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OR SETTLEMENT PURPOSES 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 (
ement") is entered into by and among (a) Jeffrey Epstein, Financial Trust Company, Inc. ("FTC") and The C.
e ("Agreement") is entered into by and among (a) Jeffrey Epstein, Financial Trust Company, Inc. ("FTC") an
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,
is ___ 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 Steams Companies Inc. (n/k/a The Bear Steams Companies LLC), Bear, Steams & Co. Inc. (n/lcia J.P. Morgan S
e C.O.U.Q. Foundation, Inc. ("COUQ") and Jeffrey Epstein (together, "Claimants") and (ii) The Bear Steams
FTC"), The C.O.U.Q. Foundation, Inc. ("COUQ") and Jeffrey Epstein (together, "Claimants") and (ii) The Bea
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
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 Stearns Companies LLC), Bear, Steams & Co. Inc. (n/k/a ■. Morgan Se
e C.O.U.Q. Foundation, Inc. ("COUQ") and Jeffrey Epstein (together, "Claimants") and (ii) The Bear Stearns
FTC"), The C.O.U.Q. Foundation, Inc. ("COUQ") and Jeffrey Epstein (together, "Claimants") and (ii) The Bea
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
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 Stearns Companies LLC), Bear, Steams & Co. Inc. (n/k/a J.P. Morgan
e C.O.U.Q. Foundation, Inc. ("COUQ") and Jeffrey Epstein (together, "Claimants") and (ii) The Bear Stearns
FTC"), The C.O.U.Q. Foundation, Inc. ("COUQ") and Jeffrey Epstein (together, "Claimants") and (ii) The Bea
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
his day of August 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/lc/a The Bear Steams Companies LLC), Bear, Steams & Co. Inc. (n/k/a J.P. Morgan
e C.O.U.Q. Foundation, Inc. ("COUQ") and Jeffrey Epstein (together, "Claimants") and (ii) The Bear Stearns
FTC"), The C.O.U.Q. Foundation, Inc. ("COUQ") and Jeffrey Epstein (together, "Claimants") and (ii) The Bea
, 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 Jeffrey Epstein and Participate in Partnership Actions/Meetings
Darren Indyke
PERSON
Eric Trump
PERSON
Alan Dershowitz
PERSON
United States
LOCATION
JPMorgan Chase
ORGANIZATION
Stephen Hawking
PERSONthe Southern District
LOCATION
Financial Trust Company
ORGANIZATION
Brad S. Karp
PERSON
Bear Stearns
ORGANIZATION
the United States District Court
ORGANIZATIONthe State of New York
LOCATIONJ.P. Morgan Securities LLC
ORGANIZATIONAce Greenberg
PERSON
Jimmy Cayne
PERSONAction
ORGANIZATIONWEISS
ORGANIZATION
Spector
PERSONSusman Godfrey LLP
ORGANIZATIONBear, Stearns & Co. Inc.
ORGANIZATION