Case: 3:10-cv-00034-CVG -RM Document#:8 Filed: 06/1 1/10 Page 1 of 5 DISTRICT COURT OF THE VIRGIN ISLANDS. DIVISION OF ST. THOMAS AND ST. JOHN x J.P. Molyneux Studio, Ltd. and Juan Pablo Molyneux FIRST ; AMENDED COMPLAINT ~against- Case No. 3:10-cv-00034 Jeffrey Epstein and L.S.J., LLC. x PLAINTIFFS, by and through the undersigned counsel, for their First Amended Complaint allege as follows: JURISDICTION AND AMOUNT IN CONTROVERSY Plaintiff Juan Pablo Molyneux is a citizen of the State of New York. - Plaintiff J.P. Molyneux Studio, Ltd. is incorporated in the State of New York and maintains its principal place of business in the State of New York. 3. Defendant Jeffrey Epstein is a citizen of the Territ Virgin Islands. - Upon information and belief, the remaining Defendant, L.S.J., LLC, is organized in the State of Delaware and maintains its principal place of business within the U.S. Virgin Islands. - This Court has original jurisdiction over this matter pursuant to 28 U.S.C. § 1332(a) because the amount in controversy exceeds $75,000, exclusive of costs, interest and disbursements and the Plaintiffs and Defendants are citizens of different states. 6. Venue is proper in this Court pursuant to 28 U.S.C. § 1391(a), (c). NS ory of the U.S. EFTA00299556

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Case: 3:10-cv-00034-CVG -RM Document #:8 Filed: 06/11/10 Page 2 of 5 FACTS COMMON TO ALL COUNTS 7. Juan-Pablo Molyneux is a world-renowned interior designer. 8. Jeffrey Epstein, via his company L.S.J., LLC, is the owner of Little Saint James, a 70-acre island within the U.S. Virgin Islands. 9. In 2005, the parties entered into an agreement whereby the Plaintiffs would provide design services for the residential compound Epstein was constructing on Little Saint James. 10.Subsequently, disputes arose between the parties with respect to the design services to be provided by Plaintifis. 11.0n May 15, 2009, the parties entered into a Settlement Agreement, annexed hereto, whereby the Defendants released all claims they might have had against the Plaintiffs in exchange for $1.2 million. 12.Following the Settlement Agreement, the parties entered into a written contract on May 15, 2009, entitled Agreement for Design Services (“Design Services Agreement”), annexed hereto, wherein the parties agreed that the Plaintiffs would perform certain design services related to the office pavilion being constructed by Defendants on Little Saint James, for which Plaintiffs would credit Defendants’ account with Plaintiffs in the amount of $250,000 to be applied toward such services. The specific services to be provided were itemized on Exhibit B to the Design Services Agreement (the “Exhibit B Services”). 13.The Settlement Agreement specifically provides that the Design Services Agreement “shall not be treated as an inducement to the execution of the Settlement Agreement.” Settlement Agreement at q 2. 14.Subsequent to the execution of the Design Services Agreement, Plaintiffs, with the assistance of an internationally-known woodworking craftsman, undertook to and did perform the Exhibit B Services, thereby satisfying their obligations pursuant to the Design Services Agreement. EFTA00299557

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Case: 3:10-cv-00034-CVG -RM- Document #:8 Filed: 06/11/10 Page 3 of 5 _15.On January 26 and 27, 2010, Plaintiffs travelled to Little Saint James to supervise the final stages of the work pursuant to the Design Services Agreement. It was agreed that Epstein would be present in order to give his approval of the work. Epstein, however, failed to attend this agreed meeting. ; 16.0n March 10, 2010, Defendants’ agent created a Punch List cataloguing certain tasks remaining to be completed pursuant to the Design Services Agreement. 17.On March 22, 2010, Plaintiffs again travelled to Little Saint James to. meet with Epstein in an effort to finalize the work performed by Plaintiffs pursuant to the Design Services Agreement. Epstein again failed to attend the agreed meeting. In an effort to perform their obligations under the Design Services Agreement, Plaintiffs and their representatives, nevertheless, undertook to complete, and did complete, the Punch List items falling under the Design Services Agreement. . 18.On March 25, 2010, Defendants’ agent signed off on all items © enumerated on the Punch List by signing it and noting that all the woodwork on the list was done with the exception of three minor items, none of which was specified in Exhibit B to the Design Services Agreement. 19.Although their agent had signed off on the Punch List, Defendants’ counsel sent a letter to Plaintiffs on April 15, 2010, claiming that Plaintiffs had failed to perform their obligations pursuant to the Design Services Agreement. . . 20.In the letter, Defendants’ counsel also claimed that the Plaintiffs fraudulently induced Defendants to enter both the Settlement Agreement and the Design Services Agreement. 21.In an effort to resolve the dispute, Plaintiffs’ representatives once again traveled to Little Saint James on April 29, 2010 to meet with Defendants’ representatives. The meeting was unproductive and Defendants’ counsel continued wrongfully to insist that Plaintiffs had’ not satisfied their obligations with respect to the Design Services Agreement. EFTA00299558

