Document #013

Document #013 Sent from my Blacknerry wireless device From: Doug Schoettle Date: Wed, id—iiaivZele 0?:58:56 -0800 (PST) To: [email protected]> • Cc: <'eevacati il_com›; Rowles<w Subject: Fanc nch List FAHCELLI PUNCH LIST Wood Paneling at LS) Office C Meeting August 20th 2010 ; William . _ LI: Complete the installation of the toe molding at the baseboard. Matecial*site. 2. Install closure trim piece of oak.beloWthe picture window sill to f8l WI:approx. . cm high, the length of the window. • Finish rough, unfinished end condition at the sliding panels at the2pictere window. or: Drill, file and sand perforations at tilt dawn' desk panels to removtrodikand ragged edges. sr Glue and clamp open joints in paneling through out the room. .4": Generally sand rough finishes and raised grain at paneling through out the room. LTC Replace tortise shell inlay where it is pieced or flaking and 4elaminatinge 1-8: Repair cabinet door hardware so that the screw does not loosen when the handle is rotated to operate door and so the hardware does not rattle. Supply and -install two turtle pulls at tilt down desk panels. arkeplate-bambas-atesh at all cabinet doors with metal mesh in a dark color that will not rust. 11. Replace the non functioning blackbOards with slate that will take chalk.. The existing surface has been wiped clean with wax' and dried. The surface does not take chalk satisfactor/y. • Pill. Provide additional light bulbs for the shelf lights inside the cabinets and provide the specification. 'de-under_padding. /20-poily.=-14. The staining of the cornice should be like the Escorial Library with light and dark. /A/7-1S.The staining of the columns should highlight the carvings with light and dark. pittoir- iG.An wood surfaces in the room are to be finished, currently the undersides of the desk tops are unfinished. 7/1/ lu7-17.Interiors of the cabinets the shelf lights are on. 4/08. All wood surfaces are to be varnished./ 19. The sliding panels are unfinished plywood, how are they to be finished? 20. NIL - WO) WORK It Dou e o Ai rile L. I sr o -77-1-Eg-- ft-t-AIJ Repk1 1. 5(10 3 .,1/4113 u6 irc gc , (-es •Sr\ it> a S rwA (14 o c‘o 6-zyt 1 -e f4 541:4 3. arc-Atc-K-so Age, are to be stained darker so as not to appear orange when 3fr <AP/o qbEFENDANT'S 4 EXHIBIT ts, ft Ailimploinewisearamin, EFTA00308279 Document #014 Meeting August 20th 2010 t'T:O'.:h 23. 2O1 WORK APPRoval Mot .nen..: Stud° St. Limes (sr ICE Fotloicing the on Site meeting March 2.2*: - 23-; 2010, among: The client RePresentative Gary Kerney, Molyneux Studtol JuanPablo Molyneux.0P6 t MciaS Fancelli Panehng: Jean Pierre Fanelli, 4 (s Etib7, t( -&)(..-6...0 In regard of the tittle Saint lames Othce project: 2 sEt-th 0130.) 624 Lc office/go:0 WoodivOrk, Motyneux Studio Purchase Order =2680 LI 4th fe StiAtt Fanceb Paneling Invoice =1024 Officej p ron eL IJernn er7LACK, 30A2b Molyneux Stocko Purchase Order =8321 (-3 — FanceltiPaneting Invoke 31098 AI 31/5/23 ( 0 The work executed by FanCelli Paneling tOt106.ving the project designed by Ho)yneux Stuck, and corrections executed March 19- 23'i are approved and accepted by the client representative and by MOlyneuX Studio. Balance on completed work is now due. St James Island, USVI, March 23, 2010 Client Representative Oestgner Gary KCCOAY F3Ilteni Contractor Juan Pablo (z),21.113Zix lean Pierre F.an,C,CP EFTA00308280 Cr.t.Stk Kristen Goff cram: tot so: Subject; Categories: From Date: 17 Ma To: Aurelien , Subject: Fw: 11111111111111 Wednesday, March 17, 2010 8:33 AM Kristen Goff-, Filar Motyneux Fw. ' . Red Category • • Suit from my BlackBerry0 wireless device From: Jeffrey Epstein <jeevacationggmailcom> Date: 7:14:35-0400 To: jp Cc; Dou Indyke Subject: )SI Gary Kane ; Darren jou are only to communicate with gary keamey, me or through your attnys to damn, Doug does not have all the facts. The information contained in this communication Is confidential, may be attorney-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 return e-mail or by e-mail to [email protected], and destroy this communication and all copies thereof, including all attachments. EFTA00308281 Ckv-olno 113 Little St. James Punch List Report March 22, 2010 Document #015 Meeting August 20th 2010 OH' 12.Y • 7 EFTA00308282 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. N. 01901 — Punch UGC - Item #1 2 EFTA00308283 JP MOLYNEUX STUDIO LTD. Gap underneathwindow sill Request: Install closure trim piece of oak below the picture window sill to fill gap approx. 3cm high, the length of the window. Stall's: The gap must remain. The sliding shutter track is located here —the gap needs to be open to function properly. 01901 -- Punch List — Item #2 3 EFTA00308284 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. Top right— finished end 01901 — Pttnth List — Item #3 4 EFTA00308285 Drilled, filed and sanded holes JP MOLYNEUX STUDIO LTD. Oat %Lt. 'F..i/a "i• V et ^ . . . . r • • FC Mb yr S ; • . IPiNC i• i Wret • r . . 0;e4s.QX • • .4.; "„:1 • .4....:•4:••••0•:r;'''''' . ....'%:•ntr- • I • •:•';' : • Drilled, filed and sanded perforations 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 Corner miter Joint glued and clamped. JP MOLYNEUX STUDIO LTD. Wall edge at window seat glued and clamped. Request: Glue and clamp open joints In paneling throughout the room. Status: Complete. 01901 — Punch List — Item #5 EFTA00308287 JP MOLYNEUX STUDIO LTD. Inner edges of wood profiles cleaned throughout. Request: Generally sand rough finishes and raised grain at paneling throughout the room. Status: Initial requested finish was distressed, salvaged from sea and weathered. Sanding is complete in small crevices throughout. 01901— Punch List — Item #6 7 EFTA00308288 Repaired tortoise shell Inlay— pre-Install JP MOLYNEUX STUDIO LTD. Repaired tortoise shell Inlay Request: Replace tortoise shell Inlay where it Is pieced or flaking and delaminatIng. Status: Will be completed week of March 22-26. Tortoise shell for repair 619(11— Punch List — Item #7 EFTA00308289 MOLYNEUX STUDIO LTD. Vertica ar top, ml.d a new anal bottom fastener. New middle ring fastener (back of door). New middle ring (above shell handle) Installed. Request: Repair cabinