EFTA00609438

10-20-09-B 
RDC 
SETTLEMENT AGREEMENT AND GENERAL RELEASE 
, individually, on the one hand, and Jeffrey Epstein, on the other 
hand, (jointly referred to as "Parties") enter into this Settlement Agreement and General 
Release ("Settlement Agreement") in order to resolve the pending litigation (the "Litigation") 
between them as follows: 
1. 
Case No. 09-CV-80656— Marra/Johnson. The Parties agree to immediately 
dismiss the pending lawsuit presently styled Jane Doe No. 102 vs. Jeffrey Epstein, Case 
No. 09-CV-80656 — Marra/Johnson (Southern District of Florida), with prejudice upon 
payment and clearance of the settlement amount, however, the Court will be requested to 
retain jurisdiction to enforce the terms of the Settlement Agreement. 
2. 
General Release. 
and each of her agents, attorneys, 
predecessors, successors, heirs, administrators and assigns (hereinafter "First Parties"), 
for and in consideration of the sum of Five Hundred Thousand Dollars ($500,000.00) or 
other valuable considerations, received from or on behalf of Jeffrey Epstein, and each of 
his agents, attorneys, predecessors, successors, heirs, administrators and assigns 
(hereinafter "Second Parties"), the receipt whereof is hereby acknowledged, 
(wherever used herein the terms "First Parties" and "Second Parties" shall 
include singular and plural, agents, employees, heirs and legal representatives. 
Second Parties also include any other person who could have been included as a 
potential defendant in First Parties' claim.) 
HEREBY remise, release, acquit, satisfy, and forever discharge the said Second Parties 
of and from all, and all manner of action and actions (State or Federal), cause and causes of 
action (common law or statutory), suits, debts, dues, sums of money, accounts, reckonings, 
bonds, bills, specialties, covenants, contracts, controversies, agreements, promises, variances, 
EFTA00609438

trespasses, damages, judgments, executions, claims and demands whatsoever in law or in 
equity for compensatory or punitive damages which said First Parties ever had, now has, or 
which any personal representative, successor, heir or assign of said First Parties, hereafter can, 
shall or may have, against said Second Parties, 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 attorneys' fees and costs is specifically addressed in paragraph 8. 
It is further agreed that this settlement represents a final resolution of a disputed claim 
and is intended to avoid litigation. This settlement 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 are not intended to be used by any 
other person nor 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 is pursuant, 
exclusively, to 18 USC §2255 and that the First Parties agree to waive and relinquish all other 
federal, state, or common law claims of 
against Second Parties. 
First and Second Parties further stipulate and agree that this settlement is in fulfillment 
of Jeffrey Epstein's obligations to 
exclusive of attorneys' fees and costs, 
pursuant to the Non-Prosecution Agreement, Its Addendum, and its Affirmation, collectively, 
between Jeffrey Epstein and the United States Attorney for the Southern District of Florida. 
First and Second Parties further stipulate and agree that this settlement should not in 
anyway be construed as an admission by Jeffrey Epstein that he violated any federal statute 
that constitutes a predicate for a damage claim under 18 USC §2255 or an admission that he 
violated any other federal or state statute or that Second Parties waive any legal right to fully 
defend other cases where damages exceeding the statutory minimum for 18 USC §2255 claims 
are sought, and where a Plaintiff waives her right to bring suit under any federal, state or 
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common law theory other than 18 USC §2255. 
3. 
Payment. Payment of the settlement funds has been made to Plaintiff's 
attorneys' trust account, but may not be released until the case is dismissed. 
4. 
Reciprocal Confidentiality. 
The Parties agree that the amount of the 
settlement shall be kept strictly confidential and shall not be disclosed at any time to any 
third party other than a specific family member(s) (whose identity must be disclosed to 
Second Parties' counsel as "Attorneys Eyes Only" and provided to Burman, Caton, Luther 
& Coleman in a sealed envelope to be opened only if a third party has alleged to have 
breached this provision) unless otherwise required by law, rule or as necessary in 
connection with medical treatment, legal, financial, accounting, or tax services, appropriate 
tax reporting purposes or Trustee who may receive funds or in response to inquiry from a 
governmental or regulatory agency. Moreover, this Settlement Agreement and its terms 
shall not be used or disclosed in any court, arbitration, or other legal proceedings, except to 
enforce the provisions of this Settlement Agreement. Any third party who is advised of the 
settlement amount must sign a document 
acknowledging they are aware of this 
confidentiality provision and are bound by it, including enforcement provisions. 
5. 
Anonymity. Second Parties will not intentionally disclose 
name to the press or the public. Second Parties will take no actions to disclose the First 
Parties' identity outside of ongoing litigation related matters. First Parties acknowledge 
Second Parties have no control over what other attorneys or other individuals may do in 
other cases regarding depositions and discovery. Second Parties may be required to 
subpoena and depose First Parties and call them at trial. Nothing shall prohibit Second 
Parties from conducting his defense, investigation and trial as his lawyers deems 
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appropriate. Robert Josefsberg and Katherine Ezell are hereby deemed to have full 
authority to accept a subpoena on First Parties behalf, so as not to violate the No Contact 
order. 
6. 
No Contact. Epstein agrees to continue to abide by Judge Marra's No 
Contact order or any modification of same by the Court. 
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 attorney 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 15th Judicial District of Palm Beach County shall have exclusive jurisdiction over the 
subject matter and shall have personal jurisdiction over the Parties (and third parties). The 
First Parties (and any third party family member) agree that Robert Josefsberg or Katherine 
Ezell are authorized to accept service for them and Robert D. Critton, Jr. is authorized to 
accept service for Jeffrey Epstein in the event of an enforcement matter. 
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 no contact provisions 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 (by the Parties or a Third Party to whom disclosure has been 
made) or no contact provisions set forth above, the Court shall determine the amount of 
any 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 
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EFTA00609441

(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 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 selected, Sidney Stubbs, Esq. 
9. 
Miscellaneous.
a. The First Parties further confirm and acknowledge that this Settlement 
Agreement is being entered into without any duress or undue influence, and 
she has had a full and complete opportunity to discuss the settlement and 
this release with her attorneys. 
b. 
agrees that it is her obligation to pay any outstanding bills 
relating to this matter from all healthcare providers and 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 considered costs paid for by 
counsel; these costs are subject to reimbursement by Second 
Parties under the terms of Paragraph 8. 
c. This Settlement Agreement was negotiated and entered into by the 
parties with the advice and assistance of 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 
paperwork and court filings to carry out the terms of this Settlement 
Agreement. 
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It is So Agreed. 
Date 
Jeffrey Epstein 
Date 
STATE OF FLORIDA 
COUNTY OF 
BEFORE ME, the undersigned authority, personally appeared 
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:  
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:  
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EFTA00609443