IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), 1:-tr joiti5= VS. O SCOTT ROTHSTEIN individually, J. individually, and L.M., individually, rn cam n • n -0 rn tri .rn 7-t Defendant(s). CO 0 MOTION TO DISQUALIFY OPPOSING COUNSEL Counter-plaintiff, J. 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: 1. Mr. Haddad served as defense counsel for Russel Adler, a former law partner of Mr. 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. EFTA02771243