EFTA00712160.pdf

From: "Tonja Haddad Coleman" To: "'Mary E. Pirrotta"' Cc: "'Jack Scarola'" Subject: RE: Edwards, Bradley adv. Epstein (File #: 291874) Date: Thu, 09 Aug 2012 14:07:45 +0000 Attachments: Notice of Hearing.PDF >, "'Jack Goldberger'" Please see attached. Tonja Haddad Coleman, Esq. TONJA HADDAD, P.A. Justice Building 524 South Andrews Avenue Suite 200 North Fort Lauderdale, Florida 33301 a acsimile 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: Mary E. Pirrotta [mailto: Sent: Thursday. August 09. 2012 10:00 AM To: Cc: lack Scarola; Subject: RE: Edwards, Bradley adv. Epstein (File #: 291874) Judge Crow's UMC calendar is suspended 8/13-8/15. That leaves one day open before 8/17 which is 8/16 and Mr. Scarola is available that day. From: Tonja Haddad Coleman [mailto: Sent: August 09, 2012 9:30 AM To: Mary E. Pirrotta Subject: RE: Edwards, Bradley adv. Epstein (File #: 291874) The Motion for Summary Judgment is set for next Friday so ideally we need the hearing well before then. Tonja Haddad Coleman, Esq. TONJA HADDAD, P.A. Justice Building 524 South Andrews Avenue Suite 200 North Fort Lauderdale, Florida 33301 csimile www.tonjahaddadpa.com EFTA00712160 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: Mary E. Pirrotta [maitto: Sent: Thursday, August 09, 2012 9:31 AM To: Subject: RE: Edwards, Bradley adv. Epstein (File #: 291874) Do you want Mr. Scarola's UMC availability over next two weeks? From: Tonja Haddad Coleman [mailto: Sent: August 09, 2012 9:27 AM To: Jack Scarola Cc: Mary E. Pirrotta; 'Jack Goldberger; 'Brad Edwards'; 'LillyAnnSanchez' Subject: RE: Edwards, Bradley adv. Epstein (File #: 291874) I am again requesting dates on which Mr. Scarola is available for hearing on our Motion to Continue the Summary Judgment hearing. Thank you. Tonja Haddad Coleman, Esq. TONJA HADDAD, PA. Justice Building 524 South Andrews Avenue Suite 200 North Florida 33301 acsimile www. ono a adpa.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 12:12 PM To: < I> Cc: Mary E. Pirrotta; Jack Goldberger; Brad Edwards; LillyAnnSanchez Subject: Re: Edwards, Bradley adv. Epstein (File #: 291874) I respectfully disagree and welcome the opportunity to watch you again attempt to explain to the Court how this discovery could possibly lead to admissible evidence. Should you choose to continue to attempt to pursue the malicious prosecution of your spurious claims and the irrelevant fishing expedition attendant to that malicious prosecution you will simply be continuing to aggravate your client's (and perhaps your own) liability. The only basis upon which you have thus far evaded the application of the litigation privilege has been the totally unsupported and unsupportable accusation that Brad Edwards knowingly utilized the claims against your child molester client to facilitate the Rothstein Ponzi scheme. Once the scheme was publicly disclosed and Brad Edwards left RRA, there was no possibility that the legitimate claims against Epstein were being employed to advance a scheme that no longer existed. On Aug 8, 2012, at 11:51 AM, "Tonja Haddad Coleman" < wrote: Mr. Scarola- EFTA00712161 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, PA. Justice Building 524 South Andrews Avenue Suite 200 North 1111, 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. 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 which was previously filed in connection with the Taragrah 13 production request" was prepared subsequent to the Order indicating that our earlier log did not comply with TIC. This one does comply. The new log concems emais. all which were senUreceived 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. You continue 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. On Aug 8, 2012, at 10:12 AM, "Tonja Haddad Coleman" c > wrote: Please see attached. Tonja Haddad Coleman, Esq. TONJA HADDAD, PA. Justice Building 524 South Andrews Avenue EFTA00712162 Suite 200 North Fort Lauderdale, Florida 33301 facsimile www.tomanaadadpa.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. 52510- 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. 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. 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. 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 EFTA00712163 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. ************************************************************************************* ***** EFTA00712164