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COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff, 19 Civ. 10475 (LGS) -against- DARREN K. INDYKE, in his capacity as executor : of the Estate of Jeffrey Edward Epstein, et al., Defendants. LORNA G. SCHOFIELD, District Judge: X OPINION AND ORDER On January 21, 2021, Plaintiff iled a motion to dismiss this acti
k law. These claims stem from and/or arise in connection with Mr. EFTA00095371 Case 1:19-cv-10475-LGS-DCF Document 118 Filed 02/10/21 Page 2 of 6 Epstein's and Ms. Maxwell's alleged sexual abuse of Plaintiff. Defendants did not file counterclaims. On June 2, 2020, the Superior Court of the United Sta
Epstein Victims' Compensation Program, a voluntary independent program designed to compensate and resolve the claims of victims of sexual abuse by Jeffrey Epstein (the "Program"). On June 22, 2020, based on an understanding that Plaintiff wished to participate in the Program and that participation could result
pacities as appointed executors of the Estate of Jeffrey E. Epstein (the "Estate") (Indyke and Kahn together
pacities as appointed executors of the Estate of Jeffrey E. Epstein (the "Estate") (Indyke and Kahn together,
aintiff executed a release, releasing the Estate, Mr. Epstein and other related entities and individuals, incl
judice," and that each party shall "bear its own attorneys' fees and costs." It also states that "Plaintiff shall provide Ms. Maxwell with a copy of the General Release, with the compensation amount redacted" and that "[t]he parties shall not dispute the authenticity of this copy of the General Release in any futur
ADLEY J. EDWARDS. Defendants/Counter-Plaintiffs. ORDER GRANTING MOTION FOR FEES AND COSTS THIS CAUSE came before the Court on Counter-Defendant's, Jeffrey Epstein's, Motion for Fees and Costs filed on June 2, 2014. A hearing was held on December 8, 2014, at which counsel presented argument on the Motion. On Dec
iff/Counter-Defendant Jeffery Epstein's lawsuit against Defendants/Counter-Plaintiffs Bradley Edwards and Scott Rothstein. Edwards then countersued Epstein for malicious prosecution. Epstein voluntarily dismissed his initial suit. On August 25, 2011, Epstein served an Offer of Judgment ("Offer") on Edwa
L CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, CASE NO.: 2009CA040800XXXXMB CIVIL DIV
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
J. EDWARDS, Defendants/Counter-Plaintiffs. / ORDER GRANTING MOTION FOR FEES AND COSTS THIS CAUSE came before the Court on Counter-Defendant's, Jeffrey Epstein's, Motion for Fees and Costs filed on June 2, 2014. A hearing was held on December 8, 2014, at which counsel presented argument on the Motion. On Dec
iff/Counter-Defendant Jeffery Epstein's lawsuit against Defendants/Counter-Plaintiffs Bradley Edwards and Scott Rothstein. Edwards then countersued Epstein for malicious prosecution. Epstein voluntarily dismissed his initial suit. On August 25, 2011, Epstein served an Offer of Judgment ("Offer") on Edwa
L CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, CASE NO.: 2009CA040800XXXXMB CIVIL DIV
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
& TALENT MIAMI, LLC, Plaintiffs, vs. JEFFREY EPSTEIN; TYLER McDONALD; and TYLER McDONALD d/b/a YLORG
C2 MODEL & TALENT MIAMI, LLC, Plaintiffs, vs. JEFFREY EPSTEIN; TYLER McDONALD; and TYLER McDONALD d/b
; and MC2 MODEL & TALENT MIAMI, LLC, Plaintiffs, vs. JEFFREY EPSTEIN; TYLER McDONALD; and TYLER McDONALD d/b/a YLORG, Defendants. DEFENDANT, JEFFREY EPSTEIN'S PROPOSAL FOR SETTLEMENT TO PLAINTIFF, MC2 MODEL & TALENT MIAMI, LLC Defendant, JEFFREY EPSTEIN, by and through his undersigned counsel, hereby serv
. 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
IN THE CIRCUIT COURT OF THE 1.11.1BENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXIABAG JEFFREY EPSTEIN, Plaintifffs), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant(s). PROPOSAL FOR SETTLEM
PTS TO RESOLVE: All issues and claims for damages asserted by and against the Defendant, Jeffrey Epstein against and by EFTA00599839 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Proposal for Settlement Bradley J. Edwards and all issues and claims which could be asserted between Bradley J.
UNTY, FLORIDA CASE NO.: 502009CA040800XXXXIABAG JEFFREY EPSTEIN, Plaintifffs), vs. SCOTT ROTHSTEIN, in
of America, paid to him on behalf of JEFFREY EPSTEIN, the receipt whereof is hereby acknowledged, and for and in consideration of the execution of the General Release attached hereto as Exhibit #2 has remised, released, and forever discharged, and by these presents does for himself, as well as his heirs, survivor
L CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, CASE NO.: 2009CA0408003OOOCMB CIVIL DI
APPENDIX 1. Order Granting Fees and Costs of February 3, 2015 2. Epstein's Motion for Fees and Costs with attached pleadings dated June 2, 2014. EFTA00617978 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN A
ADLEY J. EDWARDS. Defendants/Counter-Plaintiffs. ORDER GRANTING MOTION FOR FEES AND COSTS THIS CAUSE came before the Court on Counter-Defendant's, Jeffrey Epstein's, Motion for Fees and Costs filed on June 2, 2014. A hearing was held on December 8, 2014, at which 't counsel presented argument on the Motion. On
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
Palm Beach November 30, 2018 Scott J. Link, Esquire LINK & ROCKENBACH, PA 1555 Palm Beach Lakes Blvd., Suite 930 West Palm Beach, FL 33401 Re: Epstein Dear Scott: James N. Hurley General Counsel (305) 789-9218 direct (305) 728-7518 fax Your correspondence of November 29, 2018 has been forwarde
and for $3 million. During its representation of Mr. Epstein, the Firm diligently pursued issues pertaining to
kell Avenue. 14th Floor I Miami. FL 33131 I EFTA00805051 November 30, 2018 Page 2 Likewise, we disagree entirely regarding the enforceability of the General Release which Mr. Epstein executed with full benefit of legal counsel. The terms are clear and unambiguous. The only specific issue of wrongdoing you have
Entities connected to both Jeffrey Epstein and the General Release

George W. Bush
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONScott Rothstein
PERSONJack Scarola
PERSONTonja Haddad Coleman
PERSONJoseph L. Ackerman
PERSONChambers
PERSONFred Haddad
PERSONBurlington & Rockenbach
ORGANIZATIONMarc Nurik
PERSON
Nichols
PERSONthe Florida Rules of Civil Procedure
ORGANIZATIONFlorida Rule of Civil
ORGANIZATION
William B. King
PERSONBowman
PERSONReleasees
ORGANIZATIONFarm Mut
PERSONMazoff
PERSONZiadie
PERSON