EFTA00945738.pdf

From: Tonja Haddad Coleman To: "Ma E. Pirrotta" CC: :Brad Edwards' Celljchian' Subject: RE: Regarding: Edwards, Bradley adv. Epstein (File #: 291874) Date: Fri, 19 Oct 2012 17:03:55 +0000 I just spoke with Mr. Haddad (who is traveling) since you did not copy his assistant on the last email. Please be advised that moving the hearing to 2PM to accommodate your conflict does not work for him. Because you failed to respond to Mr. Haddad when he notified you the day he received the notice of hearing from the Judge regarding his request to move the hearing, he already changed his flight to accommodate the hearing set for 1:30. As such, starting the hearing at a later time is not possible. Moreover, according to your own documents filed with the Court with your request to continue the hearing, your conflict also existed at the time Mr. Haddad requested to move the hearing, yet you failed to even respond to him. One should not demand accommodation or cooperation when one fails to give it. Accordingly, Mr. Haddad will see you Monday morning. Finally, we are requesting, yet again, that you provide dates upon which the continuation of Mr. Edwards' deposition will take place. You conceded at the last hearing that your pending Motion to Disqualify Mr. Haddad cannot, and will not, stay discovery. Should we not hear from you (or whomever you designate to coordinate scheduling) by Monday at 5, 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. From: Mary E. Pirrotta [mallto: Sent: Friday, October 19, 2012 11:51 AM To: Tonja Haddad Coleman; Cc: 'Brad Edwards'; 'Maria Kelljchian' Subject: FW: Regarding: Edwards, Bradley adv. Epstein (File #: 291874) With regard to the 1:30 hearing on 10/25 on Motion to Disqualify Opposing Counsel, Judge Crow's JA advises that the hearing could be moved to a 2 p.m. start time to accommodate our conflict. Please advise if you would be agreeable to starting the hearing at 2 p.m. on that date which would obviously also cancel Monday's UMC hearing on Motion to Reschedule. EFTA00945738 Jack Scarola JS/mep 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 and destroy all copies of the original message. Thank you. EFTA00945739