From: "Tonja Haddad Coleman"

From: "Tonja Haddad Coleman" To: Subject: RE: Friday's Hearing Date: Wed, 01 Aug 2012 15:33:24 +0000 Attachments: Motion to Compel Re Privilege Log.pdf; 2).pdf Mr. Scarola- Because you seemed so certain in your email to my office yesterday that you have no outstanding discovery issues, I reviewed both the Motion to Compel Production of Documents and the Order regarding same that was entered by the Court on May 7, 2012; the one for which you requested clarification. I am attaching copies of each for your review. It seems very clear in the Order that Mr. Epstein's Motion was granted and that "Mlle Defendant Bradley Edwards shall within 30 days of this Order file a more complete privilege log." The Court further avowed that your privilege log was "insufficient on its face" and in non-compliance with the prevailing case law and applicable Rules of Civil Procedure. To date, we have not received a "more complete privilege log" as mandated by the court. Accordingly, contrary to your assertion, there are discovery issues outstanding that must be addressed by the court on Friday. Tonja Haddad Coleman, Esq. TONJA HADDAD, 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: Tonja Haddad Coleman [mailto:I Sent: Tuesday, July 31 2012 10:43 AM To: 'Ma E. Pirrotte 'Jack Scarola' Cc: Subject: Friday's Hearing ; Mr. Scarola: The attached Order has never been addressed by the Court and was the subject of your Motion for Clarification; the hearing on which was continued by the Court until this Friday. Because you have never complied with the attached Order, notwithstanding the Court's explicit and simple instructions therein, the hearing Friday must go forward- unless you want to provide to us the emails between Mr. EFTA00647347 Edwards and the members of the press (which are not privileged) and the other emails referenced in the Order. Please advise. Thank you. Tonja Haddad Coleman, Esq. TONJA HADDAD, 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: Mary E. Pirrotta [maitto: Sent: Friday. JulY 13 2012 10:30 AM To: Subject: Regarding: Edwards, Bradley adv. Epstein (Rle #: 291874) UMC hearings on Monday July 16 are cancelled due to judge's calendar suspension through 7/20 It appears that since the filing of the initial motion set for UMC on 7/16, Judge Crow's UMC calendar has become suspended through 7/20. We would like to reschedule these motions for Monday, 7/23. Please confirm your availability. Thank you. Mary Pirrotta Secretary to Jack Scarola, Esquire Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Phone: Ext. 608 Fax: Email: 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 (800) 780-8607 and destroy all copies of the original message. Thank you. EFTA00647348