EFTA00602075

SETTLEMENT AGREEMENT AND GENERAL RELEASE 
f/k/a 
), individually, and Jeffrey 
Epstein, individually (jointly referred to as "Parties"), enter into this Settlement Agreement 
and General Release ("Settlement Agreement") in order to resolve the pending litigation 
between them as follows: 
1. 
Dismissal. The Parties agree to immediately dismiss the pending lawsuit 
presently styled Jane Doe No. 102 
vs. Jeffrey Epstein, Case No. 09-80656-CIV-
Marra/Johnson (Southern District of Florida), with prejudice upon payment and clearance of 
the settlement amount; however, the Court will be asked to retain jurisdiction to enforce the 
terms of this Settlement Agreement. 
2. 
General Release. 
and her agent(s), attorney(s), 
predecessor(s), successor(s), heir(s), administrator(s), and/or assign(s) (hereinafter, "First 
Parties"), for and in consideration of the sum of Five Hundred Thousand Dollars 
($500,000.00) and other valuable consideration, received from or on behalf of Jeffrey 
Epstein and his agent(s), attomey(s), predecessor(s), successor(s), heir(s), 
administrator(s), assign(s) and/or employee(s) (hereinafter, "Second Parties"), the receipt 
whereof is hereby acknowledged, 
HEREBY remise, release, acquit, satisfy, and forever discharge the said Second 
Parties and any other person or entity who could have been included as a potential 
defendant ("Other Potential Defendants") from all, and all manner of, action and actions of 
including State or Federal, cause and causes of action (common law or 
statutory), suits, debts, dues, sums of money, accounts, reckonings, bonds, bills, 
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EFTA00602075

specialties, covenants, contracts, controversies, agreements, promises, variances, 
trespasses, damages, judgments, executions, claims, and demands whatsoever in law or in 
equity for compensatory or punitive damages that said First Parties ever had or now have, 
or that any personal representative, successor, heir, or assign of said First Parties hereafter 
can, shall, or may have, against Jeffrey Epstein, or Other Potential Defendants for, upon, or 
by reason of any matter, cause, or thing whatsoever (whether known or unknown), from the 
beginning of the world to the day of this release. The issue of amount of attorneys' fees 
and costs is specifically addressed in Paragraph 8, Attorneys' Fees and Costs. 
It is further agreed that this Settlement Agreement represents a final resolution of a 
disputed claim and is intended to avoid litigation. This Settlement Agreement shall not be 
construed to be an admission of liability or fault by any party. Additionally, as a material 
consideration in settling, First Parties and Second Parties agree that the terms of this 
Settlement Agreement are not intended to be used by any other person nor be admissible 
in any proceeding or case against or involving Jeffrey Epstein, either civil or criminal. 
First and Second Parties further stipulate and agree that this Settlement Agreement 
is pursuant to and is in fulfillment of Jeffrey Epstein's obligations to 
exclusive of attorneys' fees and costs, pursuant to and in conformity with the Non-
Prosecution Agreement, its Addendum, and Its Affirmation (collectively, the "NPA"), 
between Jeffrey Epstein and the United States Attorney for the Southem District of Florida. 
First and Second Parties further stipulate and agree that this Settlement Agreement 
should not in any way be construed as an admission by Jeffrey Epstein that he violated any 
federal statute that constitutes a predicate for a damage claim under 18 U.S.C. § 2255 or 
an admission that he violated any other federal or state statute. 
2 
EFTA00602076

3. 
Payment. Payment of the settlement funds has been made to 
M' 
attorneys' trust account, but may not be released until this agreement has been 
executed and the case is dismissed with prejudice. 
4. 
Reciprocal Confidentiality. The Parties agree that the amount of this 
settlement shall be kept strictly confidential and shall not be disclosed at any time to any 
third party, except: (a) immediate family members of the Parties (whose identities must be 
provided as "Eyes Only" to Sidney Stubbs, Esq., Special Master, or his designee, in a 
sealed envelope to be opened only if a third party is alleged to have breached this 
provision); (b) to the extent required by law or rule; (c) to the extent necessary in 
connection with medical treatment, legal, financial, accounting or tax services, or 
appropriate tax reporting purposes (only if necessary); (d) in the event that all or part of the 
proceeds of this settlement are to be placed in trust for 
to the trustee(s) of 
such trust; or (e) in response to a validly issued subpoena from a governmental or 
regulatory agency. Any third party who is advised of the settlement amount must sign a 
document acknowledging that such third party is aware of this confidentiality provision and 
is bound by it, including the provisions contained in this Settlement Agreement relating to 
the enforcement of this confidentiality provision. The Parties further agree that the Parties 
shall not provide any copy, in whole or in part, or in any form, of this Settlement Agreement 
to any third party, except to the extent required by law or rule or in response to a validly 
issued subpoena from a governmental or regulatory agency. 
Moreover, neither this 
Settlement Agreement, nor any copy hereof, nor the terms hereof shall be used or 
disclosed in any court, arbitration, or other legal proceedings, except to enforce the 
provisions of this Settlement Agreement. If any of the Parties are served with a valid 
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EFTA00602077

