EFTA00384930.pdf

From: Darren Indyke czl To: Lesley Groff Subject: Fwd: Privileged and Confidential Date: Tue, 27 Aug 2013 18:51:47 +0000 DARREN K. INDYKE DARREN K. INDYKE, PLLC 575 Lexington Avenue, 4th Floor New York, New York 10022 Telephone: Telecopier: Mobile: email: ************************** ******* ************ ***** ** ********** ** ******** *** *********** ******** The information contained in this communication is confidential, may be attorney-client privileged, and is intended only for the use of the addressee. It is the property of Darren K. Indyke, PLLC. 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, and destroy this communication and all copies thereof, including all attachments. Copyright of Darren K. Indyke, PLLC - © 2011 Darren K. Indyke, PLLC —All rights reserved. *********************************** ******** ** ******* ************* ************************** **** Begin forwarded message: From: Tonja Haddad Coleman Date: August 27, 2013 2:51:27 PM EDT To: Darren Indyke >, Jeffre Epstein <[email protected]> Cc: Jack Goldberger , Fred Haddad < Subject: RE: Privileged and Confidential 1:30 or after is better for me. I have a 12:30 appointment. Here is an agenda for the conference: 1. Motion to Compel re: Deposition Questions a. if we are moving to exclude certain things and/or prevent Edwards from using them I do not want to compel discovery from him on it; and b. Attorney/client privilege argument 2. Trial Exhibit and Witness list from Edwards 3. Do we have an expert? Are we going to call Scherer? 4. Advice of Counsel Defense and Discovery EFTA00384930 5. Can we disqualify Scarola (as per Darren and Jeffrey's request). Tonja Haddad Coleman, Esq. TONY% HADDAD, P.A. Advocate Building 315 SE 7th Street Fort Lauderdale, FL 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. From: Darren Indyke [mailto Sent: Tuesday, August 27, 2013 2:44 PM To: Jeffrey Epstein Cc: Jack Goldberger; Fred Haddad; Tonja Haddad Coleman Subject: Privileged and Confidential Does 1PM on Thursday work for everyone? If not please let me know what times work. Thanks. DARREN K. INDYKE DARREN K. INDYKE, PLLC 575 Lexington Avenue, 4th Floor New York, New York 10022 Telephone Tel Mobile: email: ********************************************************************************************** The information contained in this communication is confidential, may be attorney-client privileged, and is intended only for the use of the addressee. It is the property of Darren K. Indyke, PLLC. 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, and destroy this communication and all copies thereof, including all attachments. Copyright of Darren K. Indyke, PLLC - © 2011 Darren K. Indyke, PLLC —All rights reserved. On Aug 27, 2013, at 2:16 PM, Jeffrey Epstein wrote: EFTA00384931 can we have a call. all hands 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 [email protected], and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA00384932