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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
of this Proposal, Edwards shall sign and deliver to Epstein's counsel a Stipulation of Settlement and Dismissal With Prejudice. The exact forms of the Stipulation of Settlement and Dismissal and proposed Agreed Final Order of Dismissal are attached as Composite Exhibit A. ii. Within ten days of Edwards' written acceptance
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
of this Proposal, Edwards shall sign and deliver to Epstein's counsel a Stipulation of Settlement and Dismissal With Prejudice. The exact forms of the Stipulation of Settlement and Dismissal and proposed Agreed Final Order of Dismissal are attached as Composite Exhibit A. ii. Within ten days of Edwards' written acceptance
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
of this Proposal, Edwards shall sign and deliver to Epstein's counsel a Stipulation of Settlement and Dismissal With Prejudice. The exact forms of the Stipulation of Settlement and Dismissal and proposed Agreed Final Order of Dismissal are attached as Composite Exhibit A. ii. Within ten days of Edwards' written acceptance
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
of this Proposal, Edwards shall sign and deliver to Epstein's counsel a Stipulation of Settlement and Dismissal With Prejudice. The exact forms of the Stipulation of Settlement and Dismissal and proposed Agreed Final Order of Dismissal are attached as Composite Exhibit A. ii. Within ten days of Edwards' written acceptance
Entities connected to both Fourth Amended and the Stipulation of Settlement

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONScott Rothstein
PERSONJack Goldberger
PERSONJack Scarola
PERSON
Donald Trump
PERSONTonja Haddad Coleman
PERSONPalm Beach Lakes Boulevard
LOCATIONGoldberger & Weiss
ORGANIZATION
Palm Beach County
LOCATION
Searcy Denney Scarola Barnhart & Shipley
ORGANIZATIONChambers
PERSONTONJA HADDAD
ORGANIZATIONFlorida Rule of Civil
ORGANIZATIONADJUDGES
ORGANIZATIONthe Total Amount
ORGANIZATIONthe "Litigation"
ORGANIZATION
Lauderdale
LOCATIONthe Total Amount of this Proposal
ORGANIZATION
SEARCY DENNEY
ORGANIZATION