subpoena, court order, government agency order or subpoena, or other compulsory legal 
process, pursuant to which disclosure of this Settlement Agreement, the settlement 
amount, or other terms hereof is requested, or production of the Settlement Agreement is 
requested, the Party so served shall give counsel for the other Party notice thereof within 
five (5) days of such service and, prior to making any such disclosure, shall give counsel to 
such other Party at least ten (10) days to commence necessary proceedings to obtain a 
court order preventing, limiting, or otherwise restricting such disclosure. 
5. 
Anonymity. Second Parties shall not release 
identity, 
name, or physical depiction, or otherwise identify 
absent 
express written waiver of her right to anonymity, outside of ongoing or future litigation-
related or claim-related matters. First Parties acknowledge that Second Parties have no 
control over what other plaintiffs' attorneys, witnesses' attorneys, or witnesses may do or 
disclose in other cases regarding depositions and discovery. Second Parties may be 
required to subpoena and depose 
and call her at trial(s). Except as 
provided in this Settlement Agreement, nothing shall prohibit Second Parties from 
conducting Jeffrey Epstein's defense, investigation, and trials) as his lawyers deem 
appropriate. Robert Josefsberg and Katherine Ezell are hereby deemed to have full 
authority to accept a subpoena from Second Parties on 
behalf, so that 
Second Parties are not in violation of the terms of Paragraph 6 No Contact. 
6. 
No Contact. Jeffrey Epstein agrees to continue to abide by Judge Marra's 
July 31, 2009 No Contact Order or any modification of same by the Court, so long as First 
Parties are given notice of any such modification and an opportunity to address this matter 
before the Court. 
4 
EFTA00602078

7. 
Enforcement. This Settlement Agreement shall be governed by the laws of 
the State of Florida. In the event of litigation arising out of a dispute over the interpretation 
of this Settlement Agreement, the prevailing party shall be entitled to recover its cost of 
litigation, including attorneys' fees and other reasonable costs of litigation. Should the 
federal court not retain jurisdiction, the Parties (and any third party) agree that the courts of 
the 151h Judicial Circuit of Palm Beach County shall have exclusive jurisdiction over the 
subject matter and shall have personal jurisdiction over the Parties (and third parties). In 
the event of an enforcement matter, the First Parties (and any third party family member) 
agree that Robert Josefsberg or Katherine Ezell is authorized to accept service for them, 
and Robert D. Critton, Jr. is authorized to accept service for Jeffrey Epstein. 
First and Second Parties expressly acknowledge and agree that, if either First or 
Second Parties allege that a breach of the confidentiality provision has occurred, or if First 
Parties allege that a breach of the anonymity or no contact provision has occurred, the 
aggrieved First or Second Parties may seek an appropriate remedy with the Court. If the 
Court finds a breach of the confidentiality, anonymity, or no contact provision set forth 
above, the Court shall determine the amount of the award. Equitable remedies are not 
relinquished by virtue of this provision; nor does either Party relinquish the right to pursue 
any other legal or equitable damages to which (s)he may be entitled as a result of the other 
Party's breach, including, but not limited to, prevailing party costs, to include attorneys' 
fees. 
8. 
Attorneys' Fees and Costs. This settlement does not include any amounts 
for attorneys' fees or costs. The Parties and their attorneys have agreed to resolve the 
amount of attorneys' fees and costs through the Special Master whom they have mutually 
5 
EFTA00602079

