From: Darren Indyke <
To: Jeffrey Epstein <jeevacation@gmail.com>
Subject: Fwd: Edwards adv. Epstein
Date: Fri, 01 Jun 2012 MA:09 +0000
Darren'. Indyke
Darren . Indyke, PLLC
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Telephone: (212) 517-2052
Direct:
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Begin forwarded message:
From: "Tonja Haddad Coleman" <a
Date: June 1, 2012 10:21:57 AM EDT
To: "'Mary E. Pirrotta'"
Cc: "'Jack Scarola"' < "'Brad Edwards—
Subject: RE: Edwards adv. E stein
Reply-To:
Mr. Scarola:
When responding to a Request for Production, one is required to put, in writing (not in an insulting email), a
proper response; to wit: 1) that the documents responsive to the request are provided; 2) state an objection and
the grounds therefor (including providing a privilege log, etc.); 3) state that no such documents responsive to
the request exist. As quoted in our Motions to Compel and for Sanctions, failure to provide a complete
response is deemed non-responsive by the courts.
We could obviate the need for the hearing on June 11- and the sarcasm from you- by your simple compliance
with the Rules and years of precedent-setting jurisprudence. As such, please put, in writing, a response to the
following request as Court-ordered. I will break it down for you:
Are there any e-mails, data, correspondence, and similar documents dated April 1, 2008 through August 1,
2010 that mention Mr. Epstein between (meaning to or from) Bradley J. Edwards and any of the following
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people?
a) Scott W. Rothstein (no response yet)
b) Marc Nurik (no response yet)
c) Cam Holmes (no response yet)
d) Mike Fisten (no response yet)
e) the U.S. Attorney's Office (no response yet)
f) the State Attorney's Office (no response yet)
g) the Federal Bureau of Investigation (no response yet)
h) '(you have provided some responses to this request)
i) any other news employees or reporters (you have provided some responses to this as well).
Please respond by either providing the documents, objecting and citing therein the proper reasons and/or
privilege asserted with the accompanying log, or stating that no such documents exist.
Tonja Haddad Coleman, Esq.
TONJA HADDAD, P.A.
Justice Building
524 South Andrews Avenue
Suite 200 North
Fort Lauderdale, Florida 33301
(954) 467-1223
(954) 337-3716 facsimile
www.tonjahaddadpa.com
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