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Case: 3:10-cv-00034-CVG -RM Document #: 8: Filed: 06/11/10 Page 4 of 5 FIRST CLAIM | DECLARATORY JUDGMENT 22. Plaintiffs repeat and reallege the allegations contained in paragraphs one through 21 above. 23. There are justiciable controversies with respect to the following issues: Whether the Plaintiffs substantially performed their duties as % required by the Design Services Agreement; Whether Defendants violated their duty of good faith and fair dealing under the Design Services Agreement by engaging in conduct that was inconsistent with the terms and purpose of that agreement and the reasonable expectations of the parties by, among other things: (a) wrongfully rejecting ‘the Plaintiffs’ work with respect to the Exhibit B Services; and, (b) absenting themselves from the meetings between the parties which were held to resolve their differences, thereby interfering with and failing to cooperate with Plaintiffs in the performance of their obligations; and : Whether, as alleged in Defendants’ April 15, 2010 letter, c. Plaintiffs fraudulently induced Defendants to enter the Settlenient Agreement and the Design Services Agreement. 24.A declaration of the rights among the parties is warranted pursuant to 28 U.S.C. § 2201. WHEREFORE, Plaintiffs demand judgment against the Defendants as follows: a. Adjudging and declaring that Plaintiffs substantially performed their duties as required by the Design Services Agreement; EFTA00299559

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Case: 3:10-cv-00034-CVG -RM Document #:8 Filed: 06/11/10 Page 5 of 5 Adjudging and declaring that the Defendants violated their duty of good faith and fair cay under the Design Services Agreement; and c. ~ Adjudging and declaring that Plaintiffs did not fraudulently induce Defendants to enter the Settlement Agreement or the Design Services Agreement, and that the Settlement Agreement and Design Services Agreement are valid and enforceable; and d. | Awarding such other and further relief as the Court deems equitable and just. Respectfully Submitted, © Rosh D. Alger Esquire, LLC Attomeys for Plaintiffs DATED: June 11, 2010 © St. Thomas, U.S. Virgin Islands By: s/ Rosh D. Alger Rosh D. Alger, Esq. VI Bar No. 932 . PMB 10 Royal Dane Mall #12 St. Thomas, VI 00802 —_ Fax EFTA00299560

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_ Case: 3:10-2v-00034-CVG-RM Document #: 8-1 Filed: 06/14/10 Page tof 1 SUSKE ev 11Oq CIVIL COVER SHEET BS es ame etn at etre L(@) PLAINTIFFS DEFENDANTS Jeffrey Epstein and L.SJ., LLC (~)-P. Molyneux Stodio, Lad, and:Yoen Pablo Molyneux (b) Coanty of Residence of Fics Listed Plaintitr New York, NY County of Residence of Ficst Listed Defendant St Thomas, VI (XCET IN US PLAINTIFE CASES) (04 US. PLAINTIFF CASES ONLY) NOTE BN LAND CONDEMNATION CASES, USE THE LOCATION OF THE LAND Invotveb. © ‘Atoeney’s Fim Morne Adres, wad Telephone Member) IL BASIS OF JURISDICTION (Place £4 °X" ix One Bex Orly} OF PRINCIPAL PARTIES( Pisce an bcuz Box he Pua Cases Only) ad One Bex for Defeedoct) oF OS 0) rare Mocs Perey) Ot Ot tcwpormed Principat a. a Govwmwnendt, . or eal Pace 4 of Busioces ia This Suse = _ O2 US Coreen © 4 Diversity Giiten of Another Stace B22 bncecpocnted ane Principal Pace @s os . Soeies (lndicote Cainerahip of Parties te hem ft) of Decimess be Another Scam 7 O3° 0 3 Fercentetion RAL TAX SUF ws. UT} mil V. ORIGIN Oece an inieregea 5! orieteat 92 pemondton 3 pResanded trom IF ANY JUDGE it eS SF TRY PR 06/11/2010 s/Rosh D. Alger : ° SmCErT« AMOUNT APPLYING IFP DCE EFTA00299561

