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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
ade in Bear Steams High Grade Structured Credit Strategies Enhanced Leverage Fund, L.P. by in-kind transfer from Bear Stearns High Grade Structured Credit Strategies, L.P. "ABS" refers to one or more of Bear Stearns Asset Backed Securities Partners, L.P., Bear Stearns Asset Backed Securities Overseas, Ltd. and B
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
made in Bear Steams High Grade Structured Credit Strategies Enhanced Leverage Fund, L.P. by in-kind transfer from Bear Steams High Grade Structured Credit Strategies, L.P. "ABS" refers to one or more of Bear Steams Asset Backed Securities Partners, L.P., Bear Steams Asset Backed Securities Overseas, Ltd. and Bea
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
made in Bear Steams High Grade Structured Credit Strategies Enhanced Leverage Fund, L.P. by in-kind transfer from Bear Steams High Grade Structured Credit Strategies, L.P. "ABS" refers to either or both of Bear Steams Asset Backed Securities Partners, L.P. and Bear Steams Asset Backed Securities Overseas, Ltd.
Entities connected to both Financial Trust Company and Credit Strategies

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