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Y9/C 9CX CTX Y10Cy CX CX CX YC YY FV uTl bEWa ȓjJ-8 Gc G??Q9E 9Wq CTX CTX Up i I A 9_ qr qr YY D.X 7s F??Y bc3_c iH CTX CTX A qr 10Cy YY EMq 7H AY mK9Z BY A2 P6L N7 CTX CTX a I I i qr rC CTX CTX 7O I FMM qr qr i I I3 CTX Z6 I L(K4 P:u Z6P CTX y8 be heard then However the Courts Judicial Assistant advised such was not possible due to the length of time scheduled for the hearing About a week after the above referenced October email noticing Haddads conflict and without the courtesy of being advised of attorney Scarola presently alleged conflict his secretary sent an inquiry regarding whether the undersigned still had a conflict The response some minutes later by the undersigneds secretary was to advise that the undersigneds conflict the previously mentioned seminar in New Orleans also included a conflicting conference at the saine time in New Orleans for his wife a surgeon ASPS annual convention but she advised the secretary the undersigned was attempting to make later reservations see email conversation attached hereto since no response had been had to the earlier request Rather than acknowledge that attorney Scarola decided unilaterally to attempt to obtain a new date and advise that a call was placed to the JA see email conversation attached hereto It was stated that the next available date for hearing was in early December The undersigneds secretary was advised attorney Scarola now asserted a conflict on October with a hearing before Judge Brown in Gauger Dougan and hence was seeking a reset of the disqualification hearing Judge Browns hearing was set by Court Order of September Thus from the date of October attorney Scarolas office and ipso facto the attorney was well aware of that conflict and obviously attempted to leave 267counsel hanging until the last minute despite being advised on October of the undersigneds conflict with an out of state seminar Further on October the undersigned through his office emailed attorney Scarola to see if he would accept service of process for Edwards for this hearing and he agreed see email conversation attached hereto knowing it is submitted he had a conflict and not bothering to extend the courtesy of advising the undersigned of the same The undersigned also has another attorney/witness under subpoena Edwards through counsel has noticed this matter for trial and Mr Epstein wants the undersigned to try the case The issue of disqualification needs to be resolved for discovery to be conducted in a manner the undersigned if trial counsel directs Page of Mr Edwards moved to disqualify the undersigned the undersigned filed a lengthy response with several exhibits refuting the allegations and setting forth facts and law that the undersigned submits was sufficient for outright denial of Edwards barebones motion at the very least an evidentiary hearing was mandated by the response Rather than just acknowledge that attorney Scarola caused_ the undersigned and other Broward co-counsel both of whom have children in second.gracie,_to make arrangements for their I children so they could attend an hearing just to hear attorney Sc ola announce the bvious about the necessity of an evidentiary hearing Realistically this was not an unexpected move but still inconvenient In thirty eight or more years of practice the undersigned cannot recall a single instance of not accommodating another lawyer however attorney Scarola seems to think it proper to inconvenience other counsel without hesitation and not respond for almost a week when advised of conflicts by opposing counsel thus the undersigned has no intention of accommodating such conduct and objects to resetting the October hearing WHEREFORE Jeffrey Epstein opposes the Motion to reset the hearing I HEREBY CERTIFY that a copy of the foregoing was furnished via Email to all counsel listed below this 18TH day ofOctober FRED HADDAD P.A One Financial 267plaza Suite Fort Lauderdale Tel Florida Bar No Dee FredHaddadLaw.com Page of COUNSEL LIST Jack Scarola Esq E-mail jsx searcylaw.com mep searcylaw.com Palm Beach Lakes Blvd West Palm Beach Florida Jack Goldberger Esq E-mail jgoldberger agwpa.com smahoney agwpa.com Australian A venue South Suite West Palm Beach Florida Marc Nurik Esq E-mail marc nuriklaw.com One East Broward Blvd Suite Fort Lauderdale Florida Bradley Edwards Esq E-mail bje.efile pathtojustice.com staff.efile pathtojustice.com Andrews A venue Suite Fort Lauderdale Florida Tonja Haddad Coleman Esq E-mail tonja tonjahaddad.com debbie tonjahaddad.com S.E th Street Suite Fort Lauderdale Florida Lilly.Ann Sanchez Esq E-mail lsanchez thelsfirm.com Brickell A venue th Floor Miami Florida Page of Dee Soli From Sent To Mary Pirrotta MEP Searcylaw.com Thursday October AM Dee Soli Subject RE Epstein Edwards Mr Scarola asked me to inquire aQout getting a new date for the hearing I have a call into the JA but was only able to leave a message The next available date on the onli.ne scheduling calendar is Is your attorney available on between sometime for a hr hearing I have not checked with any of the other opposing counsel yet Please advise thank you From Dee Soli mailto:Dee fredhaddadlaw.com Sent October AM To Mary Pirrotta Subject RE Epstein Edwards Mr Haddads wife is a surgeon who has a conference in New Orleans and Mr Haddad also has a conference in New Orleans They are attempting to obtain other reservations for later flights at this juncture and I cannot reach either of them right now to see if they have been successful Dee Soli Florida Registered Paralegal FRED HADDAD P.A One Financial Plaza Suite Fort Lauderdale Florida Tel Fax Email Dee FredHaddadLaw.com or NolefanlO aol.com CONFIDENTIALITY NOTICE This e-mail transmission and any accompanying documents are solely for the use of the intended recipient and may contain information that is privileged confidential or otherwise exempt from disclosure under applicable law If you are not the intended recipient you are hereby notified that any disclosures copying distribution or action taken or omitted in re!iance on it is strictly prohibited If you received this information in emJr please notify the sender immediately and delete the