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JP, “Molyneux,”) S.J, LLC (“LS)*) ” connection with design and-related se . James Island and other Epstein (the “Disputes”); and Case: 3:10-cv-00034-CVG-RM Document #: 8-2 Filed: 06/11/10 Page fof6 THIS AGREEMENT, red into this 1Sth day of May, 2009, by and among Juan Pablo Molyneux (7JP*), Molyneux Studio, Ltd. (‘Studio", and together with and Jeffrey Epstein (Epstein*). WHEREAS, disputes have arisen between Molyneux, on the one hand, and relating to payments and deliverables in LSJ and Epstein, on the other hand, tvices by Molyneux for LSJ and/or: Epstein properties beneficially owned by WHEREAS, the parties hereto desire to settle all Disputes as provided in this Agreement; regoing premises and the NOW, THEREFORE, in consideration of the fo provisions contained rautual agreements, promises and other and Epstein (the “Parties*), intending to be bound, hereby agree as follows: 1. ‘The Parties agree to settle the Disputes, upon, subject to and in accordance with the provisions of this Agreement. 2. —_On or before May 15, 2009, Molyneux shall pay Epstein One Million Two Hundred Thousand Dollars ($1,200,000) by wire transfer of that amount te ari account designated in writing by Epstein to Molyneux not later than May 15, 2009, With the payment of this amount, all claims Shall be released and extinguished, except for claims to enforce the provisions of this Agreement or the Design Services Agreement of even date herewith. Said Design Services Agreement provides its own remedies for any breach thereof, shall not affect- the release provisions of this Settlement Agreement, and shall not be treated as an inducement to the execution of the Settlement Agreement 3. (a) Epstein and LSJ and executors and administrators (collectively, the “Epstein Releasors”) hereby fully and irrevocably-release each of JP and Studio, and each of their successors, assigns, principals, - heirs, executors, and administrators (collectively, the “Molyneux nd all manner of claims, demands, Tights, Ilabilities, enalties, sanctions, * Releasees"), of and from any ai damages, debts, expenses, interest, p aye! causes on, suits, losses, obligations, duties, fees, attorneys’ fees, costs, actions, potential actions, controversies of any kind, agreements, judgments, decrees, matters, Issues and nature or description “whatsoever, whether known or unknown; disclosed or unforeseen, matured or not ma fixed or contingent, Whether direct, representative, legal, equitable, or of any type, or fn any other capacity; whether ed on state, local, foreign, federal, statutory, regulatory, common, or other law, * upon or by reason of any matter, cause, or thing whatsoever in any way relating t of, or based upon, directly or indfrectly, any for, to, involving, referring to, arising ou 1 hereln, JP, Studio, Ls] each of their successors, assigns, heirs, b thks EFTA00299562

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— C) ms with respect to those disputes, Case: 3:10-cv-00034-CVG-RM Document #: 8-2 Filed: 06/11/10 Page 2o0f 6 actions, transactions, occurrences, statements, representations, misrepresentations, omissions, allegations, facts, practices, events, claims or any other matters or things whatsoever, or any series thereof existing .or occurring on or prior to the date hereof relating in any way to the Disputes, Anything to the contrary in this Section 3(a) notwithstanding, nothing herein shall release the Molyneux Releasees from any der this Agreeinent or the Design of their respective joint or several obligations un Services Agreement. (b) . JP and Studio and each of their successors, assigns, heirs, administrators (collectively, the “Molyneux Releasors’) hereby fully and irrévocably rel . n and LS}, and each of their successors, assigns, principals, heirs, executors, and administrators (collectively, the “Epstein manner of claims, demands, rights, liabilities, “), of and from any and all debts, expenses, interest, penalties, Sanctions, On, suits, . Rekasees’ losses, obligations, duties, damages, fees, attorneys’ fees, costs, actions, potential actions,, causes of acti agreements, judgments, decrees, matters, issues and controversies of ever, Whether known or unknown, disclosed or nature or description whatso undisclosed, accrued or unaccrued, apparent or not apparent, foi not matured, suspected or unsuspected, I{quidated or not contingent, whether direct, derivative, individual}, liquidated, fixed or representative, legal, equitable, or of any type, or in any other capacity, whether based on state, local, forelgn, federal, statutory, regulatory, common, or other law, thing whatsoever in any Way relating for, apon or by reason of any matter, cause, or y to, involving, referring to, arising out of, or based upon, directly or indirectly, any actions, transactions, Occurrences, statements, representations, misrepresentations, omissions, allegations, facts, practices, events, claims or any other matters or things oever, or any series thereof, existing or occurring on or prior to the date ing in any way to the Disputes. Anything to the contrary in this Section 3(b) notwithstanding, nothing herein shall release the Epstein Releasees from any of their respective Joint or several obligations under this Agreement or the Design Services Agreement. 4, By entering into this’ Agreement, the Parties do not intend to make, nor shall they be deemed to have made, any admission of liability of any kind whatsoever, The Parties agree that they are en purpose of settling certain disputes between them and to avold further expense - S. The Parties agree: that the existence, terms, this Agreement will not be 2 tering into this Agreement for the . EFTA00299563

