EFTA00805155.pdf

LINK & ta ROCKENBACH, PA CIVIL TRIAL & APPELLATE LAW 1555 Palm Beach Lakes Blvd., Suite 301 West Palm Beach, Florida 33401 T 561.727.3600 F 561.727.3601 Scott J. Link November 15, 2017 Board Certified Business Litigation CONFIDENTIAL SETTLEMENT COMMUNICATION VIA E-MAIL VIA E-MAIL Jack Scarola Bradley J. Edwards Searcy, Denney, Scarola, Barnhart Edwards Pottinger LLC & Shipley, P.A. 425 N. Andrews Avenue, Suite 2 2139 Palm Beach Lakes Blvd. Fort Lauderdale, FL 33401 West Palm Beach, FL 33409 RE: Jei9`rey Epstein v. Scott Rothstein and Bradley J. Edwards 15'h Judicial Circuit Case No. 50-2009CA040800XXXXMBAG Dear Jack and Brad: Our client has watched the video of Brad's deposition and asked us to extend a final settlement offer, which will remain open until 5:00 p.m. on Friday, November 17, 2017. Having reviewed Brad's testimony and demeanor at his recent deposition, we strongly suggest that Brad reevaluate his position. Our client has authorized us to offer Brad a "walk away." That is, he suggests that the parties enter into a Mutual General Release and Brad dismiss his Counterclaim with prejudice, with each side to bear his own attorneys' fees and costs. If Brad would like to protect his reputation and keep the settlement confidential, we are willing to agree to a confidentiality agreement. This litigation has been pending a long time. In light of attorneys' fees incurred from the date of Mr. Epstein's earliest Proposal for Settlement and those which will be incurred to try this case, Brad's potential personal liability will be well in excess of $2 million. Based on the information we have gathered, we suspect a judgment of that magnitude will result in Brad having to file personal bankruptcy. If we end this now, each side will walk away and avoid that result. We look forward to receiving your response by Friday, November 17, 2017, at 5:00 p.m. Sincerely, Scott J. Link EFTA00805155