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r?qr rq YY Lsy7H4 C,6E IL CTX U3 CTX J,O3_3xx qrM?r q?CX 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 calendar was suspended June and Undersigned stated that she needed to be present atthe hearing as the hearing is to schedule a trial date and offered in tum that perhaps one of Edwardss co-counsels or another attorney in Mr ScarolaS office could stand.in during a hearing iri June in Mr Scarolas absence No response to this offer was received True and correct copies of these communications are attached hereto as composite Exhibit A Next on May workhours Edwardss counsel sent another email regarding June and as proposed hearing dates for his Motion fo Set a Trial Date stating therein that if undersigned failed to responcl then the hearing would be set for June or Undersigned again 267responded within minutes and reiterated that she was unavailable on those dates due to starting trial on June On June communications continued and notwithstanding undersigneds explanation that she was starting a criminal jury trial on June a Notice of Hearing for Tuesday June was served upon counsel.oh the.afternoon of June True and correct copies of these communications 267are attached hereto as composite Exhibit and a true and correct copy of the Notice of Hearing is attached hereto as Exhibit MEMORANDUM OFLA Rule of the Florida Rules of Civil Procedure provides that a copy of any written motion which may not be heard ex parte and a copy of the notice of the hearing thereof shall be served a reasonable time before the time specified for the hearing FLA R.C1v See also Devoe Raynolds Co Inc KDS Paint Co So.2d Fla 4th DCA holding that absent extraordinary circumstances proper notice should include written notice served a reasonable time Tonja Haddad P.A SE th Street Fort Lauderdale FL I before the 267time specified for the hearing While there are no-hard rules regarding how much time constitutes reasonable time for service of notice before hearing two business days has consistently been held to be unreasonable Harreld Harreld So 2d Fla 2d DCA Finn Elliott So 2d Fla 2d DCA Likewise the focal rules applicable hereto require at least five business days notice ofa hearing As such pursuant to Local Rule Number of the Fifteenth Judicial Circuit and the Palm Beach County Bar Associations Standards for Professional Courtesy and Civility this unilaterally set hearing with two business days notice is improper and must be stricken and the hearing reset to a time when counsel can be preserit Local Rule of the Fifteenth Judicial Circuit governs Uniform Motion Calendar and provides in relevant part that hearings shall be set and noticed pursuant to the Standards of Professional Courtesy and Civility which have been endorsed by the judges of the Fifteenth Judicial Circuit See Local Rule No 1n Re Uniform Motiofz Calendar attached hereto as Exhibit The Standards for Professional Courtesy and Civility provide the following with respect to scheduling hearings As a general rule actm1l notice should be given that is no Jess than five business days for in-state depositions ten business days for out-of-state deposition and five business days for hearings See Palm Beach County Bar Associations Standards for Professional Courtesy and Civility emphasis added In the instant case Edwards fails to comport with the basic requisites for setting this hearing not only by giving two business days notice but also by setting it on a date on which he is well-aware that undersigned will be in trial in another jurisdiction and unable to attend the hearing As such it must be reset to a time during which counsel can Tonja Haddad P.A SE th Street Fort Lauderdale FL be present It is likewise noteworthy to illustrate that this Court is currently scheduling Jury Trials for the trial period of January through March As such a two-week delay to set a trial date does not prejudice Edwards Consequently Edwardss Notice of Hearing should be stricken and this hearing reset upon proper notice on a date on which counsel can be present WE HEREBY CERTIFY that a true and correct copy of the foregoing was served upbh all parties listed below via Electronic Service,.this June Tonja Haddad Coleman Tonja Haddad Coleman Esq Fla LAW OFFICES OF TONJA HADDAD PA SE th Street Suite Fort Lauderdale Fiorida