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EFTA01122503

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In a separate civil proceeding, Mr. Epstein has sued attorney Bradley Edwards for abuse of process in state court. Bradley Edwards is one of the lawyers who represents the plaintiffs Jane Doe I and Jane Doe 2 in the case before this Court. Jeffrey Epstein is represented in that state court civil proceeding by Tonja Haddad, and Mr. Edwards is represented by Jack Scarola. The email that the plaintiffs Jane Doe 1 and Jane Doe 2 have asked this Court to consider as "supplemental authority" is an exchange between the lawyers Tonja Haddad and Jack Scarola concerning a motion to compel discovery that was granted by the state court in the civil case. The entire exchange between the two attorneys is attached here as EXHIBIT A. Among other things, the discovery that was compelled by the state court required that Mr. Scarola, on behalf of his client attorney Bradley Edwards, produce all emails and correspondence between Mr. Edwards and the U.S. Attorney's Office or the State Attorney's Office regarding or mentioning Jeffrey Epstein. The emails involve Mr. Edwards' efforts to have Jeffrey Epstein investigated and indicted. When Mr. Scarola complained to Ms. Haddad that emails between Bradley Edwards and the USAO or the SAO could be privileged, Ms. Haddad correctly responded that communications between Bradley Edwards and the USAO or the SAO concerning Jeffrey Epstein could not be privileged. The plaintiffs Jane Doe 1 and Jane Doe 2 now claim that this statement by Ms. Haddad — that communications between a lawyer (Bradley Edwards) and the government, concerning the lawyer's adversary, nemesis, and the subject of a criminal investigation (Jeffrey Epstein), are not privileged — somehow qualifies as supplemental authority concerning the dispute before this Court about plea negotiations. This is absurd. EFTA01122503

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