Epstein Secrets

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

ndent Releasees, including Representative Claims and any Claims that any Claimant asserted or could have asserted in the Arbitration, the Action; or the Consolidated Action, that in any way arise out of, are connected with or relate to: (a) any of the HG Funds or the ABS Funds (together, the "Funds"); (b) any BSCI Secu

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

7 Civ. 11633 (AKH) (S.D.N.Y.); Navigator Capital Partners, LP. v. Bear Stearns Asset Management Inc., et at, No. 07 Civ. 7783 (AKH) (S.D.N.Y.); and the Consolidated Action. 1.6 "Respondent Released Claims" means and includes all Claims of every nature, character and description, known and unknown, that Respondents, o

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

Civ. 11633 (AKH) (S.D.N.Y.); Navigator Capital Partners, L.P. v. Bear Stearns Asset Management Inc., et at, No. 07 Civ. 7783 (AKH) (S.D.N.Y.); and the Consolidated Action. 1.6 "Respondent Released Claims" means and includes all Claims of every nature, character and description, known and unknown, that Respondents, o

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

Civ. 11633 (AKH) (S.D.N.Y.); Navigator Capital Partners, L.P. v. Bear Stearns Asset Management Inc., et al., No. 07 Civ. 7783 (AKH) (S.D.N.Y.); and the Consolidated Action. 1.6 "Respondent Released Claims" means and includes all Claims of every nature, character and description, known and unknown, that Respondents, o