03-23-10 10:30 FROU-LEDPOLONKUV1111, P.A. T-403 P.001/003 F-193 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA B.B, CASE NO: Plaintiff, S02008CA037319XXXXM.11 AB vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S NOTICE OF FILING PILIOPOSAL, TO DEFENDANT JEFFREY EPSTEIN Plaintiff, B.B., by and through her undersigned counsel, hereby gives Notice of Filing a Proposal for Settlement to Defendant, JEFFREY EPSTEIN. HEREBY CERTIFY that a true and correct copy of the foregoing was famished by U. S. Mail, postage prepaid, this22 day of March, 2010, to Jack A. Goldberger. Esq., ■ Bruce E. Reinhart, Esq IIIII Robert D. Crinon, Jr., Michael J. Pike, IIII EFTA00604998
03-23-10 16:36 FROWLEOPOLD,KUVIN, P.A. 7-403 P.002/003 F-103 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA B33, CASE NO: Plaintiff, 50200SCA037319XXXXMB AB vs. JEFFREY EPSTEIN, Defendant. PROPOSAL FOR SETTLEMENT FROM B.B. The Plaintiff, B.B., by and through her undersigned attorneys, serves the following Proposal for Settlement upon the Defendant, JEFFREY EPSTEIN, and states: 1. This proposal is made pursuant to Florida Rules of Civil Procedure, Rule 1.442, and applicable Florida Law, Florida Statute §768.79. 2. This proposal is served to Defendant JEFFREY EPSTEIN. 3. This proposal Is being made for the purpose of resolving all pending claims in this action between the Plaintiff, B.B., and .IEFFItEY EPSTEIN resulting from an incident which occurred between B.B. and JEFFREY EPSTEIN. 4 The total amount of this Proposal for Settlement is THREE I IUNDRED EIGHTY THOUSAND ($380,000.00) Dollars. 5 This Proposal for Settlement includes any and all claims for punitive damages. 6. All parties shall bear their own costs and attorneys fees. EFTA00604999
03-23-10 16:36 FROWLEOPOLD,,KUVIN, P.A. 1-403 P 003/003 F-103 Banyon Boulevard, Suite 400 7. Plaintiff, B.B., agrees that if Defendant JEFFREY EPSTEIN accepts this proposal, upon acceptance of the terms of this proposal Plaintiff, B.B. will dismiss Defendant JEFFREY EPSTEIN with prejudice in the above captioned matter. HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by U. S. Mail, postage prepaid, this g day of March, 2010 to Jack A. Goldberger, Esq.1.1.113 ; Bruce E. Reinhart, ; Robert D. Clifton, Jr., Michael J. Pikes Page 2 of 2 EFTA00605000
