ice of David E. Borack, P.A., 2010 WL 597213, at *2 (11th Cir. Feb. 22, 2010) ("[T]he Law Office's Offer of Judgment also contained a condition-that Danow sign a confidential release. While it is difficult to assess the value of this condition, it presumably was worth something to the Law Office, sign

overy, which did not contain this condition, was 'more favorable' to Danow than that provided in the Offer of Judgment") (italics in original). In Danow, a defendant law firm offered to settle a debt collection lawsuit brought against it, by offering $1,000 in damages and $2,000 in fees and costs. Th

745 Fifth Avenue New York NY 10151 USA 1212-486-4444 Begin forwarded message: From: "Paul M. Kade" Date: April 11, 2018 at 6:12:10 PM EDT To: "Danow, Matthew" , "Epstein, Victoria" , Yaniv Nakash , "Amengual, Randolph" , J Cc: David Mitchell - Feldman Subject: Re: Life Hotel - Draft Third

45 Fifth Avenue New York NY 10151 USA 1212-4864444 Begin forwarded message: From: "Paul M. Kade" < Date: April 11, 2018 at 6:12:10 PM EDT To: "Danow, Matthew" Cc: David Mitchell "Epstein, Victoria" • >, Yaniv Nakash "Amen ual, Randol h" , J Feldman Subject: Re: Life Hotel - Draft Third Amen

tel - $100,000 Note to R Rosenthal DAVID MITCHELL Mitchell Holdings LLC 745 Fifth Avenue New York NY 10151 USA Begin forwarded message: From: "Danow, Matthew" Date: March 13, 2018 at 12:20:07 PM EDT To: "Howie W. Muchnick" Cc: David Mitchell Subject: Life Hotel - $100,000 Note to R Rosenthal "A

ue New York NY 10151 USA Begin forwarded message: From: "Amengual, Randolph" Date: March 9, 2018 at 10:20:32 AM EST To: "Howie W. Muchnick" Cc: "Danow, Matthew" Subject: Re: The hotel agreed to an immediate $50k loan. If that's acceptable we can prepare the loan does today. > On Mar 9, 2018, at 1

e New York NY 10151 USA Begin forwarded message: From: "Amengual, Randolph" Date: March 9, 2018 at 10:20:32 AM EST To: "Howie W. Muchnick" Cc: "Danow, Matthew" Subject: Re: The hotel agreed to an immediate $50k loan. If that's acceptable we can prepare the loan docs today. > On Mar 9, 2018, at 1

25 Oct 2017 18:32:10 +0000 fyi, DAVID MITCHELL Mitchell Holdings LLC 801 Madison Avenue New York NY 10065 USA Begin forwarded message: From: "Danow, Matthew" < Date: October 25, 2017 at 2:15:31 PM EDT To: Eric Sadkin Cc: David Mitchell Subject: RE: Life Hotel Pref Thanks, Eric. Matthew Dano

e need is for him to review and fund, DAVID MITCHELL Mitchell Holdings LLC 801 Madison Avenue New York NY 10065 Begin forwarded message: From: "Danow, Matthew" Date: October 25, 2017 at 2:15:09 PM EDT To: "Shields, Constance" Cc: David Mitchell •, Stu Rosen Randolph" Subject: Mitchell Brother

17 at 11:50 PM, David Mitchell < DAVID MITCHELL Mitchell Holdings LLC 801 Madison Avenue New York NY 10065 USA Begin forwarded message: From: "Danow, Matthew" < Date: October 18, 2017 at 11:04:44 AM EDT To: "Constance Shields Cc: David Mitchell Subject: Southampton - wrote: )"<', Constance—

23, 2017 1:40 PM To: Jeffrey Epstein Subject: Fwd: FYI DAVID MITCHELL Mitchell Holdings LLC M I</=> <mailto Begin forwarded message: From: "Danow, Matthew" Date: October 23, 2017 at 9:38:O9 AM EDT To: "Constance Shields Subject: > > Constance—Were you able to confirm that Alex=can close t

e New York NY 10151 USA Begin forwarded message: From: "Amengual, Randolph" Date: March 9, 2018 at 10:20:32 AM EST To: "Howie W. Muchnick" Cc: "Danow, Matthew" Subject: Re: The hotel agreed to an immediate $50k loan. If that's acceptable we =an prepare the loan docs today. > On Mar 9, 2018, at 1

urc e=g> >= <mailto Begin forwarded message: From: "Amengual, Randolph" < Date: March 9, 2018 at 10:20:32 AM EST To: "Howie W. Muchnick" Cc: "Danow, Matthew" Subject: Re: <mailto > > >>> The hotel agreed to an immediate $50k loan. If that's acceptab=e we can prepare the loan docs today. > O