Document #013 Sent from my BlackBerfy wireless device Meeting August 20“ 2010 From: Doug Schoettig Ls Date: Wed, 16° Mar “2819 09:58:56 -98e0 (PST) To: <jpm6929@a0l<tom> * - Coa onee icon; TE < cE | 12150: Rowles<w : Subject: F. ich List . . z 7 FANCELLI PUNCH LIST . Wood Paneling at LSJ Office . “if “i Complete the installation of the toe molding dt the baseboard. Matépial olf site. 2. Install closure trim piece of oak belowthe picture window sill to £01 gapzapprox, 3 ca high, the length of the window. . Boar . ~3<— Finish rough, unfinished end condition st the sliding panels at thepictire window. “> Drill, file and sand perforations at tilt down’ desk panels to remove rodpty- and ragged edges. at = Glue and clarp open joints in paneling through out the room & a through out the room. delaminati; IZ. Provide additional the specification. ‘ Doywers. The staining of the cornice should be like the Escorial Library with Light and dark. BH1H7-15. the staining of the columns should highlight TT 36.a11 wood surfaces room finished, current ge unfistished. wm fhe ane fo Be * = ersitieg of the eas dept? aan tt Dinets are to be stained darker so as not to appear orange when AJT 28. ALL wood surfaces are to be varnished. 2. The sliding panels are unfinished plywood, how are they to be Finished? ALL Kf00f KOR. 15 DoNE on THE LIsT OTHER TH Bphew (Saves: |. Seud vs Lite BerBs 2. Seyp ¢S BGAMBoe Gtalf F486 6 IUAl 3. BACKBOARD. Blas / 20 EFTA00308279

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Document #014 Meeting August 20% 2010 Date Mgech 23. 2010 Work Approvat Mol meu Studio ast Pe ererse St. lames CFFICE Following the on ste meeting March 22°: - 23% 2010, among: The Chent Representative: Gary Kerney, Al 3/ 25/ 29 ? Molyaeux Studo: Juan Pablo Molyneux, OPEN | WUGS . Fancelh Paneling: Jean Prerre Fancelh, 4. SEND le BULBS In regard “+3 the Little Samt James Office project: 2 . JEM BANBOQD CY Ut Molyneux Stude Purchase Order ©2680 u Sie ANS b SHALL Fancel Panekng Invorce =2024 © : Molyneux Studeo Purchase Order =8321 3 - BlAc K BOARD Fanceli Panekng Invoice = 1098 The work executed by Fancelk Paneling following the project designed by Molyneux Studio, and correcbons executed March 19- 23% are approved and accepted by the chent representabve and by Molyneux Studio. Balance on completed workis now due. StJames Island, USVI. March 23, 2010 Chent Representative Oesigner Eancssik Contractor Gary Kerney Juan Pablo Holyneux Jean Prerre Fancelu EFTA00308280

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10; Subject: Kristen Goff : "rom: | . Int: Wednesday, March 17, 2010 8:33 AM Kristen Goff. Pilar Molyneux Pwr. Categories: Red Category a = Pon Date: » 17 Ma VE ) To: Aurelien Paris baad” ; Subject: Fy: Sent from my BlackBerry® wireless device ne rene a pean eager te, PAO eee es, From: Jefirey Epstein <Jecvacation@gmail.com> Date: 219:35 -0400 . ee... To: j 70U are only to communicate with gary keamey, me or through your atinys to darren, Doug does not have all Ce; Dou: Indyk Subject: the facts. abhbbebhaeet TLL TTT TTT Tren o¢ TOS eon eeeesresesceeeenes The information Contained in this communication is , confidential, may be altomey-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 thereof is Strictly prohibited and may be unlawful, If you have received this communication in error, please notify us immediately by relum e-mail or by e-mail to jeevacati umai and destroy this communication and all copies thereof, including all attachments, EFTA00308281

