EFTA00730062.pdf

03/10/2000 17:02 FAX 5815153148 BURMAN CRITTON LUTTIER QD003/010 SETTLEMENT AGREEMENT AND GENERAL RELEASE individually, on the one hand, and Jeffrey Epstein and 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. 502008CA006596,000048 AB. The Parties agrees to Immediately dismiss the pending lawsuit presently styled Jane Doe, by and through Jane Doe's Mother as parent and natural guardian v. Jeffrey Epstein, M, and Case No. 502008CA006598)0OO(MB AB (Fla. 15th Jud. Cir. Ct.) with prejudice upon payment and clearance of the settlement amount. Each party shall bear their own fees and costs. 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 Fifty Thousand Dollars, ($50.000.00) or other valuable considerations, received from or on behalf of Jeffrey Epstein, by (hereinafter "Second Parties"), the receipt whereof is hereby acknowledged, (wherever used herein the terms "First Parties" and "Second Parties" shall include singu) representatives. Second Parties also includes and any other person who could have been included as a efe an eintiffs 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. 1 PZE3t10' AT3t1C0095111:93 PM lEastem Drfight Timer SaRICHTFAXII. DNS:1675' CSC:56151531W DURATION immis):0148 EFTA00730062 03/10/2009 17:02 FAX 5615153148 BURMAN CRITTON LUTT:ER V)04/010 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 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. The First Parties further confirm and acknowledge that thls settlement and 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 hor 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 Party harmless from same, including costs and attorneys' fees. 3. Enforcement. This Settlement Agreement shall be governed by the laws of the State of Florida. Any dispute arising out of this Settlement Agreement shall be resolved exclusively in the courts of Palm Beach County, Florida. In the event of litigation arising out of a dispute over the Interpretation of this Settlement Agreement, the preva-ling party shall be entitled to recover its cost of litigation, Including attorney fees and other reasonable costs of litigation. 4. Payment, Payment of the settlement funds shall be made to Plaintiff and her attorneys within 10 days of the signing of this agreement by all parties. 2 PAGE MT li10;2N9 5:04:55 PM [Eastern Cayllp Tinter SVR:RIGHTF104 DI41675 ' CU:561515314S DURCICI (rms):01.35 EFTA00730063 03/10/2008 17:02 FAX 5815153148 BURMAN CRITTON IUTTIER a 005/010 5. Miscellaneous. This Settlement Agreement was negotiated and entered into by the parties with the advice and assistance of counsel. This Settlement Agreement may he executed by the parties in counterparts on separate signature pages. The parties and their counsel will cooperate to execute the necessary paperwork and court filings to cant' out the terms of this Settlement Agreement. It is So Agreed: Date STATE OF eflOCida ) COUNTY OF 4theitheciuk ) BEFORE ME, the undersigned authority, personally appeared Mantilie tt — vJ who is personally known to me or has produced persoy,Aki kmaur, as identification, and executed the foregoing instrument. WITNESS my hand and official seal this S , 2009. Notary P blic j Print Na e: 1, 1Avt Commission No.: it It My Commission Expires: 3 b 4$3q741 -2-009 PAGE51101RCY0 AT 116120095;n:56Phl [Eastern Daylight Timer SVItRIGHTTIWO' Dhi3:16/51 CSID:5815153148 DRIATION (nriss):014I EFTA00730064 03/10/2009 17* 02 FAX 5815153148 BURMAN CRIT70N LUTHER VI 008/010 STATE OF COUNTY OF ) ) 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 sea! this day of 2009. 1 STATE OF COUNTY OF 4 Notary Public Print Name: Commission No.: My Commission Expires: ) ) undersigned authority, personally appeared who or has produced , en ca io 1, and ()mg instrument. WITNESS my hand and official seal N0WYPinauc-srArs AWFLORMA D " Co # D656882 )Vimmission Want Patricia Arthuso sisri aotair' Expires. MAY 04, 2011 LAARIC EXIXD:NG co, INC Notary Public, Print Name: lilt) Commission No.: My Commission Expires: day of (lb\ G91 , 2009. 4 PAGE MO' RCM AT 31012a99 514:56 PM [Eastern Dajilght Time] SVRAIGHTFAVY DI43:1675` CH:5615153148 ' DURATION (mm•ss):01.36 EFTA00730065