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roward Blvd., Ste. 700 Ft. Lauderdale, FL 33301 Bradley J. Edwards, Esq. 425 N. Andrews Ave., Ste. 2 Ft. Lauderdale, FL
is case arises from Plainfiffitounter-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 Augustin 2011, Epstein served an Offer of Jud
ger & 250 S. Australian Avenue Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esquire 1 East Broward Blvd. Suite 700 Ft. Lauderdale FL 301 Bradley J. Edwards Esquire Staftefil Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N. Andrews Avenue Suite 2 Ft. Lauderdale, FL 33301 Fred ' de I Financial Plaza S
, PA 250 Australian Ave. South Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esq. 1 East Btoward Blvd. Suite 700 Fort Lauderdale, FL 33301 Bradle J. Edwards Es . brad Fan a e eissing 425 N Andrews Avenue Suite 2 Fort Lauderdale, Florida 33301 Fred Haddad, Es . tnancta aza Suite 2612 Fort Lauderda
N, against Defendant/Counter-Plaintiff, BRADLEY EDWARDS, individually, and are not part of the legal claims brought by Defendant/Counte•-Plaintiff, BRADLEY EDWARDS, individually, against Plaintiff/Counter-Defendant, JEFFREY EPSTEIN. However, this Proposal is intended to resolve all such claims if available.
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
mla Fyn Jack Goldberger, Esq. Marc Nurik, Esq. Bradley J. Edwards, Esq. Fred Haddad, Esq. Tonja Haddad Coleman, Esq. W
is case arises from Plaintiff/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
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
a. Esa. Jack Goldberner, Esa. Marc Nurik, Esq. Bradley J. Edwards, Esq. Fred Haddad, Esq. Tonja Haddad Coleman, Esq. W
is case arises from Plaintiff/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
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
adv. Epstein Case No.: 502009CA040800XXXXMBAG Proposal for Settlement Bradley J. Edwards and all issues and claims which could be asserted between Bradley J. Edwards and Jeffrey Epstein whether known or unknown. 4. TOTAL AMOUNT OF PROPOSAL: Defendant/Counter-Plaintiff proposes to resolve all claims for damages
ROPOSAL ATTEMPTS 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
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
Entities connected to both Bradley Edwards and the General Release

Jeffrey Epstein
PERSONJack Goldberger
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJack Scarola
PERSONTonja Haddad Coleman
PERSONJoseph L. Ackerman
PERSONFred Haddad
PERSONChambers
PERSONBurlington & Rockenbach
ORGANIZATIONMarc Nurik
PERSONthe Florida Rules of Civil Procedure
ORGANIZATIONFlorida Rule of Civil
ORGANIZATION
William B. King
PERSON
Nichols
PERSONBowman
PERSONMazoff
PERSONReleasees
ORGANIZATIONthe Court on Counter-Defendant's
ORGANIZATIONthe Offer of Judgment
ORGANIZATION