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ntitled to fees and costs. H. ANALYSIS The requirements for a valid proposal for settlement are set forth in section 768.79, Florida Statutes, and Florida Rule of Civil Procedure 1.442. The offer of judgment statute and rule must be strictly construed, as they are in derogation of the common law rule that each party
al for settlement. See Bd of Motets of Florida Ad. Univ. v. Bowman, 853 So. 2d 507, 509 ,(Fla. 4th DCA 2003) ("In the instant case, the language in the General Release, even:though expansive, is typical of other general releases and is clear and unambiguous. The fact „that Plaintiffs are required to release Defend
titled to fees and costs. II. ANALYSIS The requirements for a valid proposal for settlement are set forth in section 768.79, Florida Statutes, and Florida Rule of Civil Procedure 1.442. The offer of judgment statute and rule must be strictly construed, as they are in derogation of the common law rule that each party
for settlement. See Bd. of Trustees of Florida Ail. Univ. v. Bowman, 853 So. 2d 507, 509 (Fla. 4th DCA 2003) ("In the instant case, the language in the General Release, even though expansive, is typical of other general releases and is clear and unambiguous. The fact that Plaintiffs are required to release Defenda
ntitled to fees and costs. IL ANALYSIS The requirements for a valid proposal for settlement are set forth in section 768.79, Florida Statutes, and Florida Rule of Civil Procedure 1.442. The offer of judgment statute and rule must be strictly construed, as they are in derogation of the common law rule that each party
l for settlement. See Bd. of Trustees of Florida Ad Univ. v. Bowman, 853 So. 2d 507, 509 (Fla. 4th DCA 2003) ("In the instant case, the language in the General Release, even though expansive, is typical of other general releases and is clear and unambiguous. The fact that Plaintiffs are required to release Defenda
ugh his undersigned counsel, hereby serves this Proposal for Settlement upon Plaintiff, MC2 MODEL & TALENT MIAMI, LLC, pursuant to F.S. §768.79 and Florida Rule of Civil Procedure 1.442: 1. This Proposal is being made pursuant to F.S. §768.79 and Florida Rule of Civil Procedure 1.442. 2. This Proposal is made on
. S. The conditions of this Proposal are: (1) that Plaintiff, MC2 MODEL & TALENT MIAMI, LLC, shall execute and deliver to the undersigned counsel, the General Release, attached hereto, as Exhibit A. and (2) that Plaintiff, MC2 MODEL & TALENT MIAMI, LLC, shall, by and through his attorney, execute and deliver to t
Entities connected to both Florida Rule of Civil and the General Release

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONScott Rothstein
PERSONJack Scarola
PERSON
George W. Bush
PERSONTonja Haddad Coleman
PERSONBurlington & Rockenbach
ORGANIZATIONFred Haddad
PERSONChambers
PERSONMarc Nurik
PERSON
William B. King
PERSONthe Florida Rules of Civil Procedure
ORGANIZATIONBowman
PERSONJoseph L. Ackerman
PERSON
Nichols
PERSONZiadie
PERSONthe Court on Counter-Defendant's
ORGANIZATIONthe Offer of Judgment
ORGANIZATIONAlamo Fin
ORGANIZATION