EFTA01099380

TONJA HADDAD PA 
September 26. 2013 
Via Electronic Mail 
Jack Scarola, Esq. 
Searcy Denney et al. 
Re: 
Epstein v. Edwards et ed. 
Mr. Scarola: 
As discussed, the items listed below (numbered as they appear on your exhibit list) were 
never provided to us during discovery in this matter. Please advise if you agree that you 
will not use this substantial (and irrelevant) list of items, or if we need to address it in 
our Motion in Limine. Back on April 23, 2013, you were served with the following 
request as listed on Schedule A to Brad's deposition notice: 
12. 
Copies of any and all documents you intend to introduce at trial in support of the 
allegations made by you in your Fourth Amended Counterclaim you filed in this matter. 
At the hearing on your Motion for Protective Order on June 10, 2013, you told the judge 
specifically that you were providing all items responsive to that request. 
7 The last one is copies of any and all 
8 documents you intend to introduce at trial in 
9 support of the allegations made by you in the 
to fourth amended counterclaim. Again, we are 
11 giving them all the evidence that we intend to 
12 rely upon. 
See Transcript ofJune 10. 2013 hearing, p. 27, which is attached to this letter. 
4. 
9. 
II. 
12. 
Video of Jeffrey Epstein's home and route from victim to Epstein's home 
Documents related to Jeffrey Epstein produced by Alfredo Rodriguez 
Jeffrey Epstein phone records 
 
1
phone records 
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15. 
All probable cause affidavits related to criminal investigation of Jeffrey Epstein 
16. 
All evidence, information and documents taken or possessed by FBI related to 
criminal investigation of Jeffrey Epstein 
17. 
Victims' statements to the FBI related to criminal investigation of Jeffrey 
Epstein 
18. 
Video of Search Warrant of Jeffrey Epstein's home being executed 
19. 
Application for Search Warrant of Jeffrey Epstein's home 
27. 
Yearbooks of Jane Doe 
28. 
2002 Royal Palm Beach High School Year Book 
29. 
2001 Royal Palm Beach High School Year Book 
30. 
2003 Palm Beach Gardens High School Year Book 
31. 
Affidavit and Application for Search Warrant on Jeffrey Epstein's home 
32. 
Tape recording or transcript of recording of conversation between Jeffrey 
Epstein and George Rush 
33. 
Notepads found in Jeffrey Epstein's home and/or during trash pulls outside of his 
home during criminal investigation 
39. 
All statements made by Jeffrey Epstein 
40. 
List of properties and vehicles in Larry Visoski's name 
50. 
Video footage (DVD) of walk through site inspection of Jeffrey Epstein's home. 
51. 
Photos of all of Jeffrey Epstein's properties, cars, boats and planes 
52. 
Probable Cause Affidavits prepared against Jeffrey Epstein and 
53. 
Audio tape of 
54. 
Photographs, videos and books taken in the search warrant of Jeffrey Epstein's 
home 
55. 
Documents related to or evidencing Jeffrey Epstein's donations to law 
enforcement 
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56. 
Victim Notification Letter from US Attorney's Office to Victim 
57. 
Expert Dr. L. Dennison Reed's Report of Victim 
59. 
All reports and documentation generated by Palm Beach Police Department 
related to Jeffrey Epstein 
60. 
All Witness Statements generated by Palm Beach Police Department relating to 
Jeffrey Epstein 
61. 
Passenger Manifests of Jeffrey Epstein's aircraft and private plane flight logs 
62. 
Passenger lists for flights taken by Jeffrey Epstein 
63. 
Letter from Jeffrey Epstein to Alberto Pinto regarding house island project 
65. 
MC2 emails involving communications of Jeffrey Epstein, Jeff Puller, 
Pappas Suat, Jean Luc Brunel and Amanda Grant 
68. 
Massage Table 
69. 
Lotions taken from Jeffrey Epstein's home during search warrant 
70. 
Computers taken from Jeffrey Epstein's home during search warrant 
71. 
Vibrators, dildos and other sex toys taken from Jeffrey Epstein's home during 
search warrant 
77. 
80. 
Letter from Chief' 
82. 
83. 
CAD calls to 358 El Brillo Way, Palm Beach FL 33480 
to 
Letter from Guy Fronstin to Assistant State Attorney dated 1-11-06 
Letter from Guy Fronstin to Assistant State Attorney dated 1-13-06 
84. 
Letter from Guy Fronstin to Assistant State Attorney dated 2-17-06 
85. 
Letter from Guy Fronstin to Assistant State Attorney dated 4-6-06 
86. 