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Chvono |]% Little St. James Punch List Report March 22, 2010 Document #015 Meeting August 20 2010 EFTA00308282

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JP MOLYNEUX STUDIO LTD. With toe molding Request: Complete the Installation of toe molding. Status: Toe molding Is on site and will be Installed week of March 22-26, ‘. Doe - 01901 — Punch List ~ Item #1 EFTA00308283

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JP MOLYNEUX STUDIO LTD. Gap underneath window sill , Statiis: The gap must remain. The sliding shutter track Is located here—the 8ap needs to be open to fu: We 01901 ~ Punch List ~ Item #2 Request: Install closure trim plece of oak below the picture window sill to fill gap approx. 3em high, the length of the window. nction properly. EFTA00308284

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JP MOLYNEUX STUDIO LTD. Top right ~ finished end Bottom left unfinished end Bottom right ~ unfinished end Request: Finish rough unfinished end condition at the sliding panels at the picture window, Status: Two finished ends as of March 22, two more to be finished week of March 22-26, _ Dow 01901 = Punch List ~ Lrem #3 & EFTA00308285

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JP MOLYNEUX STUDIO LTD. Drilled, flled and sanded holes tilled, filed and sanded perforations D Request: Drill, file and sand perforations at tilt down desk panels to remove rough and ragged edges. Status: Complete. 01901- Punch List — Item #4 EFTA00308286

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JP MOLYNEUX STUDIO LTD. Corner miter Joint glued and clamped, Request: Glue and clamp open Joints In panelln g throughout the room, Status: Complete, 04901 - Punch List - ftem #5 6 EFTA00308287

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JP MOLYNEUX STUDIO LTD. Inner edges of wood profiles cleaned throughout. Dake Request; Generally sand rough finishes and ralsed grain at paneling throughout the room, Status: Initial requested finish was distressed, salvaged from sea and weathered, Sanding Is complete In small crevices throughout, EFTA00308288

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JP MOLYNEUX STUDIO LTD. 52 Repalred tortolse shell Inlay — pre-install Repalred tortolse shell Inla Request: Replace tortolse shell Inlay where It Is pleced or flaki: ng and delaminating. Status: Will be completed week of March 22-26, 1901 — Punch List — Item #7 EFTA00308289

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Vertical hardware rod with top, m bottom fastener, New middle ring (above shell handle) installed Request; Repair cabinet door hardware so screw does not loosen when hand Status: Complete. A third metal ring was Installed on metal vertical bar to act as third fastener, 01901 ~ Punch List ~ Item #8 yy. Je Is rotated to operate the door and so rattle Is ellminated, eliminating rattle. Hardware tightened EFTA00308290

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JP MOLYNEUX STUDIO LTD. Request: Supply and Install two new turtle pulls. Status: Complete, 01901 ~ Punch List ~ rem #9 10 EFTA00308291

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JP MOLYNEUX STUDIO LTD. edrmaed bamboo grille, Damaged bamboo grille, , Request: Replace bamboo mesh at all cabinet doges wi th metal mesh Ina dark color that will not rust, Status: li has repaired damaged grilles and will provide 8 new framed grilles for future use, 01901 - Punch List — Item #10 EFTA00308292

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JP MOLYNEUX STUDIO LID. Appropriate chalk to use. The blackboard works ~ tested on site, " Request: Replace the non Status: Replacement of bl. 01901 - Punch List ~ Item #11 EFTA00308293

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JP MOLYNEUX STUDIO LTD. o ~ it oe bs Inside cabinet shelf. Light bulbs Inside cabinet shelf. Request: Provide additional light bulbs for the shelf lights Inside the cabinets and provide the specifications. Status: Fancelli will provide the specifications for the light bulbs » Ordering the bulbs Is not In the agreement and must be paid for by client, 01901 - Punch List — Item #12 {5 EFTA00308294

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JP MOLYNEUX STUDIO LTD. : , Request: Confirm the size of the carpet and provide under— padding. Status: Carpet padding Is not In the agreement. 01901 - Punch List = Item #13 EFTA00308295

