about her allegations against Mr. Epstein and others. Moreover, she is Mr. Edwards's client and is identified on his witness list, and her allegations have been featuredprominently in Mr. Edwards's pleadings throughout this case, which we assume was with her permission. Use o deposition testimony, whether in pre-trial motions or at trial, would be unnecessarily complicated by a confidentiality order. As we are a week away from her deposition, which was scheduled over a month ago, we are unable to agree to confidential treatment under the circumstances. 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: Sigrid McCawley [- Sent: Tuesday, September 26, 2017 12:46 PM To: Tonja Haddad Coleman < ; Jack Scarola Cc: Brad Edwards ; Chester Brewer Subject: RE: Epstein Hello Tonja, Boies Schiller will be representing as a non-party witness at her deposition in this action. As testimony may implicate sensitive issues o we are requesting your agreement that the deposition will be designated as confidential and subject to an agreed protective order confirming its confidential treatment. Please confirm that you are agreeable, because if you are not, then we will need to postpone the deposition to seek a Court order with respect to the confidential nature of the deposition. Finally, we are happy to host the deposition at our office in Manhattan if that is more convenient for you. Thank you, Sigrid Sigrid McCawley Partner BOIES SCHILLER FLEXNER LLP EFTA01003720 401 E. Las Olas Blvd. Suite 1200 3301 (t) (m) •asrup. From: Tonja Haddad Coleman Sent: Saturday, September 23, To: Jack Scarota Cc: Brad Edwards; Sigrid McCawley; Chester Brewer Subject: Re: Epstein Yes it was I am sorry- we were working on scheduling around one of the three dates you gave us. Mr. Brewers office is preparing the notices Tonja Haddad Coleman, Esq. Tonja Haddad, PA Advocate Building 315 SE 7th Street Suite 301 Fort Lauderdale, FL 33301 On Sep 23, 2017, at 1:42 PM, Jack Scarola < wrote: Tonja- I assume that my omission from the email copied below was inadvertent, but please be sure I am promptly provided with the NOTICE OF DEPOSITION , which I have not yet received. Begin forwarded message: From: Tonja Haddad Coleman Date: September 18 2017 at 1: 7:14 PM EDT To: Brad Edwards < Cc: ' Subject: Gentlemen- This will confirm that eposil yard on October 5, 2017 in NYC and that Mr. Epstein will pay for (and only travel ex enses. Formal notice to follow. Brad, I also checked my records and I do not believe that has ever been deposed in any case involving Mr. Epstein. If I am wrong, can you or Mr. Pottinger kindly provide me with a copy of same, or at least the style of the case to which you are referring so that we may include a "Schedule A" to her deposition notice requesting copies of same? Thank you both for your cooperation in this matter. Tonja Haddad Coleman, Esq. Tonja Haddad, P.A. Advocate Building 315 SE 7th Street, Suite 301 Fort Lauderdale FL 33301 EFTA01003721 direct dial facsimile www.TonjaHaddad.com ** 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. 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If the reader of this electronic message is not the named recipient. or the employee or agent responsible to deliver it to the named recipient. you are hereby notified that any dissemination. distribution. copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error. please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. (v.11 The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that, among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient. you are hereby notified that any dissemination, distribution. copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error. please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. (v.11 EFTA01003722