EFTA01112022.pdf

W. CHESTER BREWER, JR., M. ATIDRNEY AT LAW SUITE 1400 250 AUSTRALIAN AVENUE SOUTH El DRAFT WEST PALM BEACH. PLORIDA 33401.5006 August 17, 2015 NOT TO BE SHARED WITH ADVERSE PARTY VIA E-MAIL ONLY The Honorable Ronal . varez Matrix Mediation, LLC 1655 Palm Beach Lakes Blvd., Suite 700 West Palm Beach, FL 33401 Re: Jeffrey Epstein vs. Scott Rothstein and Bradley J. Edwards 15th Judicial Circuit Case No. 502009CA040800XXXXMB - Div AG (Hafele) MEDIATION: Tuesday - September 1, 2015 at 2:00 p.m. (at your office) Dear Ron: The above-referenced matter is scheduled for Mediation with you on Tuesday - September 1, 2015 at 2:00 p.m. The Mediation is to take place at Matrix's offices. Some time ago, Judge Hafek granted Jeffrey Epstein's Motion for Summary Judgment. A proposal for settlement in the amount of $300,000 had been made. Later, Judge Hafele ruled that Epstein was entitled to attorneys' fees based on the Proposal for Settlement. We are, thus, discussing attorneys' fees for the period of time between the effective date of the Proposal for Settlement and the Court's Order regarding entitlement. At the Mediation, we will have available attorneys' time records for the applicable period, along with a listing of all claimed taxable costs. The attorneys' fees and costs are north of $1 million. This Mediation is very different in that it is not anticipated that any complete resolution can be obtained. The issue at hand is the amount of reasonable attorneys' fees to be awarded by Judge Hafele, along with taxable costs. Judge Hafele has ordered that the parties mediate and come to an agreement on as many issues related to attorneys' fees and taxable costs as possible. I have attached a copy of the transcript of a hearing in which Judge Hafele describes (quite forcefully) what he wishes the Mediation to accomplish. It is anticipated that Mr. Scarola will wish to discuss a "global settlement" and demand that Mr. Epstein write Mr. Edwards a check for millions of dollars. The Court's ruling on the Motion for Summary Judgment is on appeal to the 4th District Court of Appeal and it is anticipated that the issue on appeal may be decided by the supreme court of Florida. Given earlier rulings by the supreme court, we are confident that the supreme court will rule in favor of Mr. Epstein. Our EFTA01112022 The Honorable Ronald V. Alvarez Mediation Summary August 17, 2015 Page 2 side does not intend to pay any money to Mr. Edwards and should Mr. Scarola persist in his demand for monies, the Mediation can be impassed quickly. If you have any questions, please do not hesitate to give me a call. Respectfully submitted, W. CHESTER BREWER, JR., ESQUIRE WCB/ch Enclosure (Transcript of 5/20/15 Hearing on disclosure of time records) EFTA01112023