n. Epstein subsequently dismissed his Complaint without prejudice. The counter- claim proceeded, undergoing several amendments. As it now stands, the Fourth Amended Counterclaim has two causes of action: abuse of process and malicious prosecution. Epstein moved for summary judgment arguing that the litigation p

roposal. e. Amount Proposed to Settle Claim for Punitive Damages, If Any: Edwards has asserted a claim against Epstein for punitive damages in his Fourth Amended Counterclaim. The Total Amount set forth in paragraph 2(d) above includes payment of $10,000 for Edwards' claim for punitive damages. The total amo

n. Epstein subsequently dismissed his Complaint without prejudice. The counter- claim proceeded, undergoing several amendments. As it now stands, the Fourth Amended Counterclaim has two causes of action: abuse of process and malicious prosecution. Epstein moved for summary judgment arguing that the litigation p

roposal. e. Amount Proposed to Settle Claim for Punitive Damages, If Any: Edwards has asserted a claim against Epstein for punitive damages in his Fourth Amended Counterclaim. The Total Amount set forth in paragraph 2(d) above includes payment of $20,000 for Edwards' claim for punitive damages. The total amo

ent or deletion. APPROVAL OF AMENDMENT TO FOURTH AMENDED AND RESTATED VOTING AGREEMENT WHEREAS, the Company and certain Investors entered into the Fourth Amended and Restated Voting Agreement, dated June 16, 2011 (the "VA") in connection with the initial closing of the Series 5 Preferred Stock Financing; 12

d factually deficient Motion for Protective Order. In support thereof, Epstein states: INTRODUCTION On or about January 9, 2013, Edwards filed his Fourth Amended Counterclaim against Epstein, asserting therein that he suffered the following damages: "a) injury to his reputation; b) mental anguish, embarrassm

n. Epstein subsequently dismissed his Complaint without prejudice. The counter- claim proceeded, undergoing several amendments. As it now stands, the Fourth Amended Counterclaim has two causes of action: abuse of process and malicious prosecution. Epstein moved for summary judgment arguing that the litigation p

me before the court on Plaintiff/Counter-Defendant Jeffrey Epstein's Motion for Summary Judgment as to Defendant/Counter-Plaintiff Bradley Edwards's Fourth Amended Counterclaim. The Court, having considered the Motion and Responses, having heard argument of counsel, and being otherwise duly advised in the prem

roposal. e. Amount Proposed to Settle Claim for Punitive Damages, If Any: Edwards has asserted a claim against Epstein for punitive damages in his Fourth Amended Counterclaim. The Total Amount set forth in paragraph 2(d) above includes payment of $100,000 for Edwards' claim for punitive damages . The total a

n. Epstein subsequently dismissed his Complaint without prejudice. The counter- claim proceeded, undergoing several amendments. As it now stands, the Fourth Amended Counterclaim has two causes of action: abuse of process and malicious prosecution. Epstein moved for summary judgment arguing that the litigation p

roposal. e. Amount Proposed to Settle Claim for Punitive Damages, If Any: Edwards has asserted a claim against Epstein for punitive damages in his Fourth Amended Counterclaim. The Total Amount set forth in paragraph 2(d) above includes payment of $10,000 for Edwards' claim for punitive damages. The total amo

rchaser will acquire valid marketable title to the Shares, free and clear of any Encumbrances other than pursuant to the Transfer Restrictions, the Fourth Amended and Restated Voting Agreement, dated June 16, 2011, the Sixth Amended and restated Investor Rights Agreement, dated June 16, 2011 and the Third Amen

rocess claim has been disposed of. It was successfully won on the summary judgment and is no longer an issue. So the only operative portion of the Fourth Amended Counterclaim is count two, malicious prosecution. In that complaint, Judge, against Mr. Epstein, Mr. Edwards asserts in paragraph 24, "While pro