EFTA00971746.pdf

From: Tonja Haddad Coleman To: Jack Scarola CC: "Mary E. Pirrotta>, Brad Edwards < >, Maria Kelljchian Subject: Re: Joint Pretrial Stipulation (revised 9.27.13) for final review and approval for filing Edwards, Bradley adv. Epstein (File #: 291874) Date: Fri, 27 Sep 2013 20:32:48 +0000 I have Brad's business card and documents that say otherwise, but we can agree to disagree. Here are the only facts to which I will stipulate- 1. My client plead guilty to a felony that had nothing to do with any of Brad's clients; 2. Brad was a partner at RRA when it was conducting the largest Ponzi scheme in Florida history; 3. Brad's partner is serving 50 years for the Ponzi scheme. You can try to prove everything else at trial. Please send a final copy before filing. Sent from my iPhone On Sep 27, 2013, at 4:21 PM, "Jack Scarola" •=1=a , wrote: Brad was never a partner and we will not stipulate that he was. We will agree to disagree, except that we will eliminate the statement of facts to be read to the jury which I am also sure we will never agree upon. Consequently, having been fully informed of our position on each of the proposed stipulated facts, tell us which you agree to, and we will simply delete the rest. It will be a waste of time for you to try to reinsert anything we have already rejected, so please don't try. Sent from my iPad On Sep 27, 2013, at 2:44 PM, "Tonja Haddad Coleman" MIEla wrote: There were several changes made to which we do not agree; to wit: The additions in the stipulated facts to paragraphs a and b; in e put back in that Edwards was a partner at RRA- not just working there; we disagree with gin its entirety; add "partner" back into j; and what is showing as a new j makes no sense as drafted- as if words were deleted and it was not reviewed. Additionally, as I stated yesterday, the court order does not require a statement of facts to be read to the jury so they should be deleted. Thank you. Sent from my iPhone On Sep 27, 2013, at 1:20 PM, "Mary E. Pirrotta" wrote: *** 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 EFTA00971746  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. ****** ************************************************************************ ****** *** *** <Pretrial Stipulation 9.27.13 (revised 1 p.m.).docx> * 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 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. EFTA00971747