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29a
waives his right to contest damages up to an
amount as agreed to between the identified
individual and Epstein, so long as the identified
individual elects to proceed exclusively under
18 U.S.C. § 2255, and agrees to waive any other
claim for damages, whether pursuant to state,
federal, or common law. Notwithstanding this
waiver, as to those individuals whose names
appear on the list provided by the United
States, Epstein's signature on this agreement,
his waivers and failures to contest liability and
such damages in any suit are not to be
construed as an admission of any criminal or
civil liability.
9. Epstein's signature on this agreement also is
not to be construed as an admission of civil or
criminal liability or a waiver of any jurisdic-
tional or other defense as to any person whose
name does not appear on the list provided by the
United States.
10. Except as to those individuals who elect to
proceed exclusively under 18 U.S.C. § 2255, as
set forth in paragraph (8), supra, neither
Epstein's signature on this agreement, nor its
terms, nor any resulting waivers or settlements
by Epstein are to be construed as admissions or
evidence of civil or criminal liability or a waiver
of any jurisdictional or other defense as to any
person, whether or not her name appears on the
list provided by the United States.
11. Epstein shall use his best efforts to enter his
guilty plea and be sentenced not later than
October 26, 2007. The United States has no
objection to Epstein self-reporting to begin
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