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TTLEMENT AGREEMENT AND RELEASE ("Agreement") is made and entered into as of this day of JulyAuaust 2011 (the "Effective Date"), by and between (i) Financial Trust Company, Inc. ("FTC"), The C.O.U.Q. Foundation, Inc. ("COUQ") and Jeffrey Epstein (together, "Claimants") and (ii) The Bear Stearns Companies Inc. (n/k/a The Bear
C commenced before the United States District Court for the District of the Virgin Islands (St. Thomas Division), that was transferred, by order of the Judicial Panel on Multidistrict Litigation, to the UntiedUnacd States District Court for the Southern District of New York (the "Court"), entitled Financial Trust Company, Inc. v. The Bear S
his SETTLEMENT AGREEMENT AND RELEASE ("Agreement") is made and entered into as of this day of August 2011 (the "Effective Date"), by and among (i) Financial Trust Company, Inc. ("FTC"), The C.O.U.Q. Foundation, Inc. ("COUQ") and Jeffrey Epstein (together, "Claimants") and (ii) The Bear Stearns Companies Inc. (n/k/a The Bear
C commenced before the United States District Court for the District of the Virgin Islands (St. Thomas Division), that was transferred, by order of the Judicial Panel on Multidistrict Litigation, to the United States District Court for the Southern District of New York (the "Court"), entitled Financial Trust Company, Inc. v. The Bear Stearn
certain of the Disputes are the subject of (a) an arbitration that FTC and COUQ commenced before FINRA Dispute Resolution, Inc. ("FINRA"), entitled Financial Trust Company, Inc., et aL v. The Bear Stearns Companies Inc., et aL, FINRA-DR Case No. 09- EFTA00283091 00979 (the "Arbitration"), and (b) an action that FTC commence
C commenced before the United States District Court for the District of the Virgin Islands (St. Thomas Division), that was transferred, by order of the Judicial Panel on Multidistrict Litigation, to the United States District Court for the Southern District of New York (the "Court"), entitled Financial Trust Company, Inc. v. The Bear Stearn
certain of the Disputes are the subject of (a) an arbitration that FTC and COUQ commenced before FINRA Dispute Resolution, Inc. ("FINRA"), entitled Financial Trust Company, Inc., et al. v. The Bear Stearns Companies Inc., et aL, FINRA-DR Case No. 09- KU 23311357i EFTA00586174 00979 (the "Arbitration"), and (b) an action th
C commenced before the United States District Court for the District of the Virgin Islands (St. Thomas Division), that was transferred, by order of the Judicial Panel on Multidistrict Litigation, to the United States District Court for the Southern District of New York (the "Court"), entitled Financial Trust Company, Inc. v. The Bear Stearn
Entities connected to both Financial Trust Company and the Judicial Panel on Multidistrict Litigation

Jeffrey Epstein
PERSONDarren Indyke
PERSON
JPMorgan Chase
ORGANIZATION
Alan Dershowitz
PERSON
United States
LOCATIONAce Greenberg
PERSON
Eric Trump
PERSONthe State of New York
LOCATION
Stephen Hawking
PERSONthe Southern District
LOCATION
the United States District Court
ORGANIZATIONJ.P. Morgan Securities LLC
ORGANIZATIONStephen D. Susman
PERSONBear, Stearns & Co. Inc.
ORGANIZATIONWEISS
ORGANIZATIONSusman Godfrey LLP
ORGANIZATION
Jimmy Cayne
PERSON
Brad S. Karp
PERSONStephen M. Sinaiko
PERSONKramer Levin Naftalis & Frankel LLP
ORGANIZATION