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JP MOLYNEUX STUDIO LTD. Cornice light and dark. Request: The staining of the cornice should be like the Escorial llbrary with light and dark, Status: Fancelll will stain the cornice with light and da tk after the dehumidifier |s Installed and the moisture content of wood Is acceptable. 01901 — Punch List — Item #14 EFTA00308296

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Request: The stalning of the columns should highlight the carvings with light and dark. Status: Fancelli will stain the columns after the dehumidifler Is Installed and the molsture content of wood Is acceptable, 0150i ~ Punch List — ftem #15 16 EFTA00308297

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JP MOLYNEUX STUDIO LTD. Appieied and signed finish (at left). y) proved and sig ed Request: All wood surfaces In the room are to be finished’ Currently, the undersides of the desk tops are unfinished. Status: Fancelll will stain all wood surfaces after the dehumidifier Is | nstalled and the molsture content of wood Is acceptable. 01901 — Punch List — rem #16 EFTA00308298

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JP MOLYNEUX STUDIO LTD. eee Two finish options within cabinet. Pid . Two finish options within cabinet, Request: Interiors of the cabinets are to be stained da rker so as not to appear orange when the shelf lights are on. Status: Two alternate finishes have been produced on site. JPM and Gary Kerney do not recommend changing the Interior finish. Dern Me 01901 — Punch List — Item #17 18 EFTA00308299

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JP MOLYNEUX STUDIO LTD. Request: All wood sucfaces are to be varnished, — Status: Fancell] wit! stain TT wood surfaces after the dehumidifler Is installed and after the molsture content in the wood Is acceptable, 0£903 — Punch List Item #18 9 EFTA00308300

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Shutters, Request: The sliding panels are Unfinished plywood. How are they to be finished? Status: Not In agreement. 91901 ~ Punch List — Item #19 Rejected leather for shutter Insert. EFTA00308301

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Case: 3:10-cv-00034-CVG -RM Document #:8 Filed: 06/11/10 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. NS 3. Defendant Jeffrey Epstein is a citizen of the Territory of the U.S. Virgin Islands. 4. 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. 5. 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). DEEENDANT’?S EXHIBIT, EFTA00308302

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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 Plaintiffs. 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 J a 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. EFTA00308303

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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.On 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. EFTA00308304

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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: a. Whether the Plaintiffs substantially performed their duties as required by the Design Services Agreement; b. | 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 c. Whether, as alleged in Defendants’ April 15, 2010 letter, Plaintiffs fraudulently induced Defendants to enter the Settlement 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; EFTA00308305

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Case: 3:10-cv-00034-CVG -RM Document #:8 Filed: 06/11/10 Page 5 of 5 b. | Adjudging and declaring that the Defendants violated their duty of good faith and fair dealing 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. 4 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 . Tel. Fax EFTA00308306

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Case: 3:10-cv-00034-CVG-RM Document #: 8-1 Filed: 06/11/10 Page 1 of 1 + SSE Rev 1109 CIVIL COVER SHEET Be ne ee erred pe pty map DEFENDANTS - Jeffrey Epstein and L.S.J., LLC County of Residence of Fiest Listed Defendant Sc Thomas VI (0H US. PLAINTIFF CASES ONLY) _~ (a) PLAINTIFFS f yp. Molyneux Studio, Ltd. and-Juan Pablo Molyneux (b) County of Residence of First Listed Plaintitr New York, NY (EXCEPT INUS. PLAINTIFF CASES) (©) Attomey’s (Firs Nene, Addexts, wed Telcpheac Number} Rosh D. Alger, Esq., PMB J0 Royal Dane Mall Od Feder! Question (US. Government Mots Party) O2 US Govemoca Bt Diversity . Oviniet (tadicate Citecruhip of Partes ia hem itt) V. ORIGIN (Pisce an “Xin One Box Only) 02 G3 pemanded trom TA peintated oe O 5 Tamsteretiom 6 | 7 5! original Removed fom REO CHECK YES only demanded conpldne COMPLAINT: UNDER P.R.C.P. 23 . JURYDEMAND:- O Yes Ns IF ANY Gr kaneton® uDGE DOCKET NUMDER ; — OFx : 06/11/2010 s/Rosh D. Alger . . RECEIPT & AMOUNT , APPLYING IFP woe MAG WUDGE “ ——— —_ eerie ee A EFTA00308307

