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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
by section 1542 of the California Civil Code and all other similar rules, statutes and regulations of any applicable jurisdiction. Section 1542 of the California Civil Code provides that: "A general release does not extend to claims which the creditor does not know or suspect to exist in his or her favor at the time of
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
by section 1542 of the California Civil Code and all other similar rules, statutes and regulations of any applicable jurisdiction. Section 1542 of the California Civil Code provides that: "A general release does not extend to claims which the creditor does not know or suspect to exist in his or her favor at the time of
RPOSES ONLY SETTLEMENT AGREEMENT AND RELEASE This Settlement Agreement and Release ("Agreement") is entered into by and among (a) Jeffrey Epstein, Financial Trust Company, Inc. ("FTC") and The C.O.U.Q. Foundation, Inc. ("COUQ", and together with Jeffrey Epstein and FTC, the "Claimants"), and (b) The Bear Steams Companies,
ith respect to the release provided for herein, each of the Respondents waives and relinquishes all rights and benefits afforded by section 1542 of the California Civil Code and all other similar rules, statutes, regulations or principles of law of any applicable jurisdiction. 4. Covenant Not To Sue or Participate in P
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
by section 1542 of the California Civil Code and all other similar rules, statutes and regulations of any applicable jurisdiction. Section 1542 of the California Civil Code provides that: "A general release does not extend to claims which the creditor does not know or suspect to exist in his or her favor at the time of
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
by section 1542 of the California Civil Code and all other similar rules, statutes and regulations of any applicable jurisdiction. Section 1542 of the California Civil Code provides that: "A general release does not extend to claims which the creditor does not know or suspect to exist in his or her favor at the time of
Entities connected to both Financial Trust Company and the California Civil Code

Jeffrey Epstein
PERSONDarren Indyke
PERSON
JPMorgan Chase
ORGANIZATION
U.S. Virgin Islands
LOCATION
Bear Stearns
ORGANIZATION
Alan Dershowitz
PERSON
United States
LOCATIONAce Greenberg
PERSON
Eric Trump
PERSONthe State of New York
LOCATIONthe Southern District
LOCATION
Stephen Hawking
PERSON
Houston
LOCATIONJ.P. Morgan Securities LLC
ORGANIZATION
the United States District Court
ORGANIZATIONStephen D. Susman
PERSONBear, Stearns & Co. Inc.
ORGANIZATIONWEISS
ORGANIZATIONSusman Godfrey LLP
ORGANIZATION
Jimmy Cayne
PERSON