EFTA00730052

KE'S 10-30-09 
WITH RDC CHANGES 11-05-09 
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), 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 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 or entity ("Other Potential Defendants") who could have 
been included as a potential defendant 
' claim against-Jeffrey-Epstein 
ef-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, 
EFTA00730052

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 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 
Agreemenkwhieh is pursuant,-exeltisS§-22-55
; 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 Southern District of Florida. 
First and Second Parties further stipulate and agree that this Settlement 
2 
EFTA00730053

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,r ec 
that-S6GOR4-Partie
gal-right-te
defencl-ether-cases-where-darnages 
oxcooding tho statutory minimum for 18 U.S.C. § 2255 claims aro caught and where 3 
plaintiff-waives-her-right-te-bfi4g-seit-uneter-any-federalr  state-er-sentrnen-l.aw-theery 
ether-than 18-U,S,C,§-2255er-where-a-cfaimant-was-net-en-the "list" referenced-in the 
NPA-provided-i^-Jeffrey-Epstein-after-his-ple& 
3. 
Payment. Payment of the settlement funds has been made to 
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, 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 trustees 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 
3 
EFTA00730054

bound by it, including the provisions contained in this Settlement Aqreement 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 is served with a valid 
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. The-Pafties-agree-that-the-ameeh4-ef-thts-isettlement-shall-be 
kept-strictly cenficleetial-and-shall net-be-disclosed-at-any time to-any-third-party ether 
than-inweediate-family-reerrase-identityfies)-fhest-be-pfevided-a
yes-Onlyf 
te-Stetney-Stublasr  E-sc
pestal-Masterr tn-a-sealecl-ertvelepe-te-be-opertecl-enly-i4-a 
thtrcl-party-has-atlegecl-te-have-breae.hetl-this-pf-VASiG4)r  uhless-etherwise-regetretl-lay 
law-er-reler
 er-as-necessary-th-eshhectien-with-rsectical-treatmehtr
accounting,er-tax-services,
 tax roporting purpeses trustees-whe-receive 
preseeds-ef-this-feeraLer-in-respense-te-inquiry-frece-a-geweremental-er-regulatefy 
4 
EFTA00730055

agensy,Any-subb-pereens-te-whem-the-aff10614t-ef-this-settlemeat-i.s-diselesed-afa-alee 
bound-ty-tnis-provision,—MereeveMbe-terms-ef-this-Settlement-Agreement-shall net-be 
used-eediselesed-in-any-eeurtafhitratienr  ef-ether-legal-preeeedingsexeept-te-enferee 
the provisions of this Sottlomont Agroomont. Any third party who is advicod of tho 
cottlomont amount must cign a documont acknowlodging thoy aro awaro of this 
benklentialitypreviSieR-ancl-ace-beend-4-itr inbleeing-entereement-proVierio4er 
5. 
Anonymity. Second Parties shall not release 
la 
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 agreement, nothing  Nothing outcido of this 
Settlernent-Agreernenshall prohibit Second Parties from conducting Jeffrey Epstein's 
defense, investigation, and trial(s) as his lawyers deem appropriate. 
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. 
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EFTA00730056

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. 
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 
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EFTA00730057

resolve the amount of attorneys' fees and costs through the Special Master whom they 
have mutually selected, Sidney Stubbs, Esq. 
agrees 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 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 
counsel; these costs are subject to 
reimbursement by Second Parties, as previously agreed upon by the 
Parties' counsel:, and subject to a decision by the Special Master if 
there is no agreement. 
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. 
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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. 
EFTA00730059

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  
identification, and executed the foregoing instrument. 
, as 
WITNESS my hand and official seal this 
day of 
, 2009. 
STATE OF FLORIDA 
COUNTY OF PALM BEACH 
Justice of the Peace 
Print Name:  
Commission No.:  
My Commission Expires:  
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. 
9 
EFTA00730060

Notary Public 
Print Name:  
Commission No.:  
My Commission Expires:  
For Any Notice Provision: 
1. For 
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 
2. For Jeffrey Epstein 
Robert D. Critton, Jr., Esq. 
Burman, Critton, Luther & Coleman, LLP 
303 Banyan Boulevard, Suite 400 
West Palm Beach. FL 33401 
Phone: 561-842-2820 
Fax: 
561-253-0164 
or 
Jack Alan Goldberger. Esc:. 
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 
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EFTA00730061