Letter from Guy Fronstin to Assistant State Attorney dated 410-06 
87. 
Letter from Goldberger dated 6-22-06 
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88. 
All subpoenas issued to State Grand Jury 
89. 
Documents related to the rental of a vehicle for 
90. 
Ted's Sheds Documents 
91. 
Documents related to property searches of Jeffrey Epstein's properties 
92. 
Arrest Warrant of 
93. 
Police report regarding 
icking up money dated 11-28-04 
94. 
List of Trilateral Commission Members of 2003 
96. 
Guy Fronstin letter dated 4-17-06 
100. 
Victim's GED testing information and results 
101. 
JEGE, Inc. Passenger Manifest 
102. 
Hyperion Air Passenger Manifest 
103. 
Flight information for 
104. 
Passenger List Palm Beach flights 2005 
105. 
Jeffrey Epstein notepad notes 
108. 
letter to
 dated 5-1-06 
110. 
Police Report dated 11-28-04 
Ill. 
Compulsory Medial Examination of victim, CMA 
112. 
Victim's school records and transcripts 
113. 
Victim Notification letter dated 7-9-08 
114. 
Victim's employment records from IHOP 
115. 
Police report of Juan Alessi theft at Jeffrey Epstein's home 
116. 
Victim's Medical Records from Milton Girls Juvenile Facility 
117. 
Victim's Medical Records from Dr. Randee Speciale 
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118. 
Victim's Medical Records from Wellington Regional Hospital 
119. 
Victim's Medical Records from St. Mary's Medical Center 
120. 
Victim's Medical Records from United Health 
121. 
All surveillance conducted by law enforcement on Jeffrey Epstein's home 
122. 
Emails received from Palm Beach Records related to Jeffrey Epstein 
123. 
All items listed on the Palm Beach Police Property Report Lists 
124. 
All items taken in the execution of the search warrant of Jeffrey Epstein's home: 
358 El Brillo Way, Palm Beach FL 33480 
127. 
All documents produced by Palm Beach Police Department prior to the 
deposition of Detective Recarey 
128. 
Photographs of all persons listed on Victims' Witness Lists 
129. 
Statements, deposition transcripts, videotaped depositions and transcripts taken 
in connection with this and all related cases and exhibits thereto 
130. 
Any and all expert witness reports and/or records generated in preparation for 
this litigation by any party to this cause 
132. 
Curriculum vitae of Dr. Ryan Hall 
133. 
Any articles or publications of Dr. Ryan Hall 
134. 
Any articles or publications of Dr. Richard Hall 
135. 
Any articles or publications of Dr. L. Dennison Reed 
136. 
All items and documentation review by Dr. L. Dennison Reed 
137. 
Transcript and video (DVD) of IME of Victims 
138. 
All exhibits to Dr. L. Demlison Reed's Deposition 
139. 
All exhibits to Dr. Richard Hall's Deposition 
140. 
All items and documents reviewed by Dr. Richard Hall 
141. 
All items and documents reviewed by Dr. Ryan Hall 
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142. 
Demonstrative aids and exhibits including, but not limited to, anatomical charts, 
diagrams and models, surveys, photographs and similar material including blow-ups of 
the foresaid items.-
143. 
Any and all mortality tables 
By notifying you of this defect pursuant to our requirement that we try to resolve 
discovery issues before we bring them before the court, we are in no way agreeing to 
their validity, relevancy, or admissibility in any way. We are further not waiving the 
right to assert any and all objections to these items as permitted by law. 
Sincerely, 
TONJA HADDAD, II 
cc: 
Parties on Service List 
Tonja Haddad Coleman 
for the firm 
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I skipped over number 9, copies of any 
and all receipts, reports, invoices or other 
documents evidencing treatment for your mental 
anguish, embarrassment, anxiety, as alleged in 
your counterclaim, there has been no formal 
treatment, we have already told them none. 
The last one is copies of any and all 
documents you intend to introduce at trial in 
support of the allegations made by you in the 
fourth amended counterclaim. Again, we are 
giving them all the evidence that we intend to 
rely upon. 
So the motion for protective order is 
directed principally to number 1, number 2, 
number 3, number 4, as it relates to anything 
other than attorney's fees awards for Bradley 
Edwards, and number 5 and the partnership 
agreement in number 6. 
So, understanding what we are claiming 
and the fact that they are entitled to test 
our claim, the answer to the question Your 
Honor asks is, yes, they are entitled to test 
our claim that this is the amount of time that 
Brad Edwards devoted to the defense of this 
case, but they haven't asked for anything that 
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EFTA01099386