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Nee : nor’shall they hereafter do so, Case: 3:10-cv-00034-CVG-RM Document #: 8-2 Filed: 06/11/10 Page 3 of g purpose of performing their accountants and attomeys who require the same for the such Party; Gii) to its or his employment duties or providing professional services lo insurers or re~insurers; (iii) ag tequired by any law, regulation, or rule of a court or court agency; or (iv) in response to a duly authorized subpoena or court order. Before disclosing sny facts about the settlement under provisos (i) or (ii) above, the Party ving party of the terms of this confidentiality making the disclosure shall inform the recei isi measures to’ ensure that the receiving party agrees not provision and shall take reasonable 'o make further disclosures 6f the requested information. Af least five business days Prior fo disclosing any facts about the settlement under provisos (iii) or (iv) above (other than in conection with Proceedings to enforce the provisions of this Agreement or the the extent permissible by law, regulation, rule of a court Design Services Agreement), to Y the Party making or asked to i request for information, and shall: not be used to construe any term of : negotiated by each Party and such Party’s respective attorneys, and the language hereof will not be construed for or against any such Party as the principal drafter of this Agreement. 7, The individuals signing this Agreement and the Parties on whose behalf such individuals are signing heteby represent and warrant that they are ‘ ¢mpowered and authorized to sign on behalf of and bind the Parties for whom they ~ * The Parties represent and warrant that, as-of the Effective Date of this Agreement, they have not assigned, conveyed, or otherwise transferred the rights to demands, causes of action, rights, or obligations related in any way to other person or entity, any claims, the claims to be released in paragraphs 3(a) and 3 (b) to any 9. Each Party agrees that this Agreement shall be binding upon the heirs, successors, and assigns of each Party, agrees that such Party: (i) has fully 10, Each Party represents and t and has had the opportunity to seek advice by reviewed this Agreemen choosing with respect to the same; (il) fully understands the terms of this Agreement and has entered Into this Agreement voluntarily on the part of any person or entity; and (iii) was EFTA00299564

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CJ Case: 3:10-cv-00034-CVG-RM Document #: 8-2 Filed: 06/11/10 Page 4of6 given adequate time to consider all implications of this Agreement prior to entering into it. be executed in any number of counterparts, each 11. . This Agreement may of which shall be deemed an original, but all of which together shall constitute one and the same instrument. Signatures of this Agreement transthitted by fax shall have the same effect as original signatures, 12. This Agreement may not be amended or modified except by a -written representatives of all of the- Parties, Instrument executed by the duly authorized Any waiver of any provision hereof must be in writing and signed by the party to be charged with such waiver. Any such waiver shall be effective only in the Specific instance and for the specific purpose for which such waiver {s given, No failure on ariy Party to exercise, and no delay in exercising, any right, power or privilege under this Agreement shall operate as*a walver thereof; nor shall any single or partial exercise of any right, power or privilege under this Agreement, preclude any other or further exercise thereof or the exercise of any other right, Power or privilege hereunder. . ‘ 13. Any statements, communications or notices to be provided pursuant to this Agreement shall be in writing and sent by hand delivery or by reputable ‘overnight courier to the attention of the Parties indicated below, until such time as notified or change of address ts forwarded to all notice of any change of person to be Parties; . .(@) For Epstein and L3}: Darren K, Indyke, Esq. ; 301 East 66th Street, 10B New-York, New York 10065 (}} = For JP and Studio: Jay Goldberg, Esq. 250 Park Avenue Suite 2020 . 14. This Agreement shall be governed by and: construed-In accordance with the laws of the Virgin Islands applicable to agreements entered into entirely Within the Virgin Islands, without regard to the principles of Virgin Islands law regarding conflicts of laws. EFTA00299565

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f “) Case: 3:10-cv-00034-CVG-RM Document #: 8-2 Filed: 06/11/10 Page 5of6 15. Each Party irrevocably and unconditionally submits to the exdusive jurisdiction of any court sitting In the Virgin Islands over any suit, action or proceeding arising out of or relating to the Disputes. Each Party agrees that service hotice or document as provided in Section 13 hereof shall of any process, summons, be effective service of Process for any action, suit ° ; ally Walves any Objection to’ the the parties hereto have caused this Agreement to IN WITNESS WHEREOF, ir duly authorized representatives, as the case may * be executed by themselves or the year first above-written. be, as of the date of the day and J.P. MOLYNEUX STUDIO, LTD, LSJ., LLC By JEFFREY EPSTEIN. Member EFTA00299566

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=. Case: 3:10-cv-00034-CVG-RM Document #: 8-2 Filed: 06/11/40 Page 6 of 6 15, Each Party irrevocably and unconditionally submits to the exclusive jurisdiction of any court sitting in the Virgin Islands over any’ suit, action or proceeding arising out of or relating to the Disputes, Each Party agrees that service of any process, summons, notice or document as provided in Section 13 here of shall Suit or proceeding brought in any such be effective service of process for any action, j rrevocably-and-unconditionally-waives-any objection” Owrthe ~— - roceeding brought in any such court and * --cCourt--Each - - laying of venue of any such suit, action orp roceeding brought in such court has been any claim that any such sult, action or Pp brought in an inconvenient forum. Each Party agrees that a final, non-appealable judgment in any such suit, action or proceeding brought In any such court shall be conclusive and binding upon such Party and may be enforced in any othér courts to whose jurisdiction such Party is or may be subject, by suit upon judgment. IN WITNESS WHEREOF, the parties hereto have caused this Agreement to thelr duly authorized representatives, as the case may ~* be executed by themselves or d year first above-written, be, as of the date of the day an JP. MOLYNEUX STUDIO, LTD. By: : : Juan Pablo Molynenx President LSJ. LLC Member EFTA00299567