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" connection with design and:related services by "Epstein (the “Disputes”; and ' Releasees"), of and from any a Case: 3:10-cv-00034-CVG-RM Document #: 8-2 Filed: 06/11/10 Page 1of6 THIS AGREEMENT, entered into this 15th day of May, 2009, by and among Juan Pablo Molyneux ("JP"), Molyneux Studio, Ltd. (“Studio”, and together with JP, “Molyneux,”) L.S.J., LLC (“LS]") and Jeffrey Epstein (“Epstein”). WHEREAS, disputes have arisen between Molyneux, on the one hand, and LSJ and Epstein, on the other hand, relating to payments and deliverables in Molyneux for LS] and/or Epstein properties beneficially owned by with respect to Little St. James Island and other WHEREAS, the parties hereto desire to settle all Disputes as provided in this Agreement; NOW, THEREFORE, in consideration of the foregoing premises and the rautual agreements, promises and other provisions contained herein, JP, Studio, LS] and Epstein (the “Parties"), intending to be bound, hereby agree as follows: subject to and in 1. The Parties agree to settle the Disputes, upon, 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 tq an 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 each 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, rights, liabilities, losses, obligations, duties, damages, debts, expenses, interest, penalties, sanctions, fees, attorneys’ fees, costs, actions, potential actions, causes of action, suits, agreements, judgments, decrees, matters, issues and controversies of any kind, nature or description “whatsoever, whether known or unknown; disclosed or undisclosed, accrued or unaccrued, apparent or not apparent, foreseen or unforeseen, matured or not matured, suspected or unsuspected, liquidated or not liquidated, fixed or contingent, whether direct, derivative, individual, representative, legal, equitable, or of any type, or in any other capacity; whether based on state, local, foreign, federal, statutory, regulatory, common, or other law, for, upon or by reason of any matter, cause, or thing whatsoever in any way relating to, involving, referring to, arising out of, or based upon, directly or indirectly, any 1 of their successors, assigns, heirs, | & tht: EFTA00308308

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_—, — oo ? Case: 3:10-cv-00034-CVG-RM Document #: 8-2 Filed: 06/11/10 Page 2 of 6 actions, transactions, occurrences, statements, representations, misrepresen tations, 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 of their respective joint or several obligations under this Agreement or the Design Services Agreement. ; (b) . JP and Studio and each of their successors, assigns, heirs, executors and administrators (collectively, the “Molyneux Releasors") hereby fully and irrevocably release each of Epstein and LSJ, and each of their successors, assigns, principals, heirs, executors, and administrators (collectively, the “Epstein Releasees"), of and from any and all manner of claims, demands, rights, liabilities, losses, obligations, duties, damages, debts, expenses, interest, penalties, sanctions, fees, attorneys’ fees, costs, actions, potential actions,, causes of action, suits, agreements, Judgments, decrees, matters, issues and controversies of any kind, nature or description whatsoever, whether known or unknown, disclosed or undisclosed, accrued or unaccrued, appa matured, suspected or unsuspected, lquidated or not representative, legal, equitable, or of any type, or in any other capacity, whether based on state, Jocal, foreign, federal, statutory, regulatory, common, or other law, for, upon or by reason of any matter, cause, or thing whatsoever in any way relating 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 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(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. ring into this Agreement, the Parties do not intend to 2 4. By ente admission of liability of any kind nor shall they be deemed to have made, any re entering into this Agreement forthe . whatsoever. The Parties agree that they a purpose of settling certain disputes between them and to avold further expense with respect to those disputes. Services Agreement, No Party ma: this settlement without the prior, written consent of each of the other Parties; provided, howeyer, that a Party may disclose facts about the settlement (i) to its or his employees, EFTA00308309

