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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,
ure predecessors, successors, assigns, partners, agents, shareholders, directors, officers, employees (including without limitation Warren Spector, Ralph R. Cioffi and Matthew M. Tannin), attorneys, affiliates, parents, subsidiaries and limited partners of each of them. "Bear Steams Securities" means shares 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- EFTA00283091 00979 (the "Arbitration"), and (b) an action that FTC commence
ccessors, assigns, limited and general partners, agents, shareholders, members, directors, officers, employees (including Michael Alix, James Cayne, Ralph R. Cioffi, Jeffrey M. Farber, Alan Greenberg, Raymond McGarrigal, Samuel Molinaro, Alan Schwartz, Warren Spector and Matthew M. Tannin), attorneys, accountan
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
ccessors, assigns, limited and general partners, agents, shareholders, members, directors, officers, employees (including Michael Alix, James Cayne, Ralph R. Cioffi, Jeffrey M. Farber, Alan Greenberg, Raymond McGarrigal, Samuel Molinaro, Alan Schwartz, Warren Spector and Matthew M. Tannin), attorneys, accountan
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
ccessors, assigns, limited and general partners, agents, shareholders, members, directors, officers, employees (including Michael Alix, James Cayne, Ralph R. Cioffi, Jeffrey M. Farber, Alan Greenberg, Raymond McGarrigal, Samuel Molinaro, Alan Schwartz, Warren Spector and Matthew M. Tannin), attorneys, accountan
Entities connected to both Financial Trust Company and Ralph R. Cioffi

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
PERSON
Spector
PERSON