Epstein Secrets

ney Scarola Barnhart & Shipley 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Primary: Primary: Primary: Counsel for Bradley J. Edwards TONJA HADDAD, •. 5315 S.E. Seventh Street, Suite 301 By: /s/ Tonja Haddad Coleman Tonja Haddad Coleman (FBN 0176737) Primary: Secondary: - and — Jack A. Go

st that the Court enter the attached Agreed Final Order of Dismissal With Prejudice. EFTA00807741 DATED: DATED: SEARCY DENNEY SCAROLA BARNHART TONJA HADDAD, P.A. & SHIPLEY, P.A. 5315 S.E. Seventh Street, Suite 301 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 By: By: Tonja Haddad Col

roposal. e. Amount Proposed to Settle Claim for Punitive Damages, If Any: Edwards has asserted a claim against Epstein for punitive damages in his Fourth Amended Counterclaim. The Total Amount set forth in paragraph 2(d) above includes payment of $20,000 for Edwards' claim for punitive damages. The total amo

relief as deemed necessary and proper. 6 EFTA00691828 /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737 LAW OFFICES OF TONJA HADDAD, PA 315 SE 7th Street Suite 301 ' 301 WE HEREBY CERTIFY that a true and correct copy of the foregoing was served upon all parties listed below,

d factually deficient Motion for Protective Order. In support thereof, Epstein states: INTRODUCTION On or about January 9, 2013, Edwards filed his Fourth Amended Counterclaim against Epstein, asserting therein that he suffered the following damages: "a) injury to his reputation; b) mental anguish, embarrassm

BREWER, JR., P.A. 250 S. Australian Avenue, Suite 33401 West Palm Beach, FL 33401 By W. CHESTER BREWER, JR., P.A., ESQUIRE For Jeffrey Epstein: TONJA HADDAD, P.A. 315 S.E. 7th Street, Suite 301 Fort Lauderdale, FL 33301 By TONJA HADDAD COLEMAN, ESQUIRE For Jeffrey Epstein: ATTERBURY, GOLDBERGER & WEI

rocess claim has been disposed of. It was successfully won on the summary judgment and is no longer an issue. So the only operative portion of the Fourth Amended Counterclaim is count two, malicious prosecution. In that complaint, Judge, against Mr. Epstein, Mr. Edwards asserts in paragraph 24, "While pro

ney Scarola Barnhart & Shipley 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Primary: Primary: Primary: Counsel for Bradley J. Edwards TONJA HADDAD, P.A. 5315 S.E. Seventh Street, Suite 301 Ft. Lauderdale. Florida 33301 By: /s/ Tonja Haddad Coleman (FBN 0176737) Primary: Secondary: - and —

roposal. e. Amount Proposed to Settle Claim for Punitive Damages, If Any: Edwards has asserted a claim against Epstein for punitive damages in his Fourth Amended Counterclaim. The Total Amount set forth in paragraph 2(d) above includes payment of $100,000 for Edwards' claim for punitive damages . The total a

ney Scarola Barnhart & Shipley 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Primary: Primary: Primary: Counsel for Bradley J. Edwards TONJA HADDAD, P.A. 5315 S.E. Seventh Street, Suite 301 Ft. Lauderdale, Florida 33301 (954) 467-1223; (954) 337-3716 [fax] By: /s/ Tonja Haddad Coleman Tonja

roposal. e. Amount Proposed to Settle Claim for Punitive Damages, If Any: Edwards has asserted a claim against Epstein for punitive damages in his Fourth Amended Counterclaim. The Total Amount set forth in paragraph 2(d) above includes payment of $10,000 for Edwards' claim for punitive damages. The total amo