selected, Sidney Stubbs, Esq. 
agrees that any claims by her for attorneys' 
fees or costs is solely through her attorneys and the Special Master proceeding. 
9. 
Miscellaneous.
a. The Parties further confirm and acknowledge that this Settlement 
Agreement is being entered into without any duress or undue influence, 
and that they have had a full and complete opportunity to discuss the 
terms of the Settlement Agreement with their own attorneys. 
b. 
agrees that it is her obligation to pay any outstanding 
bills relating to this matter from all healthcare providers, satisfy any 
healthcare provider obligations arising out of the injuries underlying her 
claim, and hold Second Parties harmless from same. This provision does 
not include health care evaluations, if any, which are costs that have been 
paid for by her attorneys. These costs will be subject to reimbursement by 
the Second Parties, to the extent that they are for evaluation and not 
treatment. If the Parties do not agree as to whether these costs are for 
evaluations and not treatment and/or do not agree as to the 
reasonableness of the amounts claimed, then the Special Master will 
make those determinations. 
c. This Settlement Agreement was negotiated and entered into by the 
Parties with the advice and assistance of respective counsel. 
d. This Settlement Agreement may be executed by the Parties in 
counterparts on separate signature pages. 
e. The Parties and their counsel will cooperate to execute the necessary 
6 
EFTA00602080

paperwork and court filings to carry out the terms of this Settlement 
Agreement. 
/The remainder of this page is intentionally left blank.] 
EFTA00602081

It is so agreed. 
Date 
Jeffrey Epstein 
STATE OF 
COUNTY OF  AUCTAPA,^ • 
R ME, the undersigned authority, personally appeared MI=
 f/k/a
who is personally known to me or has produced  lF a:✓a/s 
I °it MC 
 , 
as i enti cation, and executed the foregoing instrument. 
WITNESS my hand and official seal this  St a  day of 
2009. 
,., 
Justice of the Peace 
Print Name: 
Commission No.: 
My Commission Expires: 
STATE OF FLORIDA 
COUNTY OF PALM BEACH 
BEFORE ME, the undersigned authority, personally appeared Jeffrey Epstein who 
is personally known to me or has produced 
, as identification, and 
executed the foregoing instrument. 
WITNESS my hand and official seal this 
day of 
, 2009. 
Notary Public 
Print Name:  
Commission No.:  
My Commission Expires:  
8 
EFTA00602082

It is so agreed. 
Je rey Eps 
Date 
Date 
STATE OF 
COUNTY OF 
BEFORE ME, the undersigned authorityg
ersonally
,
 appeared 
who is personally known to me or has produced  
, as en ca on, 
and executed the foregoing instrument. 
WITNESS my hand and official seal this 
day of 
, 2009. 
Justice of the Peace 
Print Name:  
Commission No.:  
My Commission Expires:  
STATE OF FLORIDA 
COUNTY OF PALM BEACH 
BEFORE ME, the undersigned authority, personally appeared Jeffrey Epstein, who 
is personally known to me or has produced  
n/(7.074e , 7, as identification, and 
executed the foregoing instrument. 
WITNESS my hand and official seal this 
"
 day of  47:044'7Ael"  , 2009. 
SAM CADWEU. 
a 
inTOMMISSICH II 00.13529 
EXPIRES: Apd 19.2013 
WAS Thev*tary MIc 
"tjte-c-(745, 
nt Name: .4C .),/e4 reat'ecie/i 
Commission No.: -6 68535?-9 
8 4
141-E3  : 
Q/9/3 
EFTA00602083

For Any Notice Provision: 
1. For 
2. For Jeffrey Epstein 
Robert C. Josefsberg, Esq. or 
Katherine W. Ezell, Esq. 
Podhurst Orseck, P.A. 
25 West Flagler Street, Suite 800 
Miami, FL 33130 
Phone: 305-358-2800 
Fax: 
305-358-2832 
Robert D. Critton, Jr., Esq. 
Burman, Critton, Luttier & Coleman, LLP 
303 Banyan Boulevard, Suite 400 
West Palm Beach, FL 33401 
Phone: 561-842-2820 
Fax: 
561-253-0164 
or 
Jack Alan Goldberger, Esq. 
Atterbury Goldberger & Weiss, P.A. 
250 Australian Avenue South, Suite 1400 
West Palm Beach, FL 33401-5012 
Phone: 561-659-8300 
Fax: 
561-835-8691 
9 
EFTA00602084