TONJA HADDAD PA

TONJA HADDAD PA September 26. 2013 Via Electronic Mail Jack Scarola, Esq. Searcy Denney et al. Re: Epstein v. Edwards et ed. Mr. Scarola: As discussed, the items listed below (numbered as they appear on your exhibit list) were never provided to us during discovery in this matter. Please advise if you agree that you will not use this substantial (and irrelevant) list of items, or if we need to address it in our Motion in Limine. Back on April 23, 2013, you were served with the following request as listed on Schedule A to Brad's deposition notice: 12. Copies of any and all documents you intend to introduce at trial in support of the allegations made by you in your Fourth Amended Counterclaim you filed in this matter. At the hearing on your Motion for Protective Order on June 10, 2013, you told the judge specifically that you were providing all items responsive to that request. 7 The last one is copies of any and all 8 documents you intend to introduce at trial in 9 support of the allegations made by you in the to fourth amended counterclaim. Again, we are 11 giving them all the evidence that we intend to 12 rely upon. See Transcript ofJune 10. 2013 hearing, p. 27, which is attached to this letter. 4. 9. II. 12. Video of Jeffrey Epstein's home and route from victim to Epstein's home Documents related to Jeffrey Epstein produced by Alfredo Rodriguez Jeffrey Epstein phone records 1 phone records EFTA01099380 15. All probable cause affidavits related to criminal investigation of Jeffrey Epstein 16. All evidence, information and documents taken or possessed by FBI related to criminal investigation of Jeffrey Epstein 17. Victims' statements to the FBI related to criminal investigation of Jeffrey Epstein 18. Video of Search Warrant of Jeffrey Epstein's home being executed 19. Application for Search Warrant of Jeffrey Epstein's home 27. Yearbooks of Jane Doe 28. 2002 Royal Palm Beach High School Year Book 29. 2001 Royal Palm Beach High School Year Book 30. 2003 Palm Beach Gardens High School Year Book 31. Affidavit and Application for Search Warrant on Jeffrey Epstein's home 32. Tape recording or transcript of recording of conversation between Jeffrey Epstein and George Rush 33. Notepads found in Jeffrey Epstein's home and/or during trash pulls outside of his home during criminal investigation 39. All statements made by Jeffrey Epstein 40. List of properties and vehicles in Larry Visoski's name 50. Video footage (DVD) of walk through site inspection of Jeffrey Epstein's home. 51. Photos of all of Jeffrey Epstein's properties, cars, boats and planes 52. Probable Cause Affidavits prepared against Jeffrey Epstein and 53. Audio tape of 54. Photographs, videos and books taken in the search warrant of Jeffrey Epstein's home 55. Documents related to or evidencing Jeffrey Epstein's donations to law enforcement EFTA01099381 56. Victim Notification Letter from US Attorney's Office to Victim 57. Expert Dr. L. Dennison Reed's Report of Victim 59. All reports and documentation generated by Palm Beach Police Department related to Jeffrey Epstein 60. All Witness Statements generated by Palm Beach Police Department relating to Jeffrey Epstein 61. Passenger Manifests of Jeffrey Epstein's aircraft and private plane flight logs 62. Passenger lists for flights taken by Jeffrey Epstein 63. Letter from Jeffrey Epstein to Alberto Pinto regarding house island project 65. MC2 emails involving communications of Jeffrey Epstein, Jeff Puller, Pappas Suat, Jean Luc Brunel and Amanda Grant 68. Massage Table 69. Lotions taken from Jeffrey Epstein's home during search warrant 70. Computers taken from Jeffrey Epstein's home during search warrant 71. Vibrators, dildos and other sex toys taken from Jeffrey Epstein's home during search warrant 77. 80. Letter from Chief' 82. 