IN THE CIRCUIT COURT OF THE 1.11.1BENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXIABAG JEFFREY EPSTEIN, Plaintifffs), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant(s). PROPOSAL FOR SETTLEMENT PURSUANT TO RULE 1.442, FLORIDA RULES OF CIVIL PROCEDURE AND 4768.79. FLORIDA STATUTES Defendant/Counter-Plaintiff, Bradley J. Edwards, by and through his undersigned counsel, states that at least ninety (90) days have passed since the commencement of this action, and there are at least forty-five (45) days remaining before the date set for trial or the first day of the docket on which this case is set for trial, whichever is earlier. THEREFORE, Defendant/Counter-Plaintiff hereby serves this proposal for settlement pursuant to Florida Rule of Civil Procedure 1.442 and F.S. 768.79. This proposal for settlement must be accepted in writing, within thirty (30) days or it shall be deemed rejected. The Proposal for Settlement is as follows: 1. PARTY MAKING PROPOSAL: Bradley J. Edwards. 2. PARTY TO WHOM THE PROPOSAL IS BEING MADE: Jeffrey Epstein. 3. CLAIMS THE PROPOSAL ATTEMPTS TO RESOLVE: All issues and claims for damages asserted by and against the Defendant, Jeffrey Epstein against and by EFTA01120051