DRAFT IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT, IN AND FOR DADE COUNTY, FLORIDA CIRCUIT CIVIL SECTION 34 CASE NO. 2014-21348-CA-01 JEAN-LUC BRUNEL, individually; and MC2 MODEL & TALENT MIAMI, LLC, Plaintiffs, vs. JEFFREY EPSTEIN; TYLER McDONALD; and TYLER McDONALD d/b/a YLORG, Defendants. DEFENDANT, JEFFREY EPSTEIN'S PROPOSAL FOR SETTLEMENT TO PLAINTIFF, MC2 MODEL & TALENT MIAMI, LLC Defendant, JEFFREY EPSTEIN, by and through his undersigned counsel, hereby serves this Proposal for Settlement upon Plaintiff, MC2 MODEL & TALENT MIAMI, LLC, pursuant to F.S. §768.79 and Florida Rule of Civil Procedure 1.442: 1. This Proposal is being made pursuant to F.S. §768.79 and Florida Rule of Civil Procedure 1.442. 2. This Proposal is made on behalf of Defendant, JEFFREY EPSTEIN. 3. This Proposal is being made to Plaintiff, MC2 MODEL & TALENT MIAMI, LLC. 4. This Proposal is directed to, and is intended to resolve, all claims, pled in the instant action (Case No. 14-21348 CA 01) including any and all claims for compensatory damages, interest, attorneys fees, and costs. EFTA00591494