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7 06/11/10 Page 1 ofg t#:8-3 Filed: . VG-RM Documen FOR DESIG. THIS AGREEMENT FOR DESIGN SERVICES, is fered into this 15th day of May, n Pablo Molyneux (")P*), Molyneux Studio, Ltd, (Studio® ——ee Epstein (Epstainy ~ c Bs 2009, by and among Jua and together wits, IP, “Molyneux,*) LSJ, LLC ( "LSJ") and Jeffre rie. intending to be boung hereby, 7 “Tetaby fath-0F the-parties-harais (the Parties"), TS eres ener hereby agrees as follows, 1. Upon execution of this Agreement by the parties in return valuable and Sufficient consideration, Molyneux shall credit Epstein's account with * Studio fa the amount of Two Hundred Fifty Thousand Do} rs “ to be applied against future Services and out of Pocket disbursem and expenses incurred by, Studio, to and for the benefit of Epstein ined by Epstein in his reasonable discretion (the “Covered and/or LS, as determ Services"), 2. With respect to actual services rendered as part of the Covered Services ‘in and ‘against the Credit ata rate qual to Five Hundred Dollars ($500) Per hour for Services rendered by JP and Bighty Dollars (380) Per hour for Studio staff, Services Shall Include 3. Without fn any way limiting the foregoing, the Covereg those Services, disbursements and/or, reasonably determined by ropriate to complete the design, construction, and e mishings, of the office _ ‘C0 be necessary or app ‘{) | 8nd Interior design and decoration, including furniture and fy _ Pavilion currently under ttle es Island (the “Office . Pavilion”), and will further Include Provision su, and the Payment of alj expenses and disbursements in connection therewith, for the proper Installation, restaining and refinishing of the Cabinetry alréady delivered to Little St. James by Atelier Fancelli, : 4 ON, thstanding the Provisions of Section 3 hereof the Parties acknowledge '0n Of such cabinetry were Included in a Pre- existing Purchase order twe stein, attache and agree that such labor charges Shall be Paid fe by Mo; YNEUX without application Of the Credit Against the same, the.Covered Sery, Credit for the proms e Credit and that neither Epstein nor LS} shall have any such Items, ‘exceed the amount of th liability to make any Payment to Molyneux in respect of any EFTA00299568

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CD CJ Case: 3:10-cv-00034-CVG-RM Document #: 8-3 Filed: 06/11/10 Page 2ofg date that this Agre ement is 6, executed by all of the parties hereto, Studio shall Services in an amount equal to the Credit, then on the date of such fifth anniversary, the Credit by wire transfer to 7. In the event that-Molyneux should breach any term of this Agreement, Epstein shall give him written notice and ten days’ opportunity to cure before Molyneux shall be deemed to be in breach, . : . 8. In the event of breach of 2 material term of this Agreement, Inciuding, without limitation, a failure to complete the provision and’ proper-installation and *+ completion of any one or more of the items on Exhibit B by January 1, 2010-or the * the Office Pavilion to Epstein’s reasonable satisfaction by January 1, 2010 which {s not cured by Molyneux, Molyneux shall pay Epstein as . liquidated damages $250,000 within 30 days of the expiration of Molyneux’s ten day opportunity to cure. The parties hereto understand and agree that such $250,000 ~ payment fs in addition to the payment of the unapplied ‘balance of the Credit pursuant to Section 6 hereof. The parties hereto agree that in the event of such a material breach, the actual amount of damages sustained by Epstein and LS] would -be difficult to ascertain and, under the circumstances, the amount of these liquidated damages fs fair and reasonable. : - 9. JP. states that neither he nor Studio fs an architect and have not held themselves out as same Tegarding the services to be’ rendered under this. Agreement. Further, Epstein and LS] acknowledge that JP and Studio have Not held themselves out as an architect regarding the services to ‘be rendered under this 10. This Agreement constitutes the entire agreement between the Parties regarding theprovision of the Covered Services, Each Party acknowledges that such Party has not executed this Agreement in reliance on any representation, ment, or warranty that {s not contained in this inducement, promise, agree. Agreement or the Settlement Agreement, . . ry of this Agreement shal] not FER The Parties agree that the prior drafting histo be used to construe any term of this Agreement. This Agreement has been negotiated by each Party and such Party's respective attorneys, and the language 2 In the event that by the fifth anniversary of the not have provided Covered - EFTA00299569

