UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/MATTHEWMAN JANE DOE 1 and JANE DOE 2, Petitioners, vs. UNITED STATES OF AMERICA, Respondent. SETTLEMENT AGREEMENT WHEREAS, Jane Doe 1 and Jane Doe 2 ("Petitioners") and the United States of America ("Respondent") (jointly referred to as "the parties") have agreed that a fair, efficient, and cost effective resolution of this dispute would avoid the unnecessary expenditure of substantial resources to litigate the dispute and hereby stipulate to the adequacy of consideration exchanged; and WHEREAS, the parties have negotiated in good faith and agreed that the best interests of all parties will be served by a settlement of this proceeding; NOW, THEREFORE, in consideration of the mutual promises and recitals herein, the parties intending to be legally bound, agree as follows: 1. The parties have agreed to settle the above-captioned lawsuit upon the following terms and conditions. For purposes of this Agreement, the parties agree that the terms "Victim" and "Victims" refer to the persons whom the U.S. Attorney's Office for the Southern District of Florida ("the USAO-SDFL") has previously disclosed as persons whom it was prepared to name as victims in an indictment of Jeffrey Epstein ("Epstein"). That list of all Victims is attached EFTA00211475