Epstein Secrets

ter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S PROPOSAL FOR SETTLEMENT TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY J. EDWARDS, INDIVIDUALLY Plaintiff/Counter-Defendant, Jeffrey Epstein, hereby propo

sal for Settlement and Offer of Judgment ("Proposal") a. Parties: The party making this Proposal is Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"). The party to whom this Proposal is being made is Defendant/Counter- Plaintiff, Bradley J. Edwards, individually ("Edwards"). In this Proposal, Eps

ela M. Many (FBN 26680) Primary: Primary: Primary: Secondary: Secondary: Secondary: Secondary: Trial Counsel for Plaintiff/Counter-Defendant Jay Epstein SERVICE LIST Jack Scarola Nichole J. Segal Searcy, Denny, Scarola, Barnhart & Shipley, . Burlington & Rockenbach, 2139 Palm Beach Lakes Bouleva

OUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT

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

er-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S PROPOSAL FOR SETTLEMENT TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY J. EDWARDS. INDIVIDUALLY Plaintiff/Counter-Defendant, Jeffrey Epstein, hereby propo

sal for Settlement and Offer of Judgment ("Proposal") a. Parties: The party making this Proposal is Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"). The party to whom this Proposal is being made is Defendant/Counter-Plaintiff, Bradley J. Edwards, individually ("Edwards"). In this Proposal, E

CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Case No. 50-2009CA040800XXXXMBAG Plain

L 33301 Primary: Secondary: Co-counsel for Jef•ey Epstein Jack A. Goldberger Atterbuiy, Goldberger & Weis

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

Description of the Litigation and the Class This Notice relates to a proposed settlement of claims in a pending class action brought by victims of Jeffrey E. Epstein's ("Epstein") sex trafficking venture, which alleged, among other things, that Defendant violated the Trafficking Victims Protection Act ("TVPA") by p

is Case 5. This case grew out of our firms' long representation of the survivors of Jeffrey Epstein's sex trafficking ring. EHL began representing Epstein survivors in 2009. BSF began representing Epstein survivors in the first half of 2014. 6. By 2021, our firms had successfully brought lawsuits aga

s in a pending class action brought by victims of Jeffrey E. Epstein's ("Epstein") sex trafficking venture,

s in a pending class action brought by victims of Jeffrey E. Epstein's ("Epstein") sex trafficking venture, w

hearing (the "Settlement Hearing") to be held by the Court to consider the fairness, reasonableness, and adequacy of the Settlement as set forth in the Stipulation of Settlement dated June 22, 2023 (the "Stipulation") by and between Class Representative Jane Doe 1 ("Class Representative"), on behalf of itself and the Class

("GVI") has established a mental health fund (the "Mental Health Fund") to provide a financial resource for mental health services for survivors of Jeffrey Epstein that I will be administering. As a Class Member of both the Epstein DB Fund and the Epstein JPM Fund, you are eligible to apply for approved mental

Simone Lelchuk, Claims Administrator Epstein Survivors' Settlement Fund JPM do Freika PLL Ja

urce for mental health services for survivors of Jeffrey Epstein that I will be administering. As a Class

after reading this letter and seek support as needed. All capitalized terms not otherwise defined herein have the meaning set forth and defined in the Stipulation of Settlement dated June 22, 2023 (the "JPM Stipulation") [ECF No. 181-1]. I have fully evaluated all Questionnaires and Releases submitted to me from Participat

ing information: the circumstances, severity, type, and extent of the alleged abuse or trafficking, the nature and duration of the relationship with Jeffrey Epstein, and the impact of the alleged conduct on the Participating Claimant. Participating Claimants shall submit under penalty of perjury such other suppo

tional information you which to share with the Claims Administrator including any additional information about the harm you suffered as a result of Epstein's conduct if not already described in your prior answers. 12. Everything that you submit to the Claims Administrator will be kept completely confide

the nature and duration of the relationship with Jeffrey Epstein, and the impact of the alleged conduct on

August 7, 2023 to opt-out, or be excluded, from the Settlement. I All capitalized terms not otherwise defined herein have the meanings set forth in the Stipulation of Settlement dated June 22, 2023. To the extent there is any conflict between the definitions of capitalized terms in these Settlement Forms and the Stipulation,

er-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S PROPOSAL FOR SETTLEMENT TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY J. EDWARDS. INDIVIDUALLY Plaintiff/Counter-Defendant, Jeffrey Epstein, hereby propo

sal for Settlement and Offer of Judgment ("Proposal") a. Parties: The party making this Proposal is Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"). The party to whom this Proposal is being made is Defendant/Counter-Plaintiff, Bradley J. Edwards, individually ("Edwards"). In this Proposal, E

CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Case No. 50-2009CA040800XXXXMBAG Plain

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

er-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S PROPOSAL FOR SETTLEMENT TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY J. EDWARDS. INDIVIDUALLY Plaintiff/Counter-Defendant, Jeffrey Epstein, hereby propo

sal for Settlement and Offer of Judgment ("Proposal") a. Parties: The party making this Proposal is Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"). The party to whom this Proposal is being made is Defendant/Counter-Plaintiff, Bradley J. Edwards, individually ("Edwards"). In this Proposal, E

CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Case No. 50-2009CA040800XXXXMBAG Plain

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