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eee Case: 3:10-cv-00034-CVG-RM Document #: 8-2 Filed: 06/11/10 Page 3 of 6 accountants and attomeys 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 (iv) in response to a duly authorized subpoena or court order. Before disclosing any 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 prior {o disclosing any facts about the settlement under provisos (iii) or (iv) above (other than in connection with proceedings to enforce the provisions of this Agreement or the Design Services Agreement), to the extent pennissible by law, regulation, rule of a court or court ageacy or court order, the Party making or asked to make the disclosure shal] inform each of the other Parties of the proposed shall, at the 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 maifitained in confidence and/or held under seal, "= * 6. -The Parties agree that the prior drafting history of this Agreement shall- not 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 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 empowered and authorized to sign on behalf of and bind the Parties for whom they have signed. . . 8. 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 any claims, demands, causes of action, rights, or obligations related in any way to 3(a) and 3 (b) to any other person or entity, - the claims to be released in paragraphs nor’shall they hereafter do so, 9. Each Party agrees that this successors, and assigns of each Party. grees that such Party: (i) has fully 10. Each Party represents and a the opportunity to seek advice by reviewed this Agreement and has had pect to the same; (ii) fully understands independent counsel of its choosing with res Agreement and has entered Into this Agreement voluntarily the terms of this without any coercion or duress on the Part of any person or entity; and (iii) was Agreement shall be binding upon the heirs, disclosure or request for information, and . EFTA00308310

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» 4} dl 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. 11. — This Agreement may be executed in any number of counterparts, each 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 instrument executed by the duly authorized representatives of all of the Parties. 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 ts given. No failure on the part of ary Party to exercise, and no delay in exercising, any right, power or privilege under this Agreement shall Operate as’a waiver 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 es indicated below, until such time as ‘overnight courier to the attention of the Parti t notice of any change of person to be notified or change of address ts forwarded to all Parties; (a) For Epstein and LS): Darren K, Indyke, Esq. (6) = For JP and Studio: Jay Goldberg, Esq. 14. This Agreement shall be governed by and: construed: in accordance greements entered into entirely with the laws of the Virgin Islands applicable to a within the Virgin Islands, without regard to the principles of Virgin Islands law regarding conflicts oflaws. EFTA00308311

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{ ~, ) ’ court. Each’Party irrevocably and’ uncond 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 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 hereof shall be effective service of process for any action, suit or Proceeding brought in any such itionally waives any objection to the laying of venue of any such suit, action or proceeding brought in'any such court and any claim that any such suit, action or proceeding brought in such court has been brought in an inconvenient forum. E proceeding brought in any such court shall be Judgment in any such suit, action or conclusive and binding upon such Party and may be’enforced in any other 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 ir duly authorized representatives, as the case may " be executed by themselves or the be, as of the date of the day and year first above-written. JP. MOLYNEUX STUDIO, LTD. LS.J., LLC By JEFFREY EPSTEIN. Member ach Party agrees that a final, non-appealable _ EFTA00308312

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be executed by themselves or Case: 3:10-cv-00034-CVG-RM Document #: 8-2 Filed: 06/11/10 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, » ~-Court-- Each Party-irrevocably-and-unconditionally-waives-any objection tothe ~ - laying of venue of any such suit, action or. proceeding brought in any such court and any claim that any such suit, 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 enforced in any othér courts to whose jurisdiction such Party is or may be subject, by suit upon judgment. IN WITNESS WHEREOF, their duly authorized representatives, as the case may be, as of the date of the day and year first above-written, J.P. MOLYNEUX STUDIO, LTD. By: : Juan Pablo Molyneux President JUAN PABLO MOLYNEUX the parties hereto have caused this Agreement to EFTA00308313

