HOUSE_OVERSIGHT_013380.jpg

of the settlement were kept confidential. The sum that he paid to settle all these cases is therefore not filed with this pleading and will be provided to the court for in-camera review. Epstein chose to make this payment as the result of a federal court ordered mediation process, which he himself sought (over the objection of Jane Doe, Edwards’ client in federal court) in an effort to resolve the case. See Defendant’s Motion for Settlement Conference, or in the Alternative, Motion to Direct Parties back to Mediation, Doe v. Epstein, No. 9:08-CV-80893 (S.D. Fla. June 28, 2010) (Marra, J.) (doc. #168) attached hereto as Exhibit “A”. Notably, Epstein sought this settlement conference — and ultimately made his payments as a result of that conference - in July 2010, more than seven months after he filed this lawsuit against Edwards. Avsontingly, Epstein could not have been the victim of any scheme to “pump” the cases against him, because he nee paid to settle the cases until well after Edwards had left RRA and had severed all connection with Scott Rothstein (December 2009). In addition, if Epstein had thought that there was some improper coercion involved in, for example, Jane Doe’s case, his remedy was to raise the matter before Federal District Court Judge Kenneth A. Marra who was presiding over the matter. Far from raising any such claim, Epstein sinisly chose to settle that case. He is therefore now barred by the doctrine of res judicata from somehow re-litigating what happened in (for example) the Jane Doe case. “The doctrine of res judicata makes a judgment on the ‘vt conclusive ‘not only as to every matter which was offered and received to sustain or defeat the claim, but as to every other matter which might with propriety have been litigated and determined in that action.” AMEC Civil, LLC v. State Dept. of Transp.,___S0.2d__, 2010 WL 1542634 at *2 (Fla. 1" Dist. Ct. App. 2010) (quoting Kimbrell v. Paige, 448 So.2d 1009, 1012 (Fla. 1984). Obviously, any question of improper “pumping” of a 11 HOUSE_OVERSIGHT_013380