MARIA AN KENSON HODGE, P.C.

MARIA AN KENSON HODGE, P.C. DENISE. FRANCOI P.C. TO: FROM: Denise Franco RE: LAW OFFICES OF HODGE & FRANCOIS 1340 TAARNEDERG ST. THOMAS, VI 00802 TELEPHONE: 340.774.684S • TELEFAX 340.776.7720 MEMORANDUM Darren K. Indyke MARK HODGE GATLIN VOGEL Request for information with respect to all Civil Lawsuits of which JE, FTC or LSJ or Lafayette were named as defendants in the past 10 years: date lawsuit filed, name and address of the court, docket/case number, names of any other parties to the suit, nature of suit, disposition and date of disposition of suit. DATE: October 25, 2011 1. Financial Trust Company, Inc. vs. Citibank, N.A. Plaintiff: Financial mist Company, Inc. Defendant Citibank, N.A. & counterclaim Plaintiff Date lawsuit filed: June 11, 2002 Name of the court: District Court of the Virgin Islands, St. Thomas/St. John Division Address: 550 Veteran's Drive, Rm. 310, St. Thomas, VI 00802 Docket/case number 3:02-cv-00108 Nature of suit: Action for fraudulent misrepresentation, damages, rescission; Counterclaim against Financial Trust Company, Inc. was to enforce two notes and hypothecation agreement Disposition: Settled and stipulation for dismissal filed 2. Main Gifford d/b/a Blessed Trucking vs. LSJ, LLC, Lafayette Contractors, LLC, William Rowles and Lance Galloway Plaintiff: Alain Gifford d/b/a Blessed Trucking Defendants LSJ, LW, Lafayette Contractors, LLC, Williams Rowles and Lance Galloway Date lawsuit filed: February 20, 2009 Name of the court: Superior Court of the Virgin Islands, St. Thomas/St. John Division Address of court: P. O. Box 70, St. Thomas, VI 00804 Docket/case number: ST-09-CV-91 Nature of suit: Breach of contract Disposition: Dismissed by order of the court Date of disposition: September 20, 2010 EFTA00307081 2. Jeffrey E. Epstein v. D. Eric Williams a/k/a Eric Williams, Hairoun Aviation Services, Inc., R Pearlitha Williams and Josephine Simmons Plaintiff: Jeffrey E. Epstein Defendants & Counterclaim Plaintiffs: D. Eric Williams a/k/a Eric Williams, Hairoun Aviation Services, Inc., R. Pearlitha Williams and Josephine Simmons Date lawsuit filed: July 1, 2009 Nature of suit: Breach of contract, specific performance, material misrepresentation, fraud and declaratory relief. Defendant's counterclaim was for breach of contract and damages Docket/case number. ST-09-CV-307 Disposition: Settled and stipulation for dismissal filed Date of disposition: March 15, 2010 3. J.P. Molyneux Studio, Ltd. and Juan Pablo Molyneux vs. Jeffrey Epstein and L.S.J., LLC Plaintiffs: Defendants: Date lawsuit filed: Name of the Court: Address: Docket/case number. Nature of suit: Disposition: Date of disposition: 4. Jeffrey Epstein and Plaintiffs: Defendant: Date lawsuit filed: Name of the Court: Address of Court: Docket/case number. Nature of Suit Disposition: J.P. Molyneux Studio, Ltd. and Juan Pablo Molyneux Jeffrey Epstein and L.S.J., LLC April I, 2010 District Court of the Virgin Islands, St. Thomas/St. John Division 550 Veteran's Drive, Rm 310, St. Thomas, VI 00802 3:10-cv-00034 Breach of contract Settled January 4, 2011 self executing stipulation for dismissal with prejudice filed L.S.J., LLC vs. Fancelli Paneling, Inc. Jeffrey Epstein and L.S.J., LLC Fancelli Paneling, Inc. July 30, 2010 Superior Court of the Virgin Islands, St. Thomas/St. John Division P.O. Box 70, St. Thomas, VI 00804 ST-10-CV-443 Breach of contract, negligence pending 2 EFTA00307082