IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. CASE NO. 502009CA040800)OOOCMB JEFFREY EPSTEIN, JUDGE: HAFELE PlaintifYCounter- Defendant, v. SCOTT ROTHSTEIN, individually and BRADLEY 1. EDWARDS, individually, Defendant/Counter- Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MEMORANDUM OF LAW REGARDING ETHICAL ISSUES RAISED BY DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS REGARDING ACCEPTANCE OF EPSTEIN'S PROPOSAL FOR SETTLEMENT Plaintiff/Counter-Defendant Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned counsel and pursuant to this Court's request on December 6, 2014, hereby files this Memorandum of Law regarding Defendant/Counter-Plaintiff Bradley Edwards's (hereinafter "Edwards") Opposition to Epstein's Motion for Attorneys' Fees and Costs on the issue of "ethical grounds" and states: INTRODUCTION On June 2, 2014, Epstein filed his Motion for Attorneys' Fees and Costs pursuant to §768.79 of the Florida Statutes and Rule 1.442 of the Florida Rules of Civil Procedure (hereinafter "Epstein's Motion"). On June 26, 2014, Edwards filed his Response in Opposition to Epstein's Motion for Attorneys' Fees and Costs, asserting therein that Epstein's Proposal for Settlement (hereinafter the "Proposal") failed to comply with the Tonja Haddad. P.A. • 315 SE Th Street. Fort Lauderdale, FL 33301* 954.467.1223 EFTA01200889