Text extracted via OCR from the original document. May contain errors from the scanning process.
May 5, 2009
SENT VIA FAX
Katherine W. Ezell, Esq.
Podhurst Orseck, P.A.
25 West Flagler Street, Suite 800
Miami, FL 33130
Re:
Dear Kathy:
our discussion last week, I indicated that if we proceeded to settle the III
case, I needed some basic informs' oaa
that I could discuss and confirm
that we wish to proceed with settling Ms. Ma
case. While I will not have an
opportunity to depose her, I will require that she provide in the form of an affidavit, such
information is necessary to even consider resolution. While I know Bob's position is that
he does not need to provide any information, that is not our position. I also am aware
that you will be providing the information such that both can move forward with
resolution.
I want you to understand, however, if neither the picture nor the information is
consistent with the facts which she is alleging, we will not proceed to resolve this case.
I am sending you a revised release, but the settlement is completely contingent upon
our obtaining the below information and my confirming to you that we wish to proceed to
resolve the case.
The following information ne
provided in the form of an affidavit or summary
which is then sworn to by Mst
e
1.
Name, ad
ate of birth, social security number,
2.
How Ms. Alf came to be at Mr. Epstein's
i.e. the names and
addresses of all individuals who contacted Ms.
what was said, and
the date said conta
ade;
3.
The date/dates his...came to Mr. Epstein's home;
EFTA00602818
May 5, 2009
Page 2
4.
How Ms...1 traveled to Mr. Epstein's home, i.e. friend, cab, etc., and the
names and addresses of all individuals who traveled with her to Mr. Epstein's
home;
5.
Flow long was Ms. Ile
at Mr. Epstein's home, and whom did she meet
and what was said;
6.
What allegedly occurred at Mr. Epstein's home Oust as have been described
in complaints your office bagagd), including who said what to whom;
7.
The number of times Ms.
was at the home;
8.
Other than the occasion(s) she was at Mr. Epstein's home, did
ever speak with Mr. Epstein again at any time, either by telephone or any
other means of communication, including telephone, computer, text
messaging, etc.;
9.
After she left Mr. Epstein's home on any occasion was Ms.a
ever again
contacted by anyone purportedly on behalf of Mr. Epstein? If so, who, when,
how she siintacted and what was said; and
10.
Was Ms.
paid any money, and if so, how much did she receive?
Cordially yours,
Robert D. Critton, Jr.
RDC/bmm
cc:
Jack Goldberger, Esq.
EFTA00602819
GENERAL RELEASE
EMU
and each of her agents, attorneys, predecessors, successors, heirs,
administrators and assigns (hereinafter "First Parties"), for and in consideration of the sum of
Fifty Thousand Dollars, ($50,000.00) or other valuable considerations, received from or on
behalf of Jeffrey Epstein (hereinafter "Second Parties"), the receipt whereof is hereby
acknowledged,
(wherever used herein the terms "First Parties" and "Second Parties" shall
include singular and plural, agents, employees, heirs and legal representatives.
Second Parties also include any other person who could have been included as a
potential defendant in First Parties' claim.)
HEREBY remise, release, acquit, satisfy, and forever discharge the said Second Parties
of and from all, and all manner of action and actions (State or Federal), cause and causes of
action (common law or statutory), suits, debts, dues, sums of money, accounts, reckonings,
bonds, bills, specialties, covenants, contracts, controversies, agreements, promises, variances,
trespasses, damages, judgments, executions, claims and demands whatsoever in law or in
equity for compensatory or punitive damages which said First Parties ever had, now has, or
which any personal representative, successor, heir or assign of said First Parties, hereafter can,
shall or may have, against said Second Parties, for, upon or by reason of any matter, cause or
thing whatsoever (whether known or unknown), from the beginning of the world to the day of this
release.
It is further agreed that this settlement represents a final resolution of a disputed claim
and is intended to avoid litigation. This settlement shall not be construed to be an admission of
liability or fault by any party. Additionally, as a material consideration in settling, First Parties
and Second Parties agree that the terms of this settlement are not intended to be used by any
other person nor admissible in any proceeding or case involving Jeffrey Epstein, either civil or
criminal.