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OO Case: 3:10-cv-00034-CVG-RM Document #: 8-3 Filed: 06/11/10 Page 3of8 hereof will not be construed 12, The individuals signing this A Tepresent and warrant that they are empowered and signed. individuals are signing hereby authorized to sign on behalf of and biid the Parties for whom they have Agreement shall be binding upon the heirs, 13, . Each Party agrees that this Successors, and assigns of each Party, Party: (1) has fully reviewed this 14, Each Party represents and agrees that such Agreement and has had the opportunity to seek advice by independent counsel of its choosing with respect to the’ same; (if) fully utiderstands the terms of this Agreement and has éntered into this Agreement voluntarily without any coercion or duress on the part of any person or entity; and (iff) was given adequate time to consider all implications of this Agreement prior to entering into it. . 16. This Agreement may not be amended or modified except by a written instrument executed by the duly authorized representatives of all of the Parties. instance and for the specific purpose the part of any Party to exercise, and no delay in exercising, any righ all operate as a waiver thereof; nor shall any this Agreement, single or partial exercise of any right, power or privilege under exercise thereof or the exercise of any other right, prechade any other or further Power or privilege hereunder. 17, Any demands, Statements, cominunications or notices to be provided pursuant to this Agreement: shall be in wrifing and sent by hand delivery or by reputable overn{ght courier to the attention of the Parties indicated below, until such time as notice of any change of person to be notified or change of address is forwarded to all Parties: sot (a) For Epstein and Ls}: Darren K. Indyke, Esq 304 East 66th Street, 10B New York, NY 10065 for or against any such Party as the principal drafter of . this Agreement. greement and the Parties on whose behalf such EFTA00299570

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92 Case: 3:10-cv-00034-CVG-RM Document #: 8-3 Filed: 06/11/10 Page 4 of g (b) =‘ For JP and Studio: Jay Goldberg, Esq. . 2S0 Park Avenue 18. This Agreement shall be governed by and construed in accordance with the laws of the Virgin Islands applicable to agreements entered into entirely Within the Virgin Islands, without regard to the principles of Virgin Islands’ law regarding conflicts of laws. 19, Each Party frrevocably and unconditionally submits to the exdusive jurisdiction of any court sitting in the Virgin Islands over any suit, action or proceeding arising out of or relating to the Disputes. Each Party agrees that service of any process, summons, notice or document as provided In Section 17 hereof shall be effective service of process for any action, suit or proceeding brought in any such court, Each Party frrevocably and unconditionally waives any objection to the laying of venue of any such sult, action or proceeding brought in any such Court and any claim that any such sult, action or proceeding brought in such court has been brought in an inconvenient forum. Each Party agrees that a final, non-appealable judgment in any such suit, action or proceeding brought in any such court shall be conclusive and binding upon such Party and may be énforced in any other courts to whose jurisdiction such Party Is of may be subject, by suft upon judgment. 2. The Parties agree that the existence, terms, and consideration paid: pursuant to this Agreement are strictly confidential atid that this Agreement will not. be filed in any court, except in proceedings to enforce this Agreement or the Settlement Agreement, No Party may revéal any facts about this Agreement or the terms of any Settlement of which this Agreement is part without the prior, written consent of each of the other Parties; provided, however, that a Party may disclose facts about the-settlement (i) fo its or his employees, accountants and attorneys who require the same for the purpose of performing their employment duties or providing professional services to such Party; (ii) to its or his insurers or re-insurers; (iii) as required by any law, regulation, or rule of a court or court agency; or (iy) in response to 2 duly authorized subpoena or court order, Before disclosing any facts about the settlement under provisos () or (ii) above, the Party making the disclosure shall inform the receiving party of the terms of this confidentiality provision and ’ shall take reasonable measures fo ensare that the receiving party agrecs not to make further disclosures of the requested information. At least five business days prior to disclosing any facts about the settlement under provisos (iii) or Gv) above (other Agreernent or than in connection with proceedings to enforce the provisions of this the Design Services Agreement), to the extent permissible by law, regulation, rale of ; Suite 2020 : . —_ ork10177_— 5 ee EFTA00299571

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Case; 3:10-cv-00034-CVG-RM Document #:8-3 Filed: 06/11/10 Page Sofa a court or court agency or court order, the Party making or asked to make the i ther Parties of the proposed disclosure or disclosure shall inform each of the o and shall, at the request of any Party and at the cost of such c » request for information, requesting Party, file any disclosure or response to the request for information about the: ¢ or the terms of this Agreement pursuant fo » motion or other formal request that the information be maintained in confidence and/or held under IN WITNESS WHEREOF, the parties hereto have caused this Agreement to be ir duly authorized representatives, as the case may executed by themselves or the: be, as of the date of the day and year first above-written. J.P. MOLYNEUX STUDIO, LTD. B P : Juan Pablo Molyneux President JUAN PABLO MOLYNEUX C) EFTA00299572