original transmission The sender does not assume any responsibility for changes made to this e-mail message and any attachments after transmission From Mary Pirrotta mailto:MEP Searcylaw.com Sent Wednesday October AM To Dee Soli Subject RE Epstein Edwards Does Mr Haddad still have a conflict with the th or has that been resolved From Dee Soli mailto:Dee fredhaddadlaw.com Sent October AM To Jack Scarola Cc Julianne Lorello bje.efile pathtojustice.com staff efile pathtojustice.com jgoldberqer agwpa.com smahoney agwpa.com marc nuriklaw.com Debbie Fein lsanchez thelsfirm.com Tonja Haddad Coleman Tonja tonjahaddad.com Mary Pirrotta Brad Edwards Subject RE Epstein Edwards Mr Scarola attached is a copy of the subpoena that you agreed to accept The original subpoena and witness fee check is being delivered to your office Thank you Dee Dee Soli Florida Registered Paralegal FRED HADDAD P.A One Financial Plaza Suite 267Fort Lauderdale Florida Tel Fax Email Dee FredHaddadLaw.com or Nolefan10 aol.com CONFIDENTIALITY NOTICE This e-mai_l transmission and any accompanying documents are solely for the use of the intended recipient and may contain information that is privileged confidential or otherwise exempt from disclosure under applicable law If you are not the intended recipient you are hereby notified that any discloslires copying distribution or action taken or omitted in reliance on it is strictly prohibited If you received this information in error please notify the sender immediately and delete the original transmission The sender does not assume any responsibility for changes made to this e-mail message and any attachments after transmission From Jack Scarola mailto:JSX SearcyLaw.com Sent Thursday October PM To Dee Soli Cc Julianne Lorello bje.efile pathtojustice.com staff.efile pathtojustice.com jgoldberger agwpa.com smahoney agwpa.com marc nuriklaw.com Debbie Fein lsanchez thelsfirm.com Tonja Haddad Coleman Tonja tonjahaddad.com Mary Pirrotta Brad Edwards Subject Re Epstein Edwards I will accept service On Oct at PM Dee Soli Dee fredhaddadlaw.com wrote Jack understand Judge Crow has set the disqualification hearing for October Are you willing to accept servil for your co-counsel/witness Brad Edwards or would you prefer I have an investigator personally serve him If I dont hear from you by Monday at noon I will assume you declined to accept service Fred Dee Soli Florida Registered Paralegal FRED HADDAD P.A One Financial Plaza Suite Fort Lauderdale Florida Tel Fax Email Dee FredHaddadLaw.com or Nolefan10 aol.com CONFIDENTIALITY NOTICE This e-mail transmission and any accompanying documents are solely for the use of the intended recipient and may contain information that is privileged confidential or otherwise exempt from disclosure under applicable law If you are not the intended recipient you are hereby notified that any disclosures copying distribution or action taken or omitted in reliance on it is strictly prohibited If you received this information in error please notify the sender immediately and delete the original transmission The sender does not assume any responsibility for changes made to this e-mail message and any attachments after transmission 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 U.S.C The information contained in this E-mail message is privileged and confidential under Fla Jud Admin and information intended only for the use of the individual 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 and destroy all copies of the original message Thank you eSafe scanned this email for malicious content IMPORTANT Do not open attachments from unrecognized senders 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 U.S.C The information contained in this E-mail message is privileged and confidential under Fla Jud Admin and information intended only for the use of the individual named above If the reader ofthis message is not the intended recipient you are hereby notified that any dissemination distribution or copy of this communication is strictly prohibited Personal messages xpress 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 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 U.S.C The information contained in this E-mail message is privileged and confidential under Fla Jud Admin and information intended only for the use of the individual named above If the reader ofthis 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 Dee Soli From Dee Soli Sent To Thursday October PM MEP Searcylaw.com Subject Epstein Edwards Mary as you know the disqualification hearing was scheduled for October a date when Fred will be out of town for a seminar in New Orleans Would there be any objection to moving this hearing to the October time slot now that the other Motion has been canceled Dee Soli Florida Registered Paralegal FRED HADDAD P.A One Financial Plaza Suite Fort Lauderdale Florida Tel Fax Email Dee FredHaddadLaw.com or No1efan10 aol.com CONFIDENTIALITY NOTICE This e-mail transmission and any accompanying documents are solely for the use of the intended recipient and may contain information that is privileged confidential or otherwise exempt from disclosure under applicable law If you are not the intended recipient you are hereby notified that any disclosures copying distribution or action taken or omitted in reliance on it is strictly prohibited If you received this information in error please notify the sender immediately and delete the original transmission The sender does not assume any responsibility for changes made to this e-mail message and any attachments after transmission Dee Soli From Sent To Subject Mary Pirrotta MEP Searcylaw.com Thursday October PM Dee Soli Automatic reply Epstein Edwards I am currently out of the office I will return the nex:t business day at a.m Privileged and Confidential Electronic communication is not a secure mode of communic_ation 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 U.S.C The information contained in this E-mail message is privileged and confidential under Fla Jud Admin and information intended only for the use of the individual named above If the reader ofthis i:nessage 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
