TONJA HADDAD PA September 26. 2013 Via Electronic Mail Jack Scarola, Esq. Searcy Denney et al. Re: Epstein v. Edwards et ed. Mr. Scarola: As discussed, the items listed below (numbered as they appear on your exhibit list) were never provided to us during discovery in this matter. Please advise if you agree that you will not use this substantial (and irrelevant) list of items, or if we need to address it in our Motion in Limine. Back on April 23, 2013, you were served with the following request as listed on Schedule A to Brad's deposition notice: 12. Copies of any and all documents you intend to introduce at trial in support of the allegations made by you in your Fourth Amended Counterclaim you filed in this matter. At the hearing on your Motion for Protective Order on June 10, 2013, you told the judge specifically that you were providing all items responsive to that request. 7 The last one is copies of any and all 8 documents you intend to introduce at trial in 9 support of the allegations made by you in the to fourth amended counterclaim. Again, we are 11 giving them all the evidence that we intend to 12 rely upon. See Transcript ofJune 10. 2013 hearing, p. 27, which is attached to this letter. 4. 9. II. 12. Video of Jeffrey Epstein's home and route from victim to Epstein's home Documents related to Jeffrey Epstein produced by Alfredo Rodriguez Jeffrey Epstein phone records 1 phone records EFTA01099380