IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, MEMORANDUM OF LAW IN SUPPORT OF MOTION TO DISOUALIFY Counter-Plaintiff, Bradley J. Edwards, by and through his undersigned attorneys, files this Memorandum of Law in support of his Motion to Disqualify Attorney Fred Haddad, from further participation in this proceeding. BACKGROUND AND FACTS SUPPORTING DISQUALIFICATION Edwards represented and continues to represent victims of sexual assault at the hands of Epstein in civil actions filed against Epstein and in a pending crime victim's rights act claim in Federal District Court. During the time of this representation, Edwards was recruited by Russell Adler and hired by the Rothstein Rosenfeldt Adler firm ("RRA"). Edwards brought the Epstein files with him to RRA. On or around November 1, 2009 RRA was closed as a result of Rothstein's (the president of RRA) involvement in a massive Ponzi scheme. While at RRA, Edwards worked in the personal injury tort division. His supervisor was Russell Adler, head of the division. During this time frame Edwards had numerous discussions and meetings at which Adler was present regarding the Epstein cases. These discussions involved strategy and EFTA01112075