Epstein Secrets

l for Claimants Freshfields Bruckhaus Deringer US LLP By: Marshall H. Fishman Gabrielle L. Gould Co-Counsel for The Bear Steams Companies Inc., Bear, Stearns & Co. Inc. and Bear Stearns Asset Management Inc. - 2- KL3 , . 1. 1C7-2211112.1 EFTA00316036 Wachtell, Lipton, Rosen & Katz By: David B. Anders Counsel

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

nt. IN WITNESS WHEREOF, the Parties have caused this Agreement to be executed as of the Effective Date. The Bear Stearns Companies Inc. (n/k/a The Bear, Stearns & Co. Inc. (n/k/a J.P. Morgan Bear Steams Companies LLC) Securities LLC) By: By: Name: Name: Title: Title: Bear Stearns Asset Management Inc. Financ

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

ishman Gabrielle L. Gould 520 Madison Avenue, 34th Floor New York, New York 10022 (212) 277-4000 Co-Counsel for The Bear Steams Companies Inc., Bear, Stearns & Co. Inc. and Bear Stearns Asset Management Inc. KU 23311357i - 2 - EFTA00586194 Wachtell, Lipton, Rosen & Katz By: David B. Anders 51 West 52nd Stree

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