EFTA00609469

SETTLEMENT AGREEMENT AND GENERAL RELEASE 
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), attomey(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 considerations, received from or on behalf of Jeffrey 
Epstein and his agent(s), attorney(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 who could have been included as a potential defendant in 
claim against Jeffrey Epstein of and 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, specialties, covenants, contracts, controversies, agreements, promises, 
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EFTA00609469

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, 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 Agreemenit 
-whisk-is pursuant, exclusively, to 18 U.S.C. § 2255, and 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, the "NPA"), 
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 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, or that Second Parties 
waive any legal right to fully defend other cases where damages exceeding the statutory 
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EFTA00609470

minimum for 18 U.S.C. § 2255 claims are sought and where a plaintiff waives her right to 
bring suit under any federal, state or common law theory other than 18 U.S.C. § 2255, or 044--
where a claimant was not on the "list" referenced in the NPA provided to Jeffrey Epstein 
after his plea. 
3. 
Payment. Payment of the settlement funds has been made to 
' attorneys' trust account, but may not be released until the case is dismissed. 
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 other than immediate family member(s) (whose identity(ies) must be provided as 
"Eyes Only" to Sidney Stubbs, Esq., Special Master, in a sealed envelope to be opened 
only if a third party4ieepalleged to have breached this provision), unless otherwise required 
by law or rule, or as necessary in connection with medical treatment, legal, financial, 
? 
accounting, or tax services, appropriate tax reporting purposes, trustetegho receive 
proceeds of this fund, or in response to inquiry from a governmental or regulatory agency. 
Any such persons to whom the amount of this settlement is disclosed are also bound by 
this provision. Moreover, the terms of this Settlement Agreement 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 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-
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EFTA00609471

related or claim-related matters. First Parties acknowledge that Second Parties have no 4" -sejaz-
control over what other plaintiffs' attorneys, witnesses' attome s, or witnesses may lin 
sik 
other cases regarding depositions and discovery4. Second Parties may be required to use 
re" 
subpoena and depose 
and call her at trial(s). Nothing outside of this 
Settlement Agreement shall prohibit Second Parties from conducting Jeffrey Epstein's 
defense, investigation, and trial(s) 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. 
eilk 
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. 
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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 15th 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. 
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EFTA00609472

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 
selected, Sidney Stubbs, Esq. 
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 
settlement and this release 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 
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EFTA00609473

not include health care evaluations, if any, which are considered costs 
paid for by 
counsel; these costs are subject to 
reimbursement by Second Parties, as previously agreed upon by the 
Parties' counsel. 
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. 
It is so agreed. 
Date 
Jeffrey Epstein 
Date 
STATE OF 
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. 
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EFTA00609474

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:  
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EFTA00609475