EFTA01105951.pdf

SEARCY DENNEY IYEST_PAW BEACH OFFICE; SCAROLA ❑ TAU.AHASSEE OFFICE. BARNHART 1 E er--5 (REY. k IL and s US. MAll,mi AI TS AT LAW. August 29, 2012 ROSALYN NA RAKER'DAMES F. GREGORY BARLITART T. HARDEE OAS& • Tonja Haddad Coleman, Esquirs. LAND( J DROOS arum n nEriet Law Offices of Tonja Iiaddad, 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 Re: EDWARDS ADV. EPSTEIN earEsc.‘ cutsuie Ecranov RICCI Our File No.: 291874 'KRIS SCARP. A •CHRLSTIAN D. SEARCY 'JOHN A. SHIN.EY CHRISTOPHER K. SPEED Dear Ms. Coleman: BRIAN P SUIL NAN: Ne KAREN E. TEARY DONALD J. WAHD *C. CALVIN WARFUNEA Pursuant to the authorization and direction of Bradley Edwards, I am writing to OF CCUTISRL convey a demand to settle all claims against Jeffrey Epstein and his agents, (including 'EARL I. DERMIDE.IR.T all attorneys and law firms that have participated in Mr. Epstein's tortuous conduct), in SHAREHOLDERS •UOAPO CERTIFIER exchange for payment of the sum of Five Million Dollars. This offer is open only until ALSO ALLOTTED I KEPOUPCI such time as the scheduled hearing on our pending motion for leave to amend to assert 2 &LAIN( 'MARYLAND a claim for punitive damages at which time—unless withdrawn sooner—this offer • iuSSAC•nnt-rrs i laSNSSIPIN shall be automatically withdrawn. Upon the granting of our motion, the settlement hRIN HATNTSHIRE 'NEW JERSEY demand shall be increased to Ten Million Dollars for a period of thirty days from the TYJUDDIA WASNINCITCH DC date of entry of the order granting the motion—unless withdrawn sooner. Thereafter, R‘RALEOALS and at each 30 day interval which follows, the settlement demand shall increase by an NYIW AYAN.TEADA additional $250,000 up until the commencement of the trial calendar on which the RANG? M. INDRISSE °AVOW OILMOCIE AM C HOPIEt•S case is initially set for trial. These increased demands are also subject to earlier DEBORAH U. KNAPP VINCENT L LEONARD-0 withdrawal. JAMES PETER LOVE ROBERT W. PITCHER MARK P PORGY KATHLEEN Sakti All of these settlement demands are non-negotiable, and I have been instructed to STEVE M. WITH BOWE S STARK ignore all communications regarding settlement other than a written acceptance. wALTER A STEW 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