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a t ‘, ~., Case: 3:10-<v-00034-CVG-RM Document #:8-3 Filed: 06/11/10 Page Gof 8 & court or court agency or court order, the Party making or asked to make the disclosure shall inform each of the other Parties of the proposed disclosire or request for information, and shall, atthe request of any Party and at the cost of such requesting Party, file any disclosure or response to the request: for information about the settlement or the terms of this Agreement pursuant to a motion or other formal request that the information be maintained in confidence and/or held under IN WITNESS WHEREOF, the parties hereto have catised this Agreement to be ir duly authorized representatives, as the Case’ may executed by themselves or the: be, as of the date of the day and year first above-written. J.P. MOLYNEUX STUDIO, LTD. * -By: LSJ, LLC By: : JEFFREY EPSTEIN Member EFTA00299573

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. Case: 3:10-cv-00034-che-kmbidodhnent #: 8-3 * Filed: 06/1 1/1 0 PagertshQumix 7106, * MOLYNEUX ARCHITECTURAL INTERIORS & DECORATION CC) 29 FAST 691 STREET ; MM ai ral 66 at Fer comely cree Bet ates .) ‘3 . FANCELLI PANELING 10/1 4/2008 24 EAST 64TH STREET an.” - 212-935-6537 Ta emus : 212-935-6538 Fax —rr———jfF Re cs a Woodworking 780,000.00 780,000.00 . FABRICATION & INSTALLATION of light oak with waxed finish cabinetry per JPM design. Will include survey, shop drawings, moldings of base, lower cabintery with doors and upper bookshelves 3 hidden cabinet doors snd interior window shutter columns with bases and crown. Will include packing _ insurance and waterproof container to St. thomas . and crew travel. Cost will not inclade 2 globes, flat base (stone) transportation of goods to St. : . . James, scaffolding, local taxes, customes or C) n 4S workman's accomodations P S seal ; NOTE: THIS PO REPLACES PO#2680 . ——— Deposit Required: $ 0.00 Total:$ = 780,000.00 CK : Payments: $ 780,000.00 : Acconnt #: . ; Terms: 100% Deposit mT —_-- DO NOT PROCESS TIS ORDEX HMLESS EPRCIFICATIONS AND PRICES ARE CORRECT - " gueausi?M /LST-OFFICE/OFFICE/ gun lS}OFFICE~—~—~*S*S cle apr, OFFICE ieee ATELIER FANCELLI — . ~ 63 RUEALBERT : more . "AE Peostesen * * Jomonzen tein xe oun out ope “aeuere WoEtt seen es V08. at 3 onan WERE mk Mi aEX AtreMsnentacie est PRCEST 106 08s Hit RMD OOD tn Kee oye FA Tear TEs wn Puoren NURISEAS OREMENS CTIMRICEA HEN INES RAN, E Dem EME MAIO, SY. RESALE # 15-310-2323 * . ‘ i EFTA00299574

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em) Case: 3:10-cv-00034-CVG-RM Document #: 8-3 Filed: 06/11/10 Page 8 of 8 EXHIBIT B “and “mine” shall refer to Juan Pablo {n the following Exhibit B, the words “I,” “me Molyneux and the words “you” and “your” shall refer to Jeffrey Epstein, ! propose to include all of the following services and items for the $250,000 that we have agreed: : ates ©The Office/Ubrery: Fancelli will complete the installation at no cost to you. This means that you will not be ing travel, lodging, food, incidentals, Tesponsible for any Fancelli installer expenses Includ ete, After Fancelli finishes the installation, | will decide if the color of adequate for the overall ambiance. If it Is the paneling Is services | will provide and at no Cost to you. contemporary’ desk (Design JPM) with 2 Ceiling. | will provide back-up docu; the rates in the Design Services Agreement) for the above items and services and if the total amount falls short of $250,000, | will provide other Items at my reasonable fiice Pavilion so that the total amount equals $250,000, ! will make two trips /visits to Little Seint James Island on dates determined by me in my necessary or appropriate to oversee, perform and complete reasonable discretion to be the above work, not, | will select color with your ap proval and 7 EFTA00299575

