EFTA00836243.pdf

From: Tonja Haddad Coleman <MINIM > To: Jack Scarola ca, "Thomas E. Scott" , Paul Cassell <cassell aw.utah.edu>, "Mary E. Pirrotta" , Mary Boija "Jack Goldberger" Brad Edwards CC: a a Subject: RE: Dershowitz Date: Tue, 19 Jan 2016 16:35:11 +0000 Importance: high Good morning Jack: Our "position" regarding Mr. Epstein's deposition is as follows: First, the date upon which you set Mr. Epstein's deposition was unilaterally decided by you, and neither my client nor I can attend on said date. It is also my understanding that the date was not cleared with Mr. Dershowitz's counsel. While I received an email from you stating that you "repeatedly" tried to coordinate with my office, I have no record of any such "repeated" requests. Second, as you are aware, we tried to get our motion to stay or for entry of an order of protection heard before the deposition date that you unilaterally chose, but due to the time constraints, including scheduling conflicts with your office (since we made several good-faith attempts to coordinate it and did not unilaterally set it), we were unable to do so. Finally, it is our position that the court would have to grant our motion due to the pending appeal. Moreover, because this case is still in the discovery stages and Mr. Epstein is a non-party, it seems that nobody is prejudiced by the parties waiting for the 4th DCA to rule on the issue. All of the case law upon which we rely is clearly delineated in our motion. Again we request that you agree to stay or continue the deposition until such time that we are able to get our motion heard by the Court or until the 4th DCA rules upon the issue. Thank you. Tonja Haddad Coleman, Esq. TONJA HADDAD, P.A. Advocate Building 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 (954) 467-1223 (954) 337-3716 facsimile www.tonjahaddad.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. Original Message From: Jack Scarola [mailto Sent: Sunday, January 17, 2016 3:46 PM To: Tonja Haddad Coleman Thomas E. Scott a; Paul Cassell <cassell aw.utah.edu>; Mary E. Pirrotta ; Mary Borja ; Jack Goldberger ; Brad Edwards Subject: Dershowitz EFTA00836243 Tonja- Please confirm that it is your position that Jeffrey Epstein is excused from appearing for his scheduled deposition this Thursday as a consequence of your having appealed the order denying his motion to quash the subpoena with which he was served- and that he will not appear to be deposed on Thursday. Assuming that is the case, will you agree that it is unnecessary for us to retain a court reporter for the sole purpose of providing us with a certificate of non-appearance, and that your confirmation will as be considered an adequate substitute for the certificate? Sent from my iPad *************** *************************************************************************** I Privileged and Confidential I 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. ************************************************************************************* ***** EFTA00836244