SETTLEMENT AGREEMENT AND RELEASE This SETTLEMENT AGREEMENT AND RELEASE ("Agreement") is made and entered into as of this day of July 2011 (the "Effective Date"), by and between Jeffrey Epstein, with an address at 6100 Red Hook Quarter, Suite B-3, St. Thomas, USVI 00802 ("Epstein"), and Ghislaine Maxwell, with an address at 16 Island Avenue, Miami, Florida 33139 ("Maxwell"). AND IS NOT RELEASING JE. FTC, AND COUQ1 WHEREAS, vicious and damning allegations have been leveled against Maxwell in the international media in connection with widespread and frequent news coverage of a criminal and numerous civil actions brought against Epstein (the "News Coverage"); WHEREAS, Maxwell maintains that such allegations have been a source of great humiliation and embarrassment to her and her family and have caused her enormous mental anguish, emotional distress and pain and suffering for which she maintains that Epstein is directly responsible; WHEREAS, Epstein and Maxwell wish to resolve these matters without the waste of time and resources involved in prolonged litigation, and have agreed, therefore to settle their differences upon, subject to and in accordance with the provisions contained in this Agreement; NOW, THEREFORE, for and in consideration of the foregoing recitals and the mutual covenants contained herein, the adequacy and sufficiency of which are hereby acknowledged, Epstein and Maxwell (each a "Party" and together, the "Parties") hereby agree as follows: I. Definitions. For purposes of this Agreement: 1.1 "Claim" means and includes any and all legal or equitable claims (including any complaints, suits, petitions, or statements of claim in arbitration), demands, debts, obligations, allegations of wrongdoing or liability (based on any legal or equitable duties or EFTA01121066