EFTA00609480

KFIS 10-31)-044 
WITH RDC CHANGES 11-03-09 
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), 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 pr entity rOther Potential Defendants, 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 
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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, 
EFTA00609480

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; 
whisp 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 andja 
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 
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EFTA00609481

an admission that he violated any other federal or state statute,rer-that-Seeencl-PaFtles 
wai
aiy4eal-tght to fully dofend other cacao where damages exceeding tho statutory 
minimum-for-184:14,64-2265-claims-are-seuglit-anallerre-a-plaintiff-waivestier.-right-te 
bring-eult-uncter-eny-federelretete-ereernmen-law-theery-eilier4hae-trita-er 
where-a-elekeent-wes-ne4-en-lbe-trist"--referensed-in-the-NPA-previded-te-de*frer Epeteia 
aftec-kris-ptea, 
3. 
Payment. Payment of the settlement funds has been made to 
attorneys' trust account, but may not be released until t.blagrstementheebeert 
executed and  the case is dismissed with prejudipt 
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 party kiesis alleged 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, trustees who 
receive proceeds of thisaay 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. If
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EFTA00609482

ved with a subnoenaor_ceceives a request for the Settement Agreement 
they 
i
itagy. 
and aivina 0000sina counsel 10 days to object if thev_ssictitoesq. 
5. 
Anonymity. Second Parties shall not release 
identity, 
name, or physical depiction, or otherwise identify 
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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 gE 
disclose in other cases regarding depositions and discovery. Second Parties may be 
required to subpoena and depose 
and call her at trial(s). gxcept 
provided in this agreement nothing  Nething-eutside-ef-this-Settleinent-Aweereent-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. 
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. 
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 
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EFTA00609483

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 Josef sberg 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 
selected, Sidney Stubbs, Esq.  
wpm §toy.ogroe by her for attorneva 
blas lar costs is solely throua Tier attorneys and the Soecial Master oroceedino 
9. 
Miscellaneous.
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EFTA00609484

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 
not Include health care evaluations, if any, which are considered costs 
paid for by 
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. counsel; these costs are subject to 
reimbursement by Second Parties, as previously agreed upon by the 
Parties' counsel:. and subiect to a decision by the Soecal Master f►there
learlsint 
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. 
EFTA00609485

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. 
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. 
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EFTA00609486

Notary Public 
Print Name:  
Commission No.:  
My Commission Expires:  
for Any Notice Provision; 
1. For 
Robert C. JosSbe a. Eso. or 
Katherine W. Ezell. Esq, 
P dh 
7. For .leflrey Epstein 
- 
Burman. Critton. Luttier & Coleman. LLP 
{ Formatted: Indent Left 0.25• 
EFTA00609487