EFTA00641925.pdf

From: "Tonja Haddad Coleman" To: "'Jack Scarola"' Cc: "'Mary E. Pirrotta"' "'Jack Goldberger" Ma "'Brad Edwards"' "'Lilly AnnSanchez"' Subject: RE: Edwards, Bradley adv. Epstein (File #: 291874) Date: Wed, 08 Aug 2012 15:49:27 +0000 Mr. Scarola- First, Paragraph 13 clearly and unequivocally states "[a]ll e-mails, data, correspondence, and similar documents dated April 1, 2008 through August 1, 2010 ..." As such, you are neither in a position to change Mr. Epstein's Request for Production nor the Court's Order granting same. Next, you misplace your reliance on the following statement: "the new log concerns emails, all [sic] which were sent/received subsequent to Bradley Edwards leaving RRA and thus could not be relevant to whether Mr. Edwards "abused process" while at RRA in furtherance of a Ponzi scheme about which he knew nothing." The allegations of "abused process" against Mr. Edwards in this case are not simply premised upon the Ponzi scheme. Finally, we will wait until the end of the day to file our Motion to Compel and for Sanctions for your failure to abide by the simple instruction from the Court (although we never received a final edit of the submitted Order from you), to afford you the opportunity to comply with all of Paragraph 13. Tonja Haddad Coleman, Esq. TONJA HADDAD, P.A. Justice Building 524 South Andrews Avenue Suite 200 North Fort Lauderdale, Florida 33301 facsimile www.tomahaddadpa.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 [mailto: Sent: Wednesday, August 08, 2012 11:16 AM To: < Cc: Mary E. Pirrotta; Jack Goldberger; Brad Edwards; Lilly AnnSanchez Subject: Re: Edwards, Bradley adv. Epstein (File #: 291874) Dear Ms. Coleman: The privilege log we just produced and veiich was previously filed in connection with the 'Paragrah 13 production request" was prepared subsequent to the Order indicating that our eadier log did not comply with TIG. This one does comply. The new log concerns entails. all which were sentfreceived subsequent to Bradley Edwards leaving RRA and thus could not be relevant to whether h4. Edwards 'abused process' while at RRA in furtherance of a Ponzi scheme about which he knew nothing. You contr,ue to want to revisit the old log. which the Court has determined did not need to be revisited, but if you want to try yet again, my assistant will accommodate your request to schedule a hearing. EFTA00641925 On Aug 8, 2012, at 10:12 AM, "Tonja Haddad Coleman" c cIIIIIIIIIIIIIIIIIIII wrote: Please see attached. Tonja Haddad Coleman, Esq. TONJA HADDAD, PA. Justice Building 524 South Andrews Avenue Suite 200 North Fort Lauderdale, Florida 33301 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. *" eSafe scanned this email for malicious content "* *** IMPORTANT: Do not open attachments from unrecognized senders <Discovery Letter.PDF> Privileged and Confidential 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. It 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. EFTA00641926