CONFIDENTIALITY AGREEMENT AGAINST UNAUTHORIZED DISCLOSURE OF SETTLEMENT I. This Confidentiality Agreement Against Unauthorized Disclosure of Settlement Amount ("Confidentiality Agreement") is entered into by and between ("RELEASOR") and JEFFREY EPSTEIN ("RELEASEE") (jointly referred to as the "PARTIES") in order to settle all claims asserted or which could be asserted against RELEASEE and to settle all claims asserted in the action entitled ("the Action"). 2. In exchange for the consideration set forth in the Settlement Agreement and General Release of All Claims (the "Settlement Agreement") executed as part of the settlement of the Action, along with other good and sufficient consideration, receipt of which is hereby acknowledged, the PARTIES, and their attomeys, agents, employees and representatives, agree that they will keep completely confidential and will not directly or indirectly disclose or reveal to any person or entity, or in any way publicize or cause to be publicized in any news or communications media, including, but not limited to newspapers, magazines, journals, radio, television, internet sites, or jury verdict or settlement reports, the terms of the settlement of the Action, the amount of the settlement, the Settlement Agreement itself, the terms of this Confidentiality Agreement, and the related settlement discussions, unless required by law or unless after filing under seal, they are determined relevant in some other legal action by a final determination of a court of competent jurisdiction. The PARTIES expressly agree to decline comment on the settlement to any person or to any member of the news media, and can only confirm that the case indeed settled and the terms are confidential. The PARTIES further agree that the terms of the aforementioned settlement may be used only in a court or agency proceeding in which the existence or validity of the Settlement Agreement or this Confidentiality Agreement is at issue, unless ot