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, :06/11/10 Page 1 of8 t#:8-3 Filed: 06/ : 00034-CVG-RM Documen "hereby agrees as follows: - and the paym * Of the Credit against the same. 2009, byand among Juan Pablo Molyney IP”), J.P. me (US")and Jefirey Epstein (Epstainy. oF the- parties hereto (the Parties"), intending to be bound hereby, Z, Upon executio, Valuable and Sufficient consideration, Molyn a Fifty Ousand Dollars ($250,000) (the Credit") to be @pplied against future Services provided by, and out of ind expenses incurred by, Studio, to and for the benefit of Epstein and/or LSJ, as determined by Epstein in his reasonable discretion {the “Covered Servi 2. With respect to actual Services rendereg as part of the Covereg Se Studio shal] bill Epstein and apply such bills'‘against the Credit ata rate qual to Five Hundred Dollars ($500) Per hour for Services rendered by JP and Bighty Dollars ($80) per hour for Studio Staff, nably determined by Epstein construction, and €Xterjor to be necessary or @Ppropriate ° design, and interior design and decoration, including furniture and furnishings, of the offica Pavilion currently under Construction on Little St. James Island (the “Office Pavilion"), and will further Include ision of the skilled labor and Supervision, ent of all expenses and disbursements in connection therewith, oper installation, restaining and refinishing of the cabinetry NEcessary for the pr Hier Fancel}j, alréady delivered to Little St. James by Ate. A Notwithstanding the provisions of Section 3 hereof the Parties acknowledge that the labor es for the installation of such cabine Were included in a Pre- existing Purchase order between Studio and Epstein, attached hereto as Exhibit A, and agree that such labor charges Shall be Paid for by Molyneux without application tis a material term of this @greement that as part Of the. be rly installed and completed at the 5. Molyneux Shall furnish and cause to Prope Office Pavilion by January 1, 2010 all of the itenis listed on Exhibit B hereto and that the Office Pavilion wil} be completed to Epstein’s reasonable Satisfaction by January 1, 2020, Molyneux agrees that the’ aggrevate amount to be a Credit for the Provision, installation and completion of aj} Such items shall not ‘exceed the amount of the Credit and that ne liability to make any payment to Molyneux jn respect of any such items. EFTA00308314

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os. Case: 3:10-cv-00034-CVG-RM Document #: 8-3 Filed: 06/11/10 Page 2ofg 6, In the event that by the fifth anniversary of the date that this Agreement is have provided Covered executed by all of the parties hereto, Studio shall not Services in an amount equal to the Credit, then on the date of such fifth anniversary, Molyneux shall pay Epstein the unapplied balance of the Credit by wire transfer to the “Designated Account”) an account designated in writing by Epstein to Molyneux ( days prior tothe fifth anniversary date, Ia the event that Molyneux is deemed in breach of this Agreement in accordance with the provisions of Section 8 hereof, is in breach under Section 8 hereof, the then, effective as of the date that Molyneux unapplied balance of the Credit as of such date shall be due and payable to Epstein, Promptly upon demand by Epstein to Molyneux, Molyneux shall pay Epstein such unapplied balance by wire er to the Designated Account specified in such demand, 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 4 material term of this Agreement, Including, 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 * failure to complete the Office Pavilion to Epstein’s reasonable satisfaction by January 1, 2010 which is not cured by Molyneux, Molyneux shall pay Epstein as - liquidated damages $250,000 within 30 days of the expiration of Molyneux’s ten day eto understand and agree that such $250,000 material breach, the actual amount of be difficult to ascertain and, under the liquidated damages is fair and reasonable, 9. JP. states that neither he nor Studio js an architect and have not held themselves out as same regarding 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 Agreement . 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, inducement, promise, agreement, or warranty that is not contained in this Agreement or the Settlement Agreement, , . ‘ history of this Agreement shall not 11. ‘The Parties agree that the prior drafting 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 EFTA00308315

