IN THE CIRCUIT COURT OF THE

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800X3OOCMBAG JEFFREY EPSTEIN, Plaintiff(s), VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and M., individually, Defendant(s). MOTION TO DISQUALIFY OPPOSING COUNSEL Counter-plaintiff, Bradley J. Edwards, by and through his undersigned attorneys, moves this Honorable Court for entry of an order disqualifying Attorney Fred Haddad, from further participation in this proceeding and in support thereof would show: I. Mr. Haddad served as defense counsel for Russel Adler, a former law partner of Mr. Edwards at the firm of Rothstein Rosenfeldt & Adler (RRA). 2. The subject matter of the representation included matters directly related to circumstances at issue in this proceeding, including specifically the legitimacy of the prosecutions against Mr. Epstein and the extent to which members of the RRA firm other than Rothstein knew of and participated in the Ponzi scheme orchestrated by Rothstein. 3. In the course of Mr. Haddad's representation of Mr. Adler, Mr. Haddad was afforded unrestricted access to the files of RRA including the litigation files generated in the course of prosecuting claims against the counter-defendant, Jeffrey Epstein. EFTA01112635 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Motion to Disqualify Opposing Counsel 4. Included among the Epstein files are materials protected by attorney-client and work product privilege. Those privileges have been consistently asserted in the context of this litigation to protect the interests of RRA's former clients who continue to be represented by Mr. Edwards in a currently pending Federal Court action. 5. Mr. Haddad's access to materials to which he is denied access in the context of this litigation creates an irreconcilable conflict of interest which prejudices the counter-plaintiff and compromises the counter-plaintiffs obligations to preserve the confidences of his clients. Wherefore, the counter-plaintiff respectfully requests the entry of an order disqualifying Mr. Haddad from further involvement in this matter. I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve Ih to all Counsel on the attached list, this , 2012. a Bar No.: 169440 ary E-mail: condary E-mail(s): Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: Fax: Attorney for Bradley J. Edwards 2 EFTA01112636 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Motion to Disqualify Opposing Counsel COUNSEL LIST Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Phonil= Fax: Attorneys for Jeffrey Epstein Bradley J. Edwards, Esquire Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, FL 425 North Andrews Avenue, Suite 2 Fort Lauderdale FL 33301 PhonME Fax: Fred Haddad, Es uire Fred Haddad, P.A. One Financial Plaza, Suite 2612 Fort Lauderdale. FL 33394 Phon Fax: Attorneys for Jeffrey Epstein 3 Marc S. Nurik, itEsquire Law Offices of Marc S. Nurik One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Pho Fax:( Attorneys for Scott Rothstein Lilly Ann Sanchez, Esquire The L-S Law Firm 1441 Brickell Avenue, 15th Floor Miami, FL 33131 Phon Fax: Attorneys for Jeffrey Epstein Ton'a Haddad Coleco Esquire Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Phon Fax: Attorneys for Jeffrey Epstein EFTA01112637