IN THE CIRCUIT COURT OF THE 15' JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, CASE NO. 502009CA040800XXXXMBAG Plaintiff, vs. SCOTT ROTHSTEIN, individually, J. individually and L.M., individually, '00 S'' X p• — r4 (..,3T, tg Komi --s -rt oCr7 27 I F Defendant(s). -•4 SCP ring 9 X / rn a •= a" RESPONSE IN OPPOSITION TO MOTION TO DISQUALIFY OPP0111NG9 HEARING :< rn COUNSEL. REQUEST FOR EVIDENT -n re % COMES NOW Fred Haddad, co-counsel for JeffreyEpV • and makes the following Response in Opposition to to his representation of 1. -t 4; f .c. Motion to Disqualify the undersigned apparently due Adler, and as grounds the undersigned would state as follows: The undersigned opposes disqualification and submits no conflict as asserted by exists. 2. states in his Motion [paragraphs 2, 3, 4 and 5]: 2. The lect st matter of the representation [Haddad representing Adler] 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. 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 Page 1 of 10 CLERKS OFFICE EFTA02771258