IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM 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 BRADLEY J. EDWARDS. INDIVIDUALLY Plaintiff/Counter-Defendant, Jeffrey Epstein, hereby proposes to settle the above-styled case (the "Litigation") with Defendant/Counter-Plaintiff, Bradley J. Edwards, individually. I. This Proposal is made pursuant to section 768.79, Florida Statutes and Florida Rule of Civil Procedure 1.442. 2. Proposal for Settlement and Offer of Judgment ("Proposal") a. Parties: The party making this Proposal is Plaintiff/Counter-Defendant, 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: Acceptance of this Proposal resolves all damages that would otherwise be awarded in a final judgment in this action. EFTA00807727