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Case: 3:10-cv-00034-CVG-RM Document #:8-3 Filed: 06/11/10 Page 3of8 hereof will not be construed for or against any such Party as the principal Crafter of CT) . this Agreement. 12. The individuals signing this Agreement and the Parties on whose behalf such ereby represent and warrant that they are empowered and individuals are signing h half of and biid the Parties for whom they have signed. _ authorized to sign on be! 13, . Each Party agrees that this Agre: Successors, and assigns of each Party, 14, Each Party represents and agrees that such Party: (1) has fully reviewed this Agreement and has had the opportunity to seek.advice by independent counsel! of its choosing with respect to the same; (ii) fully uriderstands the terms of this Agreement and has éntered into this Agreement voluntarily without any coercion or and (ili) was given adequate time to duress on the part of any person or entity; consider all implications of this Agreement prior to entering into It. 15. This Agreement may be executed in any number of counterparts, each of which shall be deemed an original, but all of which together shall constitute one and the same instrument. Signatures of this Agreement transmitted by fax shall have the Same effect as original signatures, : modified except by a written 16. This Agreement may not be amended or * instrument executed by the duly authorized Tepresentatives of all of the Parties, () 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 is given. No failure on the part of any Party to exercise, and no delay in exercising, any right, power or Privilege under this Agreement shall operate as a waiver thereof; nor shal] 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. , , or notices to be provided 17, Any demands, statements, communications. 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 notice of any change of person to be notified or change of address is forwarded to all Parties: s 4 (a) For Epstein and Ls): ement shall be binding upon the heirs, Darren K. Ind EFTA00308316

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Case: 3:10-cv-00034-CVG-RM Document #: 8-3 Filed: 06/1110 Page 4 ofg (b) ForJP and Studio: Jay Goldberg, Esq. . 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 irrevocably and unconditionally submits to the exdusive jurisdiction of any court sitting in the Virgin Islands over any sult, 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 irrevocably 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 suit, 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 suit upon judgment. 20. The Parties agree ‘that the existence, terms, and consideration paid pursnant 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 reveal 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) to its or his employees, accountants and attorneys who require the g their employment duties or providing same for the purpose of performin to its or his insurers or re-insurers; (iii) as professional services to such Party; (ii) required 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 any facts about the settlement under provisos (i) 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 to ensure that the receiving party agrees 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 (iv) above (other or than in connection with proceedings fo enforce the provisions of this the Design Services Agreement), to the extent permissible by law, regulation, rule of EFTA00308317

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Case: 3:10-cv-00034-CVG-RM Document #: 8-3 Filed: 06/11/10 Page5of8 a 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 disclasure or request for information, and shall, at the 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 caused this Agreement to be executed by themselves or their duly authorized representatives, as the case may be, asof the date of the day and year first above-written. J.P. MOLYNEUX STUDIO, LTD, By: . . Juan Pablo Molyneux President JUAN PABLO MOLYNEUX EFTA00308318

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Case: 3:10-cv-00034-CVG-RM Document #: 8-3 Filed: 06/11/10 Page 6 of 8 4 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, at the Tequest of any Party and at the cost of such requesting Party, file any disclosure or respouse 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 ander — IN WITNESS WHEREOF, the parties hereto have catised this Agreement to be executed by themselves or their duly authorized representatives, as the case may be, as of the date of the day and year first above-written. J.P. MOLYNEUX STUDIO, LTD. * Ju; lo Molyneux Pres! : L.S.J., LLC By JEFFREY EPSTEIN Member EFTA00308319

