Epstein Secrets

ALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Case No. 50-2009CA040800XXXXMBAG Plaintiff/Counter-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

ant, Jeffrey Epstein ("Epstein"). The party to whom this Proposal is being made is Defendant/Counter-Plaintiff, Bradley J. Edwards, individually ("Edwards"). In this Proposal, Epstein and Edwards will be referred to collectively as the "Parties." b. Claims this Proposal is Attempting to Resolve: Acce

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

were raised or could have been raised relating to or arising out of that certain action styled Jeffrey Epstein v. Scott Rothstein, individually and Bradley J. Edwards, individually, 15th Judicial Circuit, Palm Beach County, Florida, Case No. 2009-CA- 040800XXXXMG-AG. It is further understood and agreed that this G

dant, Jeffrey Epstein ("Epstein"). The party to whom this Proposal is being made is Defendant/Counter- Plaintiff, Bradley J. Edwards, individually ("Edwards"). In this Proposal, Epstein and Edwards will be referred to collectively as the "Parties." b. Claims this Proposal is Attempting to Resolve: Acce

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

ed June 21, 2023. I declare under penalty of perjury that the foregoing is true and correct. Dated: June 22, 2023 Respectfully Submitted, By: Zs/ Bradley J. Edwards David Boies Boies Schiller Flexner LLP 55 Hudson Yards New York, NY 10001 Telephone: (212) 446-2300 Facsimile: (212) 446-2350 Email: dboies@bs

estify, I could and would testify competently to the following facts. 3. The two law firms representing Plaintiffs, Boies Schiller Flexner LLP and Edwards Henderson Lehrman (collectively, "Class Counsel"), have invested significant resources into investigating and litigating this case and as such, hav

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

ALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Case No. 50-2009CA040800XXXXMBAG Plaintiff/Counter-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

ant, Jeffrey Epstein ("Epstein"). The party to whom this Proposal is being made is Defendant/Counter-Plaintiff, Bradley J. Edwards, individually ("Edwards"). In this Proposal, Epstein and Edwards will be referred to collectively as the "Parties." b. Claims this Proposal is Attempting to Resolve: Acce

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

ALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Case No. 50-2009CA040800XXXXMBAG Plaintiff/Counter-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

ant, Jeffrey Epstein ("Epstein"). The party to whom this Proposal is being made is Defendant/Counter-Plaintiff, Bradley J. Edwards, individually ("Edwards"). In this Proposal, Epstein and Edwards will be referred to collectively as the "Parties." b. Claims this Proposal is Attempting to Resolve: Acce

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