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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
ion the Action and/or the Consolidated Action and (b) certify in writinos> counsel for Claimants that they have clone so 6. covenant Not To Sue or Participate in Partnership Actions/Meetings. Claimants, on behalf of themselves and the other Claimant Releasees, agree that they will not (a) - 8- I KU ,.1.1C7-2allalla EFTA00316022 comme
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
y in writing to counsel for Claimants that they have done so or that they received no such documents or other materials. 6. Covenant Not To Sue or Participate in Partnership Actions/Meetings. Claimants, on behalf of themselves and the other Claimant Releasees, agree that they will not (a) commence, maintain or participate in any lawsuit
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,
ornia 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 Partnership Actions/Meetings. Each of the Claimants agrees that it shall not at any time on or after the Claimant Release Date commence, maintain or participate in any lawsuit,
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
y in writing to counsel for Claimants that they have done so or that they received no such documents or other materials. 6. Covenant Not To Sue or Participate in Partnership Actions/Meetings. Claimants, on behalf of themselves and the other Claimant Releasees, agree that they will not (a) commence, maintain or participate in any lawsuit
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
, the Action and/or the Consolidated Action and (b) certify in writing to counsel for Claimants that they have done so. 6. Covenant Not To Sue or Participate in Partnership Actions/Meetings. Claimants, on behalf of themselves and the other Claimant Releasees, agree that they will not (a) commence, maintain or participate in any lawsuit
Entities connected to both Financial Trust Company and Participate in Partnership Actions/Meetings

Jeffrey Epstein
PERSONDarren Indyke
PERSON
JPMorgan Chase
ORGANIZATION
Bear Stearns
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
PERSON