EFTA00713520.pdf

From: "Tonja Haddad Coleman" < To: "'Jeffrey Epstein"' <jeevacation@gmail.com> Subject: RE: CONFIDENTIAL Date: Tue, 24 Jul 2012 16:07:04 +0000 I am sorry but Ok what? Stop working on it until we meet? Tonja Haddad Coleman, Esq. TONJA HADDAD, P.A. Justice Building 524 South Andrews Avenue Suite 200 North Fort Lauderdale. Florida 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. From: Jeffrey Epstein imaittojeevacation@gmall.com] Sent: Tuesday, July 24, 2012 12:03 PM To: Subject: Re: CONFIDENTIAL ok On Tue, Jul 24, 2012 at 11:58 AM, Tonja Haddad Coleman < > wrote: Gentlemen: I know we are discussing the potential of dropping the case in chief against Edwards and then just defending the Counterclaim (or not) and/or damages/fees, and I am researching the legal ramifications of those options. I will be fully prepared to discuss it on Friday at our meeting. If we are going to dismiss, however, it has to be before Summary Judgment, and there is some case law out there saying it has to happen before we file a response to Edwards' Summary Judgment (I am still reviewing it). That being said, collectively Debbie and I have about 90 hours in on researching and responding to their Motion (which is 22 pages and touches on 6 different areas of law, coupled with 41 pages of "Undisputed" facts that cite to literally dozens of depositions, affidavits, etc.). Because the Judge has continued the hearing date and has not provided us a new one as of yet, it is no longer pressing that our response be ready, and if you are considering dropping the case I think it is wiser financially for you if we do not incur any additional expense on the Memorandum of Law in Opposition to their Motion (although I must say our research has led to excellent points of law with respect to defending the Counterclaim and/or a motion for attorneys' fees). Please let me know your thoughts on this. Thank you. Tonja Haddad Coleman, Esq. TONJA HADDAD, P.A. Justice Building 524 South Andrews Avenue Suite 200 North EFTA00713520 Fort Lauderdale Florida 33301 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. The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of Jeffrey Epstein Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to jeevacation@gmail.com, and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA00713521