• WEST PALM OFFIC1F. 2139 PALM BEACH LAKES Diva REST RUM BEACH. FLORIDA 33409 P.O. BOX 3626 NEST RUM BEACH. FLORIDA 33402 SpsnIsh ATTCONEYS AT LAW. ROSALYN MEURER BARNES Y.ORICIORT BARNHART / HARDEE BASS III URINE J BRIGGS BRAN Fl. DEARLY AROMA S. EOLMER MARIANO GARCIA JAPES W. CAISTAFSON. JR. JACK P HU. DAVID K. KELLEY...R. CAMEICH M KEMNIEDE wI.U.A/A B. KNO$ DARRYL L LENTO AMMAR A. TODITTON PATRIOT E OUTUANT EDWARD V RICO *JOHN SCAROLA •Owarmt• 0. SCAR°. *JOHN A. SHAPLEY el CHRISTOPHER X. SPEED " MAN P SUUNAN I N KAREN E. TURN DEXIN.D J WARD $i C. CALVIN WARRIOR • RE CnoNAFT 'EARL L. DEFINEr. JR S swam/mem *sow Minna ALIKINICEI 'Komori T YAM MARYLAND ALASSAC-USETTS $ VI SR THEW HAMPSHIRE $ :TEW JERSEY IP VIRGINIA • WASIK/LINTON DC PARALEGALS: VIVIAN AYAN.TEJEDA RAIO LL DUFRESNE DAVID W OLMORE JOHN C NOINONS OE BORON IA KNAPP ViNCENT L. LECNARO. JR. AWES PETER LOVE ROBERT W. ARCHER MOW P. RCM/ KATIASEN BILKXI STEVE IA SAWN BONNE S STARK WALTER A. STEW SEARCY DENNEY SCAROLA BARNHART HIPLEY,A VIA EMAIL and U.S. Mail September 12, 2012 Fred Haddad, Esquire One Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 Re: Edwards adv. Epstein Dear Fred: o wI maRP.FF ()Met THE TONLE HOUSE 517 NORTH CALHOUN STREET TALLAHASSEE. FL 3230/1231 Brad Edwards has reminded me of your representation of Russ Adler in matters directly relating to many of the same issues presently in contention in the pending litigation against Jeffrey Epstein. Indeed, when Russ was deposed in our case, you appeared on his behalf, obviously supporting his position that neither he nor Brad was a knowing participant in the Rothstein Ponzi scheme. As counsel to Adler you had complete access to all of the RRA files relating to Brad's prosecution of the civil claims against Epstein including all attorney work-product and attorney-client privileged communications. Those are documents as to which we have asserted and continue to assert all applicable privilege objections. It certainly appears that these circumstances place you in an untenable conflict position, and since the privileges involved include privileges that belong to Brad's clients and to the former clients of RRA and Russ Adler, this is a conflict that Brad cannot waive. While we would otherwise welcome your appearance as a presumed voice of reason on the opposite side of this case, we must and do object to any participation by you in thepprt station of Mr. Epstein. Please notice your immediate withdrawal. JACK SCAROLA JA/mep cc: Bradley J. Edwards, Esq. WWW.SEARCTLAW.0012 EFTA01120096