facsimile Efiling tonjahaddad.com Tonja tonjahaddad.co1l1 Tonja Haddad P.A SE th Street Fort Lauderdale FL I SERVICE LIST CASE NO JackScarola Esq jsx searcyla V.com;mep searcylaw.com Searcy Denney Scarola et al Palm Beach Lakes Blvd West Palm Beach JackGoldberger Esq jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss PA Australian Ave South Suite.1400 West Palm Beach FL Marc Nurik Esq East Broward Blvd Suite.700 Fort Lauderdale FLJ33O1 BradleyJ Edwards Esq brad pathtojustice.com Farmer Jaffe Weissing Edwards FistosLehrman Andrews A venue Suite Fort Lauderdale Florida Fred Haddad Esq Dee FredHaddadLaw:com Financial Plaza Suite Fort Lauderdale FL Tonja Haddad Coleinan,.Esquire Tonja tonjahaddad.cmn efiling tonjahaddad.coin Law Offices of Tonja Haddad P.A SE 7th Street Suite FortLauderdale FL Attorneys for Jeffrey Epstein Chester Brewer Jr One Clearlake Center Suite Australian Avenue South West Palm Beach Florida wcblaw aol.com wcbcg aol.com Tonja Haddad P.A SE th Street FClrt Lauderdale FL30l Tonja Haddad Coleman From Sent To Mary Pirrotta MEP Searcylaw.com Friday May AM Tonja Haddad Coleman Subject RE EDWARDS ADV EPSTEIN--SERVICE OF COURT DOCUMENTS File Mr Scarola is not available Judge Hafeles calendar is suspended and What is your availability the first two weeks of July Thank you From Tonja Haddad Coleman mailto:tonja tonjahaddad.com Sent rv1ay AM To Mary Pirrotta MEP Searcylaw.com Cc jgold berger agwpa.com smahoney agwpa.com marc nuriklaw.com staff.efile pathtojustice.com Dee Fred Haddad Law com Fred FredHaddadLaw.com wcblaw _aoLcom w_cblawasst gmail.com Subject Re EDWARDS ADV EPSTEIN-SERVICE OF COURT DOCUMENTS File No as I said in my email below I start trial June Tonja Haddad Coleman Esq Ton a Haddad PA Advocate Building SE 7th Street Suite Fort Lauderaale FL On May at AM Mary E.Pirrotta MEP Searcylaw.com wrote Ms Coleman Are you available June orS by un.authorized 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 name i above If the reader of this message is not the intended recipient you are hereby notified that any dissemination distribution or copy of this comm lication is strictly prohibited Personal messages express views solely of the sender and shall not be attributed to the law firm.Jfyou received this communication in error please notify the sender immediately by e-mail or by telephone at and destroy aHcopies ofthe originalmessage Thartkyou Motion fo Expand Interrogatories-I l.pdf Tonja Haddad Coleman From Sent To Cc Subject For the third time I start Trial June and am Torija Haddad Coleman Wednesday May PM Nora Fried jgoldberger agwpa.com smahoney agwpa.com marc nuriklaw.com staff.efile patbtojustice:com dee fredhacfdadlaW.co fred fredhaddadlaw.com wcblaw aol.com wcblawasst gmail.com Re EDWARDS ADV EPSTEIN--SERVICE OF COURT DOCUMENTS File Not available this was repeatedly stated-there cannot be a hearing set on those days I am sorry it will not Be heard before Mr Scarolas vacation for weeks but my schedule does not permit it Confirm receipt please I have sent this.twice already Tonja Haddad Coleman Esq Tonja Haddad PA Advocate Building SE 7th.Street Suite Fort Lauderdale FL On May at PM Nora Fried njf searcylaw.com wrote Good afternoon Just following up on Mary Pirrottas email inquiring regarding availability for UMC on or while she is away on vacation If I do not hear otherwise by noon tomorrow I will assume either date is acceptable Thank you Nora Fried Legal Secretary EXHIBITB Tonja Haddad Coleman From Sent To Cc Subject Tonja Haddad Coleman Thursday June PM Jack Scarola Nora Fried Mary Pirrotta staff.efile pathtojustice.com wcblaw aol.com wcblawasst gmail.com Brad Edwards;.Jack Goldberger Re EDWARDS ADV EPSTEIN--SERVICE OF COURT DOCUMENTS File With all due respect Mr Scarola no hearing in this case is ever simple Moreover I need to be at the hearing and I start trial June Your th.ree week vacation is riot more important than my trial-you have countless partners who could stanain and cover for you while youre on vacation on June or during the last week of June I simply cannot appear next week Tonja Haddad Coleman Esq Tonja Haddad PA Advocate Building SE 7th Street Suite Fort Lauderdale FL On Jun at PM Jack Scarola JSX SearcyLaw.com wrote I called and left a message for you and rece.ived no response We are unwilling to wait a month or more to hold a very