EFTA00661568.pdf

From: Tonja Haddad Coleman -ta To: Jack Scarola CC: Brad Edwards "M Haddad "Jack Goldbe Subject: RE: Epstein Date: Mon, 22 Oct 2012 20:06:50 +0000 E. Pirrotta" , Fred Well lucky for us your opinion is in direct contravention with the law. You last court-ordered amendment, for example, required you to properly plead your allegation of damages. Are you conceding that you cannot provide any proof of damages, and that the most recent amendment to Paragraph 32 does not change the substance of your Counterclaim? If not, you can expect a notice from us setting Mr. Edwards's deposition for Tuesday, November 13. Tonja Haddad Coleman, Esq. TONJA HADDAD, P.A. Advocate Building 315 SE 7th Street Fort Lauderdale, FL 33301 facsimile 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. Original Message From: Jack Scarola [mailto Sent: Monday, October 22, 2012 2:19 PM To: Tonja Haddad Coleman Cc: Brad Edwards; Mary E. Pirrotta; Fred Haddad; Subject: Re: Epstein It is our position that none of the amendments altered the factual substance of the counterclaim. Jack Scarola SEARCY DENNEY SCAROLA BARNHART & SHIPLEY, P.A. On Oct 22, 2012, at 12:36 PM, "Tonja Haddad Coleman" <MMIMI > wrote: > Mr. Scarola: > First, the right to continue the deposition of your client was preserved at his initial deposition on March 23, EFTA00661568 2010. Next, your client's Counterclaim was not the subject of any of the questioning conducted at his initial deposition. Third, at the time of your client's deposition, you were only on the first of the four (4) drafts of your Counterclaim, which was initially filed on or about December 21, 2009 and amended on October 4, 2011, November 29, 2011, and May 21, 2012, respectively (after each successful Motion to Dismiss). > At this point of the litigation, your Counterclaim has been dismissed three (3) times for its deficiencies. If you are conceding that Mr. Edwards' Counterclaim has no merit and that he suffered none of the damages to which he refers therein, then file the appropriate Motion and there will be no need for the continuation of his deposition. Otherwise, please provide dates by the end of the day or we will unilaterally set same. > Tonja Haddad Coleman, Esq. > TONJA HADDAD, P.A. > Advocate Building > 315 SE 7th Street > Fort Lauderdale, FL 33301 facsimile > 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. > Original Message > From: Jack Scarola [mailto: > Sent: Monday, October 22, 2012 10:56 AM > To: Tonja Haddad Coleman > Cc: Brad Edwards; Mary E. Pirrotta; Fred Haddad > Subject: Epstein > Our counterclaim had been filed for months prior to Mr. Edwards' deposition. The desire to redepose him regarding the counterclaim does not justify a second deposition. > In the absence of some reasonable basis for a second deposition, we will not produce Mr. Edwards voluntarily. > Jack Scarola > SEARCY DENNEY SCAROLA BARNHART & SHIPLEY, P.A. 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. 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. EFTA00661569 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. 52510- 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 ou received this communication in error, please notify the sender immediately by e-mail or by telephone at and destroy all copies of the original message. Thank you. EFTA00661570