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IYEST_PAW BEACH OFFICE; AI TS AT LAW. ROSALYN NA RAKER' DAMES F. GREGORY BARLITART T. HARDEE OAS& • LAND( J DROOS arum n nEriet BRENDA S. FULMER WARLASID GARCIA AMES W.GUSTAFSOILJR. :APT P HLL DAVID X.KELLEY, JR. CAMERCTI IA KENNEDY vnatAm a KM' DARRYL L. LEWIS' A. NORTON earEsc.‘ cutsuie Ecranov RICCI 'KRIS SCARP. A •CHRLSTIAN D. SEARCY 'JOHN A. SHIN.EY CHRISTOPHER K. SPEED BRIAN P SUIL NAN: Ne KAREN E. TEARY DONALD J. WAHD *C. CALVIN WARFUNEA OF CCUTISRL 'EARL I. DERMIDE.IR.T SHAREHOLDERS •UOAPO CERTIFIER ALSO ALLOTTED I KEPOUPCI 2 &LAIN( 'MARYLAND • iuSSAC•nnt-rrs i laSNSSIPIN hRIN HATNTSHIRE 'NEW JERSEY TYJUDDIA WASNINCITCH DC R‘RALEOALS NYIW AYAN.TEADA RANG? M. INDRISSE °AVOW OILMOCIE AM C HOPIEt•S DEBORAH U. KNAPP VINCENT L LEONARD-0 JAMES PETER LOVE ROBERT W. PITCHER MARK P PORGY KATHLEEN Sakti STEVE M. WITH BOWE S STARK wALTER A STEW SEARCY DENNEY SCAROLA BARNHART er--5 (REY. IL and US. MA k ll s ,mi August 29, 2012 Tonja Haddad Coleman, Esquirs. Law Offices of Tonja Iiaddad, Re: EDWARDS ADV. EPSTEIN Our File No.: 291874 Dear Ms. Coleman: K TAU.AHASSEE OFFICE. 1 E Pursuant to the authorization and direction of Bradley Edwards, I am writing to convey a demand to settle all claims against Jeffrey Epstein and his agents, (including all attorneys and law firms that have participated in Mr. Epstein's tortuous conduct), in exchange for payment of the sum of Five Million Dollars. This offer is open only until such time as the scheduled hearing on our pending motion for leave to amend to assert a claim for punitive damages at which time—unless withdrawn sooner—this offer shall be automatically withdrawn. Upon the granting of our motion, the settlement demand shall be increased to Ten Million Dollars for a period of thirty days from the date of entry of the order granting the motion—unless withdrawn sooner. Thereafter, and at each 30 day interval which follows, the settlement demand shall increase by an additional $250,000 up until the commencement of the trial calendar on which the case is initially set for trial. These increased demands are also subject to earlier withdrawal. All of these settlement demands are non-negotiable, and I have been instructed to ignore all communications regarding settlement other than a written acceptance. While I have copied your current co-counsel, Mr. Goldberger, on this demand, I leave it to you to decide who among your numerous predecessors should be informed of this demand based on their participation in the baseless prosecution of claims against Mr. Edwards. Your access to privileged communications places you and your client in a better position than we are in at this time to determine the appropriateness of asiii3s,ert`as EFTA01105951 Tonja Haddad-Coleman, Esq. Edwards adv. Epstein August 29, 2012 Page 2 informing others of this opportunity to participate in resolving any potential liability they may have. Since you personally appear to be under the mistaken impression that the voluntary dismissal without prejudice of the last remnant of your client's extortion attempts might somehow shield you and your client from liability for malicious prosecution, I suggest you review the following: Cohen v. Corwin 980 So.2d 1153 (Fla. 4 DCA 2008); Union Oil of Cat Amsco Div. v. Watson, 468 So.2d 349 (Fla. 3 DCA Johnson Law Group v. Elimadebt USA. LLC, 2010 WL 2035284, *6 May 24, 2010) Sfeir v. Equitable Life Assur. Soc. of U.S. 595 So.2d 971 (Fla. 2 DCA 1992). Si lc K SCAROLA mep cc: Jack A. Goldberger, Esquire Bradley J. Edwards, Esquire EFTA01105952