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( 5 29 FAST 690 STREET ) MIM YORKUNEW Yok eodsa at (21D) 628 COT PAX EID IIT Oe 680 pee meen recercctins fies ver FANCELLI PANELING 212-935-6537 212-935-6538 Fax . DESCRIPTION } Woodworking 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 and interior window shutter columns with bases and crown. Will include packing _ insurance and waterproof container to St. thomas and crew tavel. Cost will not inclade 2 globes, flat base (stone) transpartation of goods to St. . James, scaffolding, local taxes, customes or C) , workman's accomodations . ? NOTE: THIS PO REPLACES PO#2680 Deposit Required: $ 0.00 CK# : Payments: $ 780,000.00 Account #: Terms: 100% Deposit Case: 3:10-cv-00034-c¥d-kmbitodtinent #: 8-3” Filed: 06/11/10(kPagesMisfguuie MOLYNEUX ARCHITECTURAL INTERIORS & DECORATION 7106 4 RCE CHAPON “MOS PVRS. PMANCT meets betes ue fetter ad eas ASME erty © Hasty anttcuualin le 10/1 472008 Al ML arr EXTENDED Cost * Gxt cost 780,000.00 780,000.00 Total: $ 780,000.00 a DO NOT PROCESS THIS ORDER IIMLESS SPREINCATIONS AND PRICHS ARH CORRECT —______P0nor roces RDO ASEEMHCICATIONS ANIM AMRCMRTE may 29964 suesuuaslPM /LSJ-OFFICE /OFFICE/ uns: LSJ-OFFICE ATELIER FANCELLI - 63RUE ALBERT DAHLENNE ‘ "GAA PRONE oe TOUGIE O68 ORNEK NIMOFK ASO OT Dene ATTHOLT OF K ORDER NY APE HON OMT STAC We YOU FAIL TOSten F US ni er pmeny Ev 15310-2323 * mn _— NANKAD RV's AM TIORIZ RO NTENA ON. EE mae ane, RCENT (HV 1ih HPAL SIRS ROS Ie RED CDMESRA TIAN INS RANE Dee OME NRE EFTA00308320

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Case: 3:10-cv-00034-CVG-RM Document #: 8-3 Filed: 06/11/10 Page 8 of 8 EXHIBIT B In the following Exhibit B, the words “I” “me” and “mine” shall referto Juan Pablo Molyneux and the words “you” and “your” shall refer to Jeffrey Epstein, llowing services and items for the $250,000 that we Fancelli will complete the installation at n responsible for any Fancelli installer expenses Including travel, lodging, food, i ncidentals, will decide if the color of the Paneling is etc, After Fancelll finishes the installation, | not, | will select color with your 8pprovaland . adequate for the overall ambiance, If it Is réstain and refinish cabinetry as part of the services | will provide and at no cost to you. The desk J will include will be a bronze contemporary’ desk (Design JPM) with a modern swivel desk chair. | will also Include a guest desk chair anda desk set. The desk lamp I will include will also be contemporary. | will Include an upholstered window seat cushion for the window seat built into the cabinetry. In will include 4' pillows (silk velvet with custom tassel trim). For the sitting area, | will include four large scaled club chairs Upholstered in a cut cotton velvet (Bevilacqua Fabric), two contemporary ‘reading lights, a coffee table (Design JPM) with a unique tiger coral Parquetry top, a pair of contemporary Celestial and Terrestrial Globes (Design JPM, from the movie by John Ford). | will provide with your approval the design (which indudes selecting, but not purchasing the materials) for the floor of the structure. | will also include a Carpet which will be a sisal and the hardware for the cabinetry, which will be all bronze with shapes of marine fauna. | will also provide lighting and ceiling design with your approval for the structure. | will provide the ceiling Painting Which was préviously ordered which | will see the proper installation of the Same on the total amount falls short of $250, discretion to complete the Office Pavilion so that the total amount equals $250,000, ! will make two trips /visits to Little Saint James Island on dates determined by me in my perform and complete reasonable discretion to be necessary or appropriate to oversee, the above work. ‘ ! propose to include all of the fo! have agreed: 0 cost to you. This means that you will not be EFTA00308321