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Kristen Goff : ne nn — "| — ee from: int ednesday, March 17, 2010 8:33 AM 10; Kristen Goff: Pilar Molyneux Subject: Fw; : ; Categorles: Red Category OL Cee eet enews yer jee a ee a Date: Wed, 17 Mar, To: Aurelien >eviilliliiae? Subject; Fw; , Sent from my BlackBerry® wireless device “on Ermhne 0 Ssiidtleei Tan te From; Jeffrey Epstein ees ‘ Date: a -0400 To: jp Ce: Doug Schoett a. Gary Kemey<( Darren ny Subject: : you are only to communicate with gary Kearney, me or through your attnys to darren, Doug docs not have all the facts. Theinte ne etttteetste stones etonetsennanssseneneecesennes The information Contained in this communication is confidential, may be allomey-client Privileged, may Constitute inside information, and is intended only for the use of the addressee. It is the Property of Jeffrey Epstein Unauthorized use, disclosure or copying of this communication or any part thercof is Strictly prohibited and may be unlawful, If you have received this communication in error, pl j j i by retum e-mail or by e-mail {o and destroy this communication and all copies thereof, including all attachments, EFTA00299576

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Document #013 Sent from my BlackBerty wireless cies Meeting August 20" 2010 tan the installation of the toe molding dt the baseboard. Ma Closure trim piece of oak belowthe picture window sill to £431 gapSapprox. £372 ° > ctire window. rogétrand “IC Complete MO 2 instar 3 ca high, the length of the window. : +3z— Finish rough, unfinished end condition at the sliding panels at ay Drill, file and sand perforations at tilt down’ desk panels to a x ragged edges. = Give and clarp open joints’ in paneling through o *6- Generally sand rough fintshes and raised grein at paneling through Sut the room. Oe Replace tortise shell inlay where it is pieced or flaking and c Rg . binet door hardware so that the screw does not loosen when the handle is hardware does. not rattle. af i ; g - : i a i F not rust. 1x. Replace the non functioning blackboards with slate that will take chalk. + The With water and dried. The surface does not take chalk existing surface fas been wiped clean che iz. Provide additional Light bulbs for the shelf lights inside the cabinets and provide 7 : . be Poy e-th. The staining of the cornice should be like the Escorial Library with Light: and P4107 15. the staining of the colums should PUT 36.012 wood surfaces in the room are to be finished, currently the undersides of the ‘the ¥ lights are on. AJIT 38. ALL wood surfaces are to be varnished. -” The sliding panels are unfinished plywood, how are tiey to be finished? 19. 20. HL Wipop KlORKK 15 DoNE On THE LIST OTHER Blew (SSVES. . |. Seub vs Lite Beres : so 2. SEenp ¢S GA MiBoo Certalf bbls ¢ surly 3. BLACK BOARD. Bes /2yp EFTA00299577

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Document #014 Meeting August 20" 2010 Lute Mari 23. SG17 Work Approvat Mol.neur Studo 29 East 69th Street ertyeects St. James CFFITE Following the on site meeung flarch 22° = 23° 2010, among The Chent Represantanve Gary Kerney, At 3(25] 29 f 2 Molynaux Studio: Juan Pablo Motvneux, OPEN \ Wucof . Fancelh Panehng: Jean Preree Fanceltr {. SEHD Lie BULBS Int dofthe tutte § J Off ject: a ie" se am Darhee ce crayec -. SEM DAHBOD CU Molyneux Stud Purchase Order =2680 4 SiG Any l SHA WL Fancell Panekng Invoice =2024 Office Complement, 3. BlAcw BOARD Molyneux Stucko Purchase Order =6321 Fancelh Paneling Invoice = 1098 The work executed by Fanceth Paneling follwing the preoyect designed by Molynaux Stucko, and corrections executed March 19- 23’: are approved and accepted by the client representsuve and Dy Molyneux Stucho. Balance on completed workis now due. St James Island, USVI. March 23, 2010 Chent Representative Designer Fancell Contr acter Juan Pablo Malynaux Jean Perce Fancell Gary Kernay 6 EFTA00299578

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Bult 71 LAW OFFICES oF JAY GOLDBERG, El 250 PARK AVENUE TWENTIETH FLOOR NEW YORK. NY 10177-0077 TELEPHONE 12121 63-6000 TELE COPIER (2121 983-6000 May 10, 2010 VIA E-MAIL: Darren K. Indyke, Esq. Darren K. Indyke, PLLC 301 East 66" Street, 10B New York, New York 10065 FOR USE DURING LITIGATION Dear Darren: Reference is made to my previous letters to you. client believed warranted Mr. Fancellj’s attention, your client should have been on the island and not “laid back in the grass”, claiming that there are new problems which were overlooked when your client’s personnel prepared the punch list, time ~ to have Mr. Fancelli return to the island to finish the cabinetry as you _ Wish, with Mr. Molyneux anda representative of his staff present. But the responsibility must be your client’s to arrange for Mr. Fancelli and his craftsmen to appear, pre-pay their expenses and that of Mr. Molyneux and a EFTA00299579

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representative of his office, and to pay for the expense of refinishing the cabinetry with the color your client finds desirable, : My previous correspondence should be taken as the response to your later served Notice to Cure. This whole controversy could have been avoided had your client taken the time to appear at the island. . Sincerely, Jay Goldberg 24 EFTA00299580