US Virgin Islands Leon Black settlement agreement

SETTLEMENT AGREEMENT AND RELEASE “This Settlement Agreement and Release (“Agreement”) is entered into his 20th day of January, 2023, between the Government of the United States Virgin Islands (“the USS. Virgin Islands” or “GVI’) and Leon Black (‘Black’). L RECITALS WHEREAS, according to public reports, Black paid $158 millon over approximately five years o Jeffrey Epstin's Virgin Islands company, Souther Trust, for what Black contends was for services rendered and value received. WHEREAS, Jeffrey Epstein used the money Black paid him to partially fund his operations inthe Virgin Islands. WHEREAS, this Agreement is not intended to constitu evidence or precedent of any kind except in any action or proceeding by one of the Parties 0 enforce, rescind, or otherwise implement or affirm any oral terms of this Agreement. WHEREAS, in consideration ofthe mutual covenants and terms contained herein, the Partics agreo tha this matter be resolved on the terms and conditions laid out below. IL SETTLEMEN AND CONDITIG A 1. In consideration for the agreement and for the full and complete mutual Release, inclusive of all attorneys’ fees and costs, as further specified herein, Black will pay 10 the USS. Virgin Ilands $62,500,000 in cash (the “Total Cash Payment”). 2. $15,000,000 of the Total Cash Payment shal be provided by the GVI toa trust fund to be established by the Government of the U.S. Virgin Islands to fund projects, services, counseling programs and activites, or mental healt services and facilities for Virgin Islands residents or inhabitants. Black shall make the Total Cash Payment within sixty (60) days of tis Agreement. Should Black not make full payment within sixty (60) days of this Agreemen, the US. Virgin Islands may seek to enforce tis settlement agreement in the Virgin Islands courts. 3. In consideration for the payments, benefits, and other promises and covenants set forth herein, the United States Virgin Islands voluntarily, knowingly, willingly and irrevocably releases and forever discharges Leon Black, and all of his attomeys and other agents acting within the scope oftheir authority, as wall as any private entities he owns or controls, as well as any of those entities” subsidiaries, affiliates, and parents, together with ‘each of those entities’ respective officers, directors, employees, or authorized agents (collectively, the “Releasees") from any an all claims and ights of any nature whatsoever Which the Urited States Virgin Islands now has or in the future may have aganst them related to Jeffrey Epstein, whether known or unknown, suspected or unsuspected, for any act, omission, or event occuring up to and including the dae this agreement is excauted. For avoidance of doubt, this release docs not apply to JP Morgan Case or any othe financial 1 institution used by Black or Jeffrey Epstein or any current or former employees of JP Morgan Chase or other financial institution. Nor does it ply to Jeffrey Epstein or his estate. 4. The Parties agree tht the Superior Court of the U.S. Virgin Islands shall have jurisdiction over this Agreement and the Pasties to enforce this Agreement. IL MISCELLANEOUS I. This Agreement represents the entire agrecment among the Parties relating (0 the subject matter of this Agreement, and there are no agreements, arrangements, of understandings, oral or written, among the Parties relating to the subject matter of this Agreement which are not fully expressed or referenced herein or attached hereto 2. This Agreements the result of compromise and settlement agreement among the Parties. Black is entering nto this Agreement solely for the purposes of settlement, ‘and nothing contained herein may be taken as or construed to be an admission by Black of any liability or of any violation of any law, regulation or local requirement, conlractual obligation, or any duty whatsoever whether based in statute, regulation, common law, contract, or otherwise, ll of which Black expressly deny. The terms ofthis Agreement shall not be cited by any person a evidence of wrongdoing by Black and may not be introduced except in an action by the Parties to enforce the Agreement. 3. This Agreement may only be enforced by the Parties. Nothing herein is intended to create a private right of ction by other parties. 4. All terms ofthis Agreement shall be governed by and interpreted according fo the laws of the United States Virgin Islands without regard to ts choice of aw or conflict of laws principles. 5. “This Agreement shall not limit the rights of any private party to pursue any remedies allowed by law and does not satisfy o release any claims or remedies of ny private party not otherwise identified in any other Settlement Agreement. Black wil not assert in any other action tha his monetary payments to the U.S. Virgin Islands resolve, satisfy, or release the claims of any individual 6. The Virgin Islands wil disclose documents related to this matter to non-parties only as permitted or required by the Jas of the Virgin Islands or any Court order. The Parties will provide 14-days’ notice of any request for documents. 7. This Agreement may be exccuted in counterparts and be delivered by facsimile or electronic transmission, or a copy thereof, such consiituting an original counterpart hereof, all of which together will constitu one and the same document. 8. Each Party listed below represents and warrants thatthe person signing below on its behalf is duly appointed and authorized to do so. 9. The terms of this Agreement may be modified only by a subsequent written agreement signed by the U.S. Virgin Islands and Black. 2 IN WITNESS WHEREOF, the Parties hereto, through their fully authorized representative, have cxecuted ths Agreement as of the date first written below. Government of the U.S. Virgin Islands Department of Justice > of the Attorney General J guns % l ‘ Dated: theo Zo Geta p) vic - od § Carol Thomas Jacobs, Esq. 7 Acting Atiorey General of the U.S. Virgin Islands )