From: Tonja Haddad Coleman -ta To: Jack Scarola CC: Brad Edwards "M Haddad "Jack Goldbe Subject: RE: Epstein Date: Mon, 22 Oct 2012 20:06:50 +0000 E. Pirrotta" , Fred Well lucky for us your opinion is in direct contravention with the law. You last court-ordered amendment, for example, required you to properly plead your allegation of damages. Are you conceding that you cannot provide any proof of damages, and that the most recent amendment to Paragraph 32 does not change the substance of your Counterclaim? If not, you can expect a notice from us setting Mr. Edwards's deposition for Tuesday, November 13. Tonja Haddad Coleman, Esq. TONJA HADDAD, P.A. Advocate Building 315 SE 7th Street Fort Lauderdale, FL 33301 facsimile The information contained in this transmission may contain privileged and confidential information. It is intended only for the use of the person(s) named above. If you are not the intended recipient, you are hereby notified that any review, dissemination, distribution or duplication of this communication is strictly prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. Original Message From: Jack Scarola [mailto Sent: Monday, October 22, 2012 2:19 PM To: Tonja Haddad Coleman Cc: Brad Edwards; Mary E. Pirrotta; Fred Haddad; Subject: Re: Epstein It is our position that none of the amendments altered the factual substance of the counterclaim. Jack Scarola SEARCY DENNEY SCAROLA BARNHART & SHIPLEY, P.A. On Oct 22, 2012, at 12:36 PM, "Tonja Haddad Coleman" <MMIMI > wrote: > Mr. Scarola: > First, the right to continue the deposition of your client was preserved at his initial deposition on March 23, EFTA00661568