## IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA

JEFFREY EPSTEIN,

Plaintiff,

v.

CIVIL DIVISION AG CASE NO. 502009CA040800XXXXMB Judge David F.

SCOTT ROTHSTEIN individually, and J. individually,

## 7'4C Defendants. MOTION TO WITHDRAW OF BURNETT AND ITS ATTORNEYS AS COUNSEL OF RECORD FOR PLAINTIFF/COUNTER-DEFENDANT, JEFFREY EPSTEIN

0 tin

Burnett, and its attorneys, as counsel of record for the Plaintiff/Counter-Defendant, Jeffrey Epstein, respectfully move, pursuant to the wishes of Mr. Epstein to retain new co-counsel, for the entry of an Order allowing Burnett and its attorneys to withdraw as counsel of record and as grounds therefore state as follows:

1. Epstein is currently co-represented by counsel of record Jack Alan Goldberge ., and Lilly Ann M, Esq. appeared in this action as co-counsel for Mr. Epstein on or about July 27, 2010, replacing the law firm of Burman, Critton, Luther and Coleman. left the employ of Burnett on February 29, 2012, and filed a notice of appearance on behalf of Mr. Epstein on March 16, 2012, for The L•S Law Firm. Mr. Epstein has indicated his intention to retain new cocounsel to replace Burnett.

1. Irreconcilable differences have arisen between the undersigned counsel and PlaintifKounter-Defendant, Jeffrey Epstein, creating the need for the discontinuance of representation of Mr. Epstein in the above-styled matter.

1. A dispute with Mr. Epstein regarding costs and fees under the Representation Agreement executed with Burnett also exists, further creating a need to withdraw.

1. None of the parties to this action would be prejudiced by the withdrawal of Burnett from this case because the case has not been set for trial.

1. Further pleadings and correspondence in this case should continue to be directed to the Plaintiff/Counter-Defendant Jeffrey Epstein's counsel, Jack Alan Goldberger, Esq., Atterbury, Goldberger & Weiss, P.A., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401-5012 and Lilly Ann ME, Esq., The L•S Law Firm, Four Seasons Tower, 15'h Floor, 1441 Brickell Avenue, Miami, FL 33131.

WHEREFORE, Burnett and its attorneys respectfully request that this Court enter an Order granting this Motion to Withdraw, releasing Burnett and its attorneys from any further obligation in this case.

## CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via U.S. Mail on this 23'd day of April, 2012 to Lilly Ann M, Esq., The L•S Law Firm, Four Seasons Tower, 15i° Floor, 1441 Brickell Avenue, Miami, FL 33131; Jack Alan Goldberger, Esq., Atterbury, Goldberger & Weiss, P.A., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401-5012; Marc S. Nurik, Esq., Law Offices of Marc S. Nurik, One East

## Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Division AG Motion to Withdraw as Counsel of Record for Plaintiff

Broward Boulevard, Suite 700, Fort Lauderdale, FL 33301; Jack Scarola, Esq., Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Boulevard, West Palm Beach, FL 33409; J. M, Esq., Farmer, Jaffe, Weissing, Fistos & Lehrman, P.L., 425 North Andrews Avenue, Suite 2, Fort Lauderdale, FL 33301; and Mr. Jeffrey Epstein 301 East 66th Street, Suite 10B, New York, NY 10065. O.)

Respectfully submitted,.

\~oseph L. Ackerman, Jr.

Florida Bar Nd. 235954 BURNETT, P.A.

901 Point West 777 South Flagler Drive . est Palm Beach, Florida 33401 elephone: (561) 802-9044 Facsimile: (561) 802-9976 Attorneys for Jeffrey Epstein, Plaintiff