EFTA00804054Set 9
2019-01-0713p3,228w
associated, excluding Rothstein Rosenteldt Adler, P.A., personal
representatives and attorneys (collectively, the "Edwards Releasees"), of and from any and
all manner of claims, demands, rights, liabilities, losses, obligations, duties, damages ... Epstein Releasors ever had, now has, or can, shall
or may have against any Edwards Releasees for, upon or by reason of any matter, cause, or
thing whatsoever ... covenant to the Epstein Releasees, and the Epstein Releasers hereby expressly covenant to
die Edwards Releasees, not to sue or initiate, prosecute, participate in or otherwise pursue
any claim
https://www.justice.gov/epstein/files/DataSet%209/EFTA00804054.pdf
EFTA00788404Set 9
2018-11-189p2,009w
each of
Edwards' successors, assigns, heirs, executors, administrators, and personal
representatives (collectively, the "Edwards Releasees"), of and from any and all
Claims, including, without limitation, any and all Claims that ... covenant to the Epstein Releasees, and the Epstein Releasors hereby
expressly covenant to the Edwards Releasees, not to sue or initiate, prosecute,
participate in or otherwise pursue any claim ... cause of action against the Epstein
Releasees or the Edwards Releasees, as the case may be, arising out of, relating to or
3
EFTA00788406
connected with any action, matter
https://www.justice.gov/epstein/files/DataSet%209/EFTA00788404.pdf
EFTA00788413Set 9
10p2,381w
each of
Edwards' successors, assigns, heirs, executors, administrators, and personal
representatives (collectively, the "Edwards Releasees"), of and from any and all
Claims, including, without limitation, any and all Claims that ... covenant to the Epstein Releasees, and the Epstein Releasors hereby
expressly covenant to the Edwards Releasees, not to sue or initiate, prosecute,
participate in or otherwise pursue any claim ... cause of action against the Epstein
Releasees or the Edwards Releasees, as the case may be, arising out of, relating to or
3
EFTA00788415
connected with any action, matter
https://www.justice.gov/epstein/files/DataSet%209/EFTA00788413.pdf
EFTA00804067Set 9
2019-01-0713p3,272w
associated, excluding Rothstein Rosenfeldt Adler, P.A., personal
representatives and attorneys (collectively, die "Edwards Releasees"), of and from any and
all manner of claims, demands, rights, liabilities, losses, obligations, duties, damages ... Epstein Releasors ever had, now has, or can, shall
or may have against any Edwards Releasees for, upon or by reason of any matter, cause, or
thing whatsoever ... otherwise pursue
any claim or cause of action against the Epstein Releasees or die Edwards Releasers, as the
case may be, arising out of, relating to or connected with
https://www.justice.gov/epstein/files/DataSet%209/EFTA00804067.pdf
EFTA01069263Set 9
15p2,751w
whatsoever, in law or in
equity, which BRADLEY J. EDWARDS, individually, ever had, now has, or may have against
Releasee or which his heirs, survivors, executors, administrators, agents, and assigns ... forever discharge BRADLEY J. EDWARDS, as well as his heirs, survivors,
executors, administrators, agents, assigns, attorneys, insurers, and reinsurers (hereinafter referred to as
"Releasee"), of and from all manner ... whatsoever, in
law or in equity, which BRADLEY J. EDWARDS, individually, ever had, now has, or may have
against Releasees or which his heirs, survivors, executors, administrators, agents, and assigns
https://www.justice.gov/epstein/files/DataSet%209/EFTA01069263.pdf
EFTA01120051Set 9
8p1,557w
RELEASE
TO ALL TO WHOM THESE PRESENTS SHALL COME OR MAY CONCERN:
BRADLEY J. EDWARDS, individually, for and in consideration of the sum of Three
Million Nine Hundred Ninety Nine ... whatsoever, in law or in
equity, which BRADLEY J. EDWARDS, individually, ever had, now has, or may have against
Releasee or which his heirs, survivors, executors, administrators, agents, and assigns ... forever discharge BRADLEY J. EDWARDS, as well as his heirs, survivors,
executors, administrators, agents, assigns, attorneys, insurers, and reinsurers (hereinafter referred to as
"Releasee"), of and from all manner
https://www.justice.gov/epstein/files/DataSet%209/EFTA01120051.pdf
EFTA00599839Set 9
8p1,561w
RELEASE
TO ALL TO WHOM THESE PRESENTS SHALL COME OR MAY CONCERN:
BRADLEY J. EDWARDS, individually, for and in consideration of the sum of Three
Million Nine Hundred Ninety Nine ... whatsoever, in law or in
equity, which BRADLEY J. EDWARDS, individually, ever had, now has, or may have against
Releasee or which his heirs, survivors, executors, administrators, agents, and assigns ... forever discharge BRADLEY J. EDWARDS, as well as his heirs, survivors,
executors, administrators, agents, assigns, attorneys, insurers, and reinsurers (hereinafter referred to as
"Releasee"), of and from all manner
https://www.justice.gov/epstein/files/DataSet%209/EFTA00599839.pdf
EFTA00613867Set 9
8p1,397w
RELEASE
TO ALL TO WHOM THESE PRESENTS SHALL COME OR MAY CONCERN:
BRADLEY J. EDWARDS, individually, for and in consideration of the sum of Three