83. CAD calls to 358 El Brillo Way, Palm Beach FL 33480 to Letter from Guy Fronstin to Assistant State Attorney dated 1-11-06 Letter from Guy Fronstin to Assistant State Attorney dated 1-13-06 84. Letter from Guy Fronstin to Assistant State Attorney dated 2-17-06 85. Letter from Guy Fronstin to Assistant State Attorney dated 4-6-06 86. Letter from Guy Fronstin to Assistant State Attorney dated 410-06 87. Letter from Goldberger dated 6-22-06 EFTA01099382 88. All subpoenas issued to State Grand Jury 89. Documents related to the rental of a vehicle for 90. Ted's Sheds Documents 91. Documents related to property searches of Jeffrey Epstein's properties 92. Arrest Warrant of 93. Police report regarding icking up money dated 11-28-04 94. List of Trilateral Commission Members of 2003 96. Guy Fronstin letter dated 4-17-06 100. Victim's GED testing information and results 101. JEGE, Inc. Passenger Manifest 102. Hyperion Air Passenger Manifest 103. Flight information for 104. Passenger List Palm Beach flights 2005 105. Jeffrey Epstein notepad notes 108. letter to dated 5-1-06 110. Police Report dated 11-28-04 Ill. Compulsory Medial Examination of victim, CMA 112. Victim's school records and transcripts 113. Victim Notification letter dated 7-9-08 114. Victim's employment records from IHOP 115. Police report of Juan Alessi theft at Jeffrey Epstein's home 116. Victim's Medical Records from Milton Girls Juvenile Facility 117. Victim's Medical Records from Dr. Randee Speciale EFTA01099383 118. Victim's Medical Records from Wellington Regional Hospital 119. Victim's Medical Records from St. Mary's Medical Center 120. Victim's Medical Records from United Health 121. All surveillance conducted by law enforcement on Jeffrey Epstein's home 122. Emails received from Palm Beach Records related to Jeffrey Epstein 123. All items listed on the Palm Beach Police Property Report Lists 124. All items taken in the execution of the search warrant of Jeffrey Epstein's home: 358 El Brillo Way, Palm Beach FL 33480 127. All documents produced by Palm Beach Police Department prior to the deposition of Detective Recarey 128. Photographs of all persons listed on Victims' Witness Lists 129. Statements, deposition transcripts, videotaped depositions and transcripts taken in connection with this and all related cases and exhibits thereto 130. Any and all expert witness reports and/or records generated in preparation for this litigation by any party to this cause 132. Curriculum vitae of Dr. Ryan Hall 133. Any articles or publications of Dr. Ryan Hall 134. Any articles or publications of Dr. Richard Hall 135. Any articles or publications of Dr. L. Dennison Reed 136. All items and documentation review by Dr. L. Dennison Reed 137. Transcript and video (DVD) of IME of Victims 138. All exhibits to Dr. L. Demlison Reed's Deposition 139. All exhibits to Dr. Richard Hall's Deposition 140. All items and documents reviewed by Dr. Richard Hall 141. All items and documents reviewed by Dr. Ryan Hall EFTA01099384 142. Demonstrative aids and exhibits including, but not limited to, anatomical charts, diagrams and models, surveys, photographs and similar material including blow-ups of the foresaid items.- 143. Any and all mortality tables By notifying you of this defect pursuant to our requirement that we try to resolve discovery issues before we bring them before the court, we are in no way agreeing to their validity, relevancy, or admissibility in any way. We are further not waiving the right to assert any and all objections to these items as permitted by law. Sincerely, TONJA HADDAD, II cc: Parties on Service List Tonja Haddad Coleman for the firm EFTA01099385 27 1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I skipped over number 9, copies of any and all receipts, reports, invoices or other documents evidencing treatment for your mental anguish, embarrassment, anxiety, as alleged in your counterclaim, there has been no formal treatment, we have already told them none. The last one is copies of any and all documents you intend to introduce at trial in support of the allegations made by you in the fourth amended counterclaim. Again, we are giving them all the evidence that we intend to rely upon. So the motion for protective order is directed principally to number 1, number 2, number 3, number 4, as it relates to anything other than attorney's fees awards for Bradley Edwards, and number 5 and the partnership agreement in number 6. So, understanding what we are claiming and the fact that they are entitled to test our claim, the answer to the question Your Honor asks is, yes, they are entitled to test our claim that this is the amount of time that Brad Edwards devoted to the defense of this case, but they haven't asked for anything that WWW.USLEGALSUPPORT.COM EFTA01099386