EFTA00602818

May 5, 2009 
SENT VIA FAX 
Katherine W. Ezell, Esq. 
Podhurst Orseck, P.A. 
25 West Flagler Street, Suite 800 
Miami, FL 33130 
Re: 
Dear Kathy: 
our discussion last week, I indicated that if we proceeded to settle the III 
case, I needed some basic informs' oaa 
that I could discuss and confirm 
that we wish to proceed with settling Ms. Ma 
case. While I will not have an 
opportunity to depose her, I will require that she provide in the form of an affidavit, such 
information is necessary to even consider resolution. While I know Bob's position is that 
he does not need to provide any information, that is not our position. I also am aware 
that you will be providing the information such that both can move forward with 
resolution. 
I want you to understand, however, if neither the picture nor the information is 
consistent with the facts which she is alleging, we will not proceed to resolve this case. 
I am sending you a revised release, but the settlement is completely contingent upon 
our obtaining the below information and my confirming to you that we wish to proceed to 
resolve the case. 
The following information ne 
provided in the form of an affidavit or summary 
which is then sworn to by Mst
e
1. 
Name, ad 
ate of birth, social security number, 
2. 
How Ms. Alf came to be at Mr. Epstein's
 i.e. the names and 
addresses of all individuals who contacted Ms. 
what was said, and 
the date said conta 
ade; 
3. 
The date/dates his...came to Mr. Epstein's home; 
EFTA00602818

May 5, 2009 
Page 2 
4. 
How Ms...1 traveled to Mr. Epstein's home, i.e. friend, cab, etc., and the 
names and addresses of all individuals who traveled with her to Mr. Epstein's 
home; 
5. 
Flow long was Ms. Ile 
at Mr. Epstein's home, and whom did she meet 
and what was said; 
6. 
What allegedly occurred at Mr. Epstein's home Oust as have been described 
in complaints your office bagagd), including who said what to whom; 
7. 
The number of times Ms.
 was at the home; 
8. 
Other than the occasion(s) she was at Mr. Epstein's home, did 
ever speak with Mr. Epstein again at any time, either by telephone or any 
other means of communication, including telephone, computer, text 
messaging, etc.; 
9. 
After she left Mr. Epstein's home on any occasion was Ms.a 
ever again 
contacted by anyone purportedly on behalf of Mr. Epstein? If so, who, when, 
how she siintacted and what was said; and 
10. 
Was Ms. 
paid any money, and if so, how much did she receive? 
Cordially yours, 
Robert D. Critton, Jr. 
RDC/bmm 
cc: 
Jack Goldberger, Esq. 
EFTA00602819

GENERAL RELEASE 
EMU 
and each of her agents, attorneys, predecessors, successors, heirs, 
administrators and assigns (hereinafter "First Parties"), for and in consideration of the sum of 
Fifty Thousand Dollars, ($50,000.00) or other valuable considerations, received from or on 
behalf of Jeffrey Epstein (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, 
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. 
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 involving Jeffrey Epstein, either civil or 
criminal. 
EFTA00602820

First Parties and Second Parties further stipulate and agree that this settlement also 
seeks to fulfill Second Parties' obligation pursuant to separate agreements between USA and 
Jeffrey Epstein, although both parties agree that this settlement should not be construed to be 
an admission by Second Party that he violated any federal or state statute that constitutes 
predicates for damage claims under 18 USC §2255, 
The First Parties further confirm and acknowledge that this release 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. 
The First Parties agree to pay any outstanding bills relating to this matter from all 
healthcare providers and satisfy any liens arising out of her claim and to hold Second Parties 
harmless from same, inc►uding costs and attorneys' fees. 
Date 
STATE OF 
COUNTY OF 
BEFORE ME, the undersigned authority, personally appeared 
who 
is personally known to me or has produced  
 as i enti ica on, and 
executed the foregoing instrument. 
WITNESS my hand and official seal this 
day of 
, 2009. 
Notary Public 
Print Name: 
Commission No.:  
My Commission Expires:  
2 
EFTA00602821

AFFIDAVIT OF 
STATE OF FLORIDA 
) 
) SS 
COUNTY OF BROWARD ) 
BEFORE ME, the undersigned authority, personally appeared 
who after first being duly sworn under oath, deposes and says: 
1. 
My name is 
This affidavit is based upon my own personal 
knowledge. 
2. 
I am over 21 years of age and am legally competent and expressly qualified to author 
this Affidavit. 1 have personal knowledge of each fact contained in this Affidavit. 
3. 
I was born on 
, 1987. 
4. 
I went to Jeffrey Epstein's mansion in Palm Beach on one occasion when I was 16 
years old. 
5. 
While I thought I was only going there to give a massage, I was sexually exploited 
by Mr. Epstein. 
6. 
As a result of this encounter with Jeffrey Epstein, I have suffered, and will in the 
future continue to suffer, physical injury, pain and suffering, emotional distress, 
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion, 
embarrassment, loss of educati onal opportunities, loss of self-esteem, loss of dignity, 
invasion of privacy and separation from my family. 
FURTHER AFFIANT SAYETH NOT. 
I declare, under penalty of perjury, that the foregoing is true and correct to the best of my 
knowledge, information and belief 
STATE OF FLORIDA 
)S8
COUNTY OF MIAMI-DADE ) 
The foregoing instrument was acknowledged before me this 
day of May, 2009, by 
Page 1 of 2 
EFTA00602822

MINISI, who is personally lcnown to me or who has produced as identification and who 
take an oath. 
Notary Public - State of Florida 
(Name of Acknowledger Typed, Printed or 
Stamped) 
Title or Rank 
Page 2 of 2 
EFTA00602823

PMERAL RFJ.V4a411;
and each of her agents, attorneys, predecessors— successors, heirs, 
administrators and assigns (hereinafter "First parties"), for and inconsideration of the sum of Fifty 
Thousand Dollars, (350,000.00) or other valuable considerations, received from or on behalf of 
Jeffrey Epstein (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 anti 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 any 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, trespasses, 
damages, judgments, executions, claims and demands whatsoever in law or in equity for 
compensatory or punitive damages which said FirsrParties ever bad, now have, 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. 
It is further agreed that this is the settlement of a disputed claim and is intended to avoid 
litigation and shall not be construed to be an admission of liability or fault by any party. 
EFTA00602824

The First Parties further confirm and acknowledge that this release 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. 
Date 
STATE OF FLORIDA 
COUNTY OF 
BEFORE ME, the undersigned authority, personally appeared 
who is 
personally knowntome or has produced 
, as identification, and executed the 
foregoing instrument 
WITNESS my band and official seal this 
day of  
 
2009. 
Notary Public 
Print Name: 
Commission No.: 
My Commission Expires: 
-2-
EFTA00602825