EFTA00602820
First Parties and Second Parties further stipulate and agree that this settlement also
seeks to fulfill Second Parties' obligation pursuant to separate agreements between USA and
Jeffrey Epstein, although both parties agree that this settlement should not be construed to be
an admission by Second Party that he violated any federal or state statute that constitutes
predicates for damage claims under 18 USC §2255,
The First Parties further confirm and acknowledge that this release is being entered into
without any duress or undue influence, and she has had a full and complete opportunity to
discuss the settlement and this release with her attorneys.
The First Parties agree to pay any outstanding bills relating to this matter from all
healthcare providers and satisfy any liens arising out of her claim and to hold Second Parties
harmless from same, inc►uding costs and attorneys' fees.
Date
STATE OF
COUNTY OF
BEFORE ME, the undersigned authority, personally appeared
who
is personally known to me or has produced
as i enti ica on, and
executed the foregoing instrument.
WITNESS my hand and official seal this
day of
, 2009.
Notary Public
Print Name:
Commission No.:
My Commission Expires:
2
EFTA00602821
AFFIDAVIT OF
)
) SS
BEFORE ME, the undersigned authority, personally appeared
who after first being duly sworn under oath, deposes and says:
1.
My name is
This affidavit is based upon my own personal
knowledge.
2.
I am over 21 years of age and am legally competent and expressly qualified to author
this Affidavit. 1 have personal knowledge of each fact contained in this Affidavit.
3.
I was born on
, 1987.
4.
I went to Jeffrey Epstein's mansion in Palm Beach on one occasion when I was 16
years old.
5.
While I thought I was only going there to give a massage, I was sexually exploited
by Mr. Epstein.
6.
As a result of this encounter with Jeffrey Epstein, I have suffered, and will in the
future continue to suffer, physical injury, pain and suffering, emotional distress,
psychological and/or psychiatric trauma, mental anguish, humiliation, confusion,
embarrassment, loss of educati onal opportunities, loss of self-esteem, loss of dignity,
invasion of privacy and separation from my family.
I declare, under penalty of perjury, that the foregoing is true and correct to the best of my
knowledge, information and belief
)S8
The foregoing instrument was acknowledged before me this
day of May, 2009, by
Page 1 of 2
EFTA00602822
MINISI, who is personally lcnown to me or who has produced as identification and who
take an oath.
Notary Public - State of Florida
(Name of Acknowledger Typed, Printed or
Stamped)
Title or Rank
Page 2 of 2
EFTA00602823
PMERAL RFJ.V4a411;
and each of her agents, attorneys, predecessors— successors, heirs,
administrators and assigns (hereinafter "First parties"), for and inconsideration of the sum of Fifty
Thousand Dollars, (350,000.00) or other valuable considerations, received from or on behalf of
Jeffrey Epstein (hereinafter "Second Parties), the receipt whereof is hereby acknowledged,
(wherever used herein the terms "First Parties" and "Second Parties" shall include
singular and plural, agents, employees, heirs anti legal representatives. Second Parties
also include any other person who could have been included as a potential defendant
in First Parties' claim.)
HEREBY remise, release, acquit, satisfy, and forever discharge the said Second Parties of
and from any and all manner of action and actions (State or Federal), cause and causes of action
(common law or statutory), suits, debts, dues, sums of money, accounts, reckonings, bonds, bills,
specialtieS, covenants, contracts, controversies, agreements, promises, variances, trespasses,
damages, judgments, executions, claims and demands whatsoever in law or in equity for
compensatory or punitive damages which said FirsrParties ever bad, now have, or which any
personal representative, successor, heir or assign of said First Parties, hereafter can, shall or may
have, against said Second Parties, for, upon or by reason of any matter, cause or thing whatsoever
(whether known or unknown), from the beginning of the world to the day of this release.
It is further agreed that this is the settlement of a disputed claim and is intended to avoid
litigation and shall not be construed to be an admission of liability or fault by any party.
EFTA00602824
The First Parties further confirm and acknowledge that this release is being entered into
without any duress or undue influence., and she has had a full and complete opportunity to discuss
the settlement and this release with her attorneys.
Date
COUNTY OF
BEFORE ME, the undersigned authority, personally appeared
who is
personally knowntome or has produced
, as identification, and executed the
foregoing instrument
WITNESS my band and official seal this
day of
2009.
Notary Public
Print Name:
Commission No.:
My Commission Expires:
-2-
EFTA00602825