simple hearing to get the referenced matter set for tric when that delay will undoubtedlyHmit the trial settings available to us There are at least four separate la firms directly and actively involved in the defense of this case One representative from one ofthose firms shol.ild be more than capable of appearing in person or by telephone for the hearing that we will notice for a UMC hearing on June Thank you for your anticipated cooperation On Jun at AM,Tonja Haddad Coleman tonja tonjahaddad.com wrote Filing E-Filed PM JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendant IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO AMENDED NOTICE OF HEARING Amended as to Motion only YOU ARE HEREBY NOTIFIED that the undersigned 267has called tip for 267hearing the following DATE June TIME a:m JUDGE Honorable Donald Hafele PLACE Dixie Highway West Palm Beach FL ROOM SPECIFIC MATTERS TO BE HEARD Plaintifrs Motion to Set Case for Trial I Counsel has conferred with all parties who may be affected by the relief sought in the.motion in a good faith eJortto 225resolve ornarrow the issues raised EXHIBITC Epstein Edwards Case No Amended Notice of Hearing Counsel has made reasonable efforts io confer with all parties who may be affected by the relief sought in the motion but has been unable to doso I HEREBY CERTIFY that a true and correct copy ofthe foregoing was 267sent via E-:Serve to all Counsel on the attached list on this nd da of June JACK LIA Florid ar No E-Mail jsx searcylaw.com and searcylaw.com Primary E-Majl _scarolateam searcylaw.com Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida Phone Fax Attorney forPlaintiff Epstein Edwards Case No Amended Notice of Hearing COUNSEL LIST William Chester Brewer Esquire wcblaw aol.com wcblawasst gmail;com Australian Avenue Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Jack A Goldberger Esquire jgoldberger agwpa.com smahoney agwpa;com Atterbury Goldberger Weiss P.A Australian Avenue Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Andrew A Harris Esquire aah FLAppellateLaw.com jew FLAppeUateLaw.com Burlington Rockenbach Railroad Avenue Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein 267BradleyJ Edwards Esquire staff.efile pathtojustice.com Fanner Jaffe Weissing Edwards Fistos Lehrman P.L Andrews Avenue Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein Fred Haddad Esquire Dee FredHaddadLaw.com Fred FredHaddadLaw.com Epstein Edwards Case No Amended Notice of Hearing COUNSEL LIST William Chester Brewer Esquire wcblaw aol.com wcblawasst gmail.com SAustralian Avenue Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Jack A Goldberger Esquire jgoldberger agwpa:com smahoney agwpa.com Atterbury Goldberger Weiss P.A Australian Avenue Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Andrew A Harris Esquire aah FLAppellateLaw.com jew FLAppellateLaw.com Burlington Rockenbach Railroad Averiue Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Bradley Edwards Esquire staff.efile pathtoj ustice;com Farmer Jaffe Weissing Edwards Fistos Lehrman P.L Andrews A venue Suite Fort Lauderdale FL Phone Fax Attorneys forJeffrey Epstein Fred Haddad Esquire Dee FredHaddadLaw.com Fred FredHaddadLaw.com Epstein Edwards Case No Amended Notice of Hearing Fred Haddad P.A One Financial Plaza Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein Paul Morris Esquire paulappeal gmail.com paul paulmorrislaw.com Paul Morris P.A Dixie Highway Suite Miami FL Phone Fax Attorneys for Jeffrey Epstein TonjaHaddad Coleman Esquire tonja tonjahaddad.com efiling tonjahaddad.com Tonja Haddad P.A SE 7th Street Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein Marc Nurik Esquire marc riuriklaw.com One Broward Blvd Suite FortLauderdale FL Phone Fax Attorneys for Scott Rothstein Epstein Edwards Case No Amended Notice of Hearing If you are a person with a disability who needs any accommodation in order to participate in this proceeding you are entitled at no cost to you to the provision of certain assistance Please contact Americans with Disabilities Act Coordinator at least days before your scheduled court appearance or immediately upon receiving this notification if the time before the scheduled appearance is less than days if you are hearing or voiceimpaired call Si usted es una persona minusvalida que nccesita algun acomodamiento 267para poder participar este procedimiento usted tiene derccho sin ten er gastos propios a qlle sc le provca cierta ayllda Ten gala amabilidad de ponerse en contacto con Americans with Disabilities Act Coordinator porlo menos dias antes de la cita fijada para su compareccncia en Jos tribunales inmediatamente desplles de rccibir esta notificacion si el tiempo antes de la comparecencia qlle se ha programado es menos de dias si llSted tiene discapacitaci6n del oido ode la voz Harne al Si ou se yon molln ki enfim ki bezwen akomodasyon pou ka patisipe nan pwosedi sa ou kalifye san ou pa gen okenn lajan poll peyc gen pwovizyon poll jwen kek Tanpri kontakte nan jou anvan dat Oil gen randevoll pou paret nan tribinal Ja Ollbyen imedyatman apre oil fin resevwa konvokasyon an si le ou gen poll paret nan tribinal la mwens ke jou si ou gen pwoblein pou tan de oubyen pale rele Rev IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND_FOR PALM BEACH COUNTY FLORIDA Local Rule No IN RE UNIFORM MOTION CALENDAR Pursuant to the authority conferred by rule Fla Jud Admin it is ORDERED as follows Circuit judges in each division shall conduct a uniform motion calendar on days and at a time specified by the judges of the division Prior to setting a matter on the Uniform Motion 267Calendar the attorney noticing the motion for hearing shall attempt to resolve the matter and shall certify the good faith attempt to resolve The term attempt to resolve the matter in paragraph shall require counsel to make reasonable efforts to actually speak to one another in person or via telephone and engage in reasonable compromises in a genuine effort to resolve or narrow the disputes before seeking court intervention All parties are to a:ct courteously and professionally in the attempted resolution of the disputes prior to setting a hearing All notices of hearings for matters scheduled on the Uniform Motion Calendar shall set forth directly above the signature block the below certifications without modification and shall designate with a check mark or other marking the specific certification which applies Counsel lzas conferred witlz_allparties wlzo i,ay be affected by tlze relief soug/zt iu tlze motion in a good faitlz effort to resolve or narrow tlze issues raised Counsel It as made reasonable efforts to confer with all parties wlto may be affected by tlte relief soug/zt in tlte motion butlzas been unable to do so EXHIBITD Failure to make a good faith attempt at resolving the issues may in the courts discretion result in the motion being stricken from the Uniform Motion Calendar and/or the imposition of sanctions The court may waive the good faith attempt at resolving the issues in appropriate circumstances To the extent possible counsel shall 267advise the Court in advance of the hearing of cancellation or resolution of some or all of the issues raised by the motion Hearings shall be limited to ten minutes per case If two parties each side shall be allotted five minutes If more than two parties the time shall be allocated by the Court The ten-minute time limitation shall include the time necessary for the Court to review documents memoranda case authority etc The movirig party must furnish the court a copy of the motion to be heard together with a copy of the notice of hearing Also all parties shall furnish the Court with copies of all documents pleadings and case authority which they wish the Court to consider SCHEDULING Except in the criminal division counsel shall not make appointments with the Courts judicial assistant but shall notice opposing counsel pursuant to the applicable rules of civil procedure and the Standards of Professional Courtesy and CiviUty which have been endorsed by the judges of the Fifteenth JudiciaLCircuit The courtroom deputy shall call cases for hearingin the order in which counsel signed up on the sheet posted outside the hearing room Failure of any party to appear at the time set for the commencement of the calendar shall not prevent a party from proceeding with the hearing Ifa party called for hearing chooses.to wait for an absent party the matter will be passed over but shall retain its position on that days calendar DONE and SIGNED in Chambers at West Palm Beach Palm Beach County Florida this day of I I Amends Local Rule approved in Amendments in bold approved by the Supreme Court of Florida June
