EFTA00802367
EFTA00802368 DataSet-9
EFTA00802370

EFTA00802368.pdf

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November , 2018 BradleyJ. Edwards Edwards Pottinger LLC 425 N Andrews Ave #2 Fort Lauderdale, FL 33301 Dear Mr. Edwards: You and I have been litigating against each other in several matters since 2008, and, in connection with our competing legal claims, directly as adverse parties since December 2009. With the legal claims on behalf of your clients behind us years ago [Jeffrey, this ignores and my initial lawsuit against you withdrawn in August 2012, I am gratified that in your counterclaim against me we now have been able to reach a settlement. Our settlement agreement and mutual releases reasonably and fairly take into account our respective legal positions and the extent of monetary damages you claimed to have actually incurred as a result of my commencement of suit against you, not to mention the exposure to liability for costs and fees as a result of your rejecting my offers for judgment, and the substantial certainty of years of prolonged appellate review no matter in whose favor the litigation would have turned. Having agreed to settle with you, making a significant payment to you and releasing you from any liability for costs or attorney's fees or any further liability as a consequence of your counterclaim and your rejection of my offers of judgment, I think you will agree that any legal (or even moral) duty to you has been fully discharged. [Note, Jeffrey, that the concessions in the next two paragraphs will work to undermine to some extent claims that we might assert against Fowler White or Rothstein. These concessions are likely less than Edwards might ask for, but I think what I provided at least includes areas Edwards would probably want to cover, short of any statements about the girls' claims. Obviously, I made no statements about any of the girls' claims.] Having said that, however, with the business of our dispute now behind me, and having had ample time to reflect on these matters, I see now that I weighed too heavily the private and public statements of others. I initially rushed to judgment in bringing suit against you in the honest but mistaken belief, based on the government allegations of Scott Rothstein's criminal wrongdoing and general third-party allegations of impropriety in the client suits you were litigating against me, that you knew or should have known of the use of your clients' lawsuits against me in the Ponzi scheme. Although I mistakenly believed in your involvement from the time that I commenced suit and even past the time that I withdrew my claim, I recognize now that I was wrong. EFTA00802368 I now see clearly that you were never implicated in the criminal conviction of Scott Rothstein. I also see that you were never named or identified as a defendant or malfeasor in any third-party lawsuits brought against Scott Rothstein or his firm. I now understand that the litigation conduct complained of in those third-party lawsuits which pertained to your client cases against me, although unorthodox, was honestly believed by you to be a proper and necessary result of what you understood to be challenging circumstances and was never intended by you to further any Ponzi scheme. Indeed, neither the government nor any court has made any determination that you engaged in any improprieties whatsoever, and the Florida Bar specifically determined that no disciplinary action was warranted against you for any unlawful conduct or other improprieties committed by Rothstein or others at Rothstein's firm. With all of this in mind, the benefit of hindsight and the wisdom gained from 10 years of prolonged litigation, I want to formally apologize to you and your family. I wish you to know that I regret having brought suit against you and the 9 years of ill will that this has engendered. I hope that you might one day recognize the sincerity of my words and forgive all that has transpired between us. Until then, I wish you continued prosperity in both your professional and personal life. Sincerely, EFTA00802369
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EFTA00802368
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DataSet-9
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document
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2

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