Hundred Thousand Dollars and 00/100 ... heirs, survivors, executors, administrators, agents,
assigns, attorneys, insurers, and reinsurers (hereinafter referred to as "Releasees"), of and from all
manner of action and actions, cause and causes of action, suits ... whatsoever, in
law or in equity, which BRADLEY J. EDWARDS, individually, ever had, now has, or may have
against Releasees or which his heirs, survivors, executors, administrators, agents, and assigns
https://www.justice.gov/epstein/files/DataSet%209/EFTA00613867.pdf
EFTA00804096Set 9
8p1,416w
RELEASE
TO ALL TO WHOM THESE PRESENTS SHALL COME OR MAY CONCERN:
BRADLEY J. EDWARDS, individually, for and in consideration of the sum of Three
Hundred Thousand Dollars and 00/100 ... heirs, survivors, executors, administrators, agents,
assigns, attorneys, insurers, and reinsurers (hereinafter referred to as "Releasees"), of and from all
manner of action and actions, cause and causes of action, suits ... whatsoever, in
law or in equity, which BRADLEY J. EDWARDS, individually, ever had, now has, or may have
against Releasees or which his heirs, survivors, executors, administrators, agents, and assigns
https://www.justice.gov/epstein/files/DataSet%209/EFTA00804096.pdf
EFTA00599847Set 9
8p1,416w
RELEASE
TO ALL TO WHOM THESE PRESENTS SHALL COME OR MAY CONCERN:
BRADLEY J. EDWARDS, individually, for and in consideration of the sum of Three
Hundred Thousand Dollars and 00/100 ... heirs, survivors, executors, administrators, agents,
assigns, attorneys, insurers, and reinsurers (hereinafter referred to as "Releasees"), of and from all
manner of action and actions, cause and causes of action, suits ... whatsoever, in
law or in equity, which BRADLEY J. EDWARDS, individually, ever had, now has, or may have
against Releasees or which his heirs, survivors, executors, administrators, agents, and assigns
https://www.justice.gov/epstein/files/DataSet%209/EFTA00599847.pdf
EFTA00617978Set 9
2015-02-0326p5,268w
whatsoever, in
law or in equity, which BRADLEY J. EDWARDS, individually, ever had, now has, or may have
against Releasees or which his heirs, survivors, executors, administrators, agents, and assigns ... hereafter can, shall or may have against Releasees, including but not limited to all claims for
compensatory damages, punitive damages, penalties, interest, costs or attorney's fees, past, present ... filed in the Action
entitled JEFFREY EPSTEIN v. SCOTT R0THSTEIN, individually, and BRADLEY J. EDWARDS,
individually, Case No. 502009CA040800)OOaM13-AO, pending in the Circuit Court of the 15th
Judicial
https://www.justice.gov/epstein/files/DataSet%209/EFTA00617978.pdf
EFTA01196659Set 9
2015-02-0326p5,229w
whatsoever, in
law or in equity, which BRADLEY J. EDWARDS, individually, ever had, now has, or may have
against Releasees or which his heirs, survivors, executors, administrators, agents, and assigns ... hereafter can, shall or may have against Releasees, including but not limited to all claims for
compensatory damages, punitive damages, penalties, interest, costs or attorney's fees, past, present ... filed in the Action
entitled JEFFREY EPSTEIN v. SCOTT R0THSTEIN, individually, and BRADLEY J. EDWARDS,
individually, Case No. 502009CA040800)OOaM13-AO, pending in the Circuit Court of the 15th
Judicial
https://www.justice.gov/epstein/files/DataSet%209/EFTA01196659.pdf
EFTA01121097Set 9
2011-08-1223p6,109w
addition to the other good and sufficient consideration
provided for in this Agreement, RELEASEE wiii pay the total amount ofOTIC Hundred Thirty-Five
Thousand and 00/100 Dollars (S135 ... RELEASOR'S attorneys' trust account, Fanner, Jaffe, Weissing, Edwards, Finns
& Lehrman, PL. Trust Account, within five (5) days after receipt by RELEASEE'S attorney of an
original of each ... RELEASOR'S attorneys' mist account, Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL
That Account, within five (5) days after receipt by RELEASEE'S attorney of an original of each
https://www.justice.gov/epstein/files/DataSet%209/EFTA01121097.pdf
EFTA00622863Set 9
2011-08-1223p6,101w
addition to the other good and sufficient consideration
provided for in this Agreement, RELEASEE wiii pay the total amount ofOTIC Hundred Thirty-Five
Thousand and 00/100 Dollars (S135 ... RELEASOR'S attorneys' trust account, Fanner, Jaffe, Weissing, Edwards, Finns
& Lehrman, PL. Trust Account, within five (5) days after receipt by RELEASEE'S attorney of an
original of each ... RELEASOR'S attorneys' mist account, Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL
That Account, within five (5) days after receipt by RELEASEE'S attorney of an original of each
https://www.justice.gov/epstein/files/DataSet%209/EFTA00622863.pdf
EFTA00623054Set 9
7p1,835w
addition to the other good and sufficient consideration
provided for in this Agreement, RELEASEE will pay the total amount of One Hundred Thirty-Five
Thousand and 00/100 Dollars ... RELEASOR'S attorneys' trust account, Fanner, Jaffe, Weissing, Edwards, Fistos
& Lehrman, PL Trust Account, within five (5) days after receipt by RELEASEE'S attorney of an
original of each ... against any of the RELEASED PARTIES.
