damages that
would otherwise be awarded in a final judgment against Cassell in the Counter-Claim action in
which this Proposal is served, in case number CACE ... There is presently no valid claim for punitive damages in the Complaint or
Counter-Claim and, therefore, no portion of this Proposal is offered to settle any claim for
punitive ... presently no valid claim for attorneys' fees or costs in the Complaint or
Counter-Claim and, therefore no portion of this Proposal is offered to settle any claim for
attorneys
https://www.justice.gov/epstein/files/DataSet%209/EFTA00593693.pdf
damages that
would otherwise be awarded in a final judgment against Edwards in the Counter-Claim action in
which this Proposal is served, in case number CACE ... There is presently no valid claim for punitive damages in the Complaint or
Counter-Claim and, therefore, no portion of this Proposal is offered to settle any claim for
punitive ... presently no valid claim for attorneys' fees or costs in the Complaint or
Counter-Claim and, therefore no portion of this Proposal is offered to settle any claim for
attorneys
https://www.justice.gov/epstein/files/DataSet%209/EFTA00614158.pdf
EFTA00298481Set 9
2003-06-0117p5,747w
Arbitration on July 25, 2011, including the dismissal with
prejudice of all claims, counter-claims and third party claims in the Arbitration, which settlement
contemplated the execution of more formal
https://www.justice.gov/epstein/files/DataSet%209/EFTA00298481.pdf
EFTA01121077Set 9
2003-06-0116p5,505w
Arbitration on July 25, 2011, including the dismissal with prejudice of
all claims, counter-claims and third party claims in the Arbitration, which settlement
contemplated the execution of more formal
https://www.justice.gov/epstein/files/DataSet%209/EFTA01121077.pdf
EFTA01083305Set 9
2003-06-0120p6,163w
Arbitration on July 25, 2011, including the dismissal with
prejudice of all claims, counter-claims and third party claims in the Arbitration, which settlement
contemplated the execution of more formal
https://www.justice.gov/epstein/files/DataSet%209/EFTA01083305.pdf
EFTA01083151Set 9
2003-06-0118p6,082w
Arbitration on July 25, 2011, including the dismissal with
prejudice of all claims, counter-claims and third party claims in the Arbitration, which settlement
contemplated the execution of more formal
https://www.justice.gov/epstein/files/DataSet%209/EFTA01083151.pdf
EFTA01088604Set 9
2003-06-0120p6,141w
Arbitration on July 25, 2011, including the dismissal with
prejudice of all claims, counter-claims and third party claims in the Arbitration, which settlement
contemplated the execution of more formal
https://www.justice.gov/epstein/files/DataSet%209/EFTA01088604.pdf
EFTA00294291Set 9
2012-02-0115p4,446w
EPSTEIN nor allow
ED ARDS to prove the valid allegations outlined in his counter-claim. While that may be what
wo d work best for EPSTEIN, that is simply ... expense, extorting EDWARDS through bullying
tactics, attempting to force EDWARDS into abandoning his legitimate counter-claim needed to
vindicate himself, and to inflict as much stress and emotional pain
https://www.justice.gov/epstein/files/DataSet%209/EFTA00294291.pdf