Filing # 21914254 Electronically Filed 12/23/2014 12:43:12 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. CASE NO. 502009CA040800XXXXMB JEFFREY EPSTEIN, JUDGE: HAFELE Plaintiff/CounterDefendant, v. 8 O 8 2 Defendant/CounterPlaintiffs. PLAINTIFF/COUNTER-DEFENDANT J MEMORANDUM OF LAW REG U • ft ED BY DEFENDANT/COUNTERPLAINTIFF ING ACCEPTANCE OF EPSTEIN'S ETTLEMENT PROPOSA Plaintiff/Counter-Defend t 6 his undersigned counsel a v. files this Memorand • Cos SCOTT ROTHSTEIN, individually and J. ,individually, (hereinafter -;, the issue pt' puns i Epstein (hereinafter "Epstein"), by and through t to this Court's request on December 6, 2014, hereby of Law regarding Defendant/Counter-Plaintiff ards' Opposition to Epstein's Motion for Attorneys' Fees and Costs on ic grounds" and states: INTRODUCTION n June 2, 2014, Epstein filed his Motion for Attorneys' Fees and Costs pursuant to §768.79 of the Florida Statutes and Rule 1.442 of the Florida Rules of Civil Procedure (hereinafter "Epstein's Motion"). On June 26. 2014, filed his Response in Opposition to Epstein's Motion for Attorneys' Fees and Costs (hereinafter Opposition"), asserting therein that Epstein's Proposal for Settlement (hereinafter the Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301• 954.467.1223 EFTA02776153