From: Darren Indyke czl To: Lesley Groff Subject: Fwd: Privileged and Confidential Date: Tue, 27 Aug 2013 18:51:47 +0000 DARREN K. INDYKE DARREN K. INDYKE, PLLC 575 Lexington Avenue, 4th Floor New York, New York 10022 Telephone: Telecopier: Mobile: email: ************************** ******* ************ ***** ** ********** ** ******** *** *********** ******** The information contained in this communication is confidential, may be attorney-client privileged, and is intended only for the use of the addressee. It is the property of Darren K. Indyke, PLLC. Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail, and destroy this communication and all copies thereof, including all attachments. Copyright of Darren K. Indyke, PLLC - © 2011 Darren K. Indyke, PLLC —All rights reserved. *********************************** ******** ** ******* ************* ************************** **** Begin forwarded message: From: Tonja Haddad Coleman Date: August 27, 2013 2:51:27 PM EDT To: Darren Indyke >, Jeffre Cc: Jack Goldberger Subject: RE: Privileged and Confidential Epstein <[email protected]> , Fred Haddad < 1:30 or after is better for me. I have a 12:30 appointment. Here is an agenda for the conference: 1. Motion to Compel re: Deposition Questions a. if we are moving to exclude certain things and/or prevent Edwards from using them I do not want to compel discovery from him on it; and b. Attorney/client privilege argument 2. Trial Exhibit and Witness list from Edwards 3. Do we have an expert? Are we going to call Scherer? 4. Advice of Counsel Defense and Discovery EFTA00384930