12. RELEASOR agrees to indemnify and hold harmless RELEASEE and the
RELEASED PARTIES from any and all manner of action and actions, cause
https://www.justice.gov/epstein/files/DataSet%209/EFTA00623054.pdf
EFTA00622856Set 9
7p1,967w
that, in addition to the other good and sufficient consideration
provided for this Agreement, RELEASEE will pay the total amount of Three Hundred
Thousand and 00/100 Dollars (S300 ... RELEASOR'S attorneys' trust account, Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman,
PL Trust Account, within five (5) days after receipt by RELEASEE'S counsel of an original of
this AGREEMENT ... Complaint filed in the ACTION.
12. RELEASOR agrees to indemnify and hold harmless RELEASEE from any and all
manner of action and actions, cause and causes of action, suits, debts
https://www.justice.gov/epstein/files/DataSet%209/EFTA00622856.pdf
EFTA01200310Set 9
2014-12-0616p4,324w
payment." See Plaintill7Counter-Defendant Jeffrey Epstein's Proposalfor Settlement to
Defendant/Counter-Plaintiff Bradley J. Edwards, Individually, attached to Epstein's
Motion as Exhibit A (emphasis added). The "reasons for the payment ... released, and that Releasees deny liability therefor and
intend merely to avoid litigation and to buy peace." Id. (emphasis added).
Accordingly, the "reasons for payment" that Edwards claims he would
https://www.justice.gov/epstein/files/DataSet%209/EFTA01200310.pdf
EFTA01098456Set 9
2014-12-0614p4,026w
emphasis added). Edwards's argument is without merit.
Although the Release provided that Edwards agreed "not to disclose the details of this
release in settlement of all claims, including ... that Releasees deny liability therefor and intend merely to avoid
litigation and to buy peace." See Plaintiff/Counter-Defendant Jef•ey Epstein's
Proposalfor Settlement to Defendant/Counter-Plaintiff Bradley J. Edwards, Individually,
attached
https://www.justice.gov/epstein/files/DataSet%209/EFTA01098456.pdf
EFTA00295823Set 9
2011-08-1012p3,167w
please
don't hesitate to contact my office.
Very truly yours,
FARMER, JAFFE, WEISSING, EDWARDS, FISTOS &
LEHRMAN, P.L.
Bradley J.
BJE:mwk
Enclosures
EFTA00295823
SETTLEMENT AGREEMENT AND
GENERAL RELEASE ... Release ("AGREEMENT") is entered into
by and between individually ("RELEASOR"), and JEFFREY
EPSTEIN, individually ("RELEASEE"), in order to settle all claims assert
ed or which could be
asserted by RELEASOR ... addition to the other good and sufficient
consideration
provided for in this Agreement, RELEASEE will pay the total amou
nt of Ninety Thousand and
00/100 Dollars ($90,000.00) (the "SETTLEMENT
https://www.justice.gov/epstein/files/DataSet%209/EFTA00295823.pdf
EFTA00805510Set 9
2011-08-2520p3,930w
RELEASE
TO ALL TO WHOM THESE PRESENTS SHALL COME OR MAY CONCERN:
BRADLEY J. EDWARDS, individually, for and in consideration of the sum of Three
Hundred Thousand Dollars and 00/100 ... heirs, survivors, executors, administrators, agents,
assigns, attorneys, insurers, and reinsurers (hereinafter referred to as "Releasees"), of and from all
manner of action and actions, cause and causes of action, suits ... judgments, executions, claims and demands whatsoever, in
law or in equity, which BRADLEY J. EDWARDS, individually, ever had, now has, or may have
against Releasers or which his heirs, survivors
https://www.justice.gov/epstein/files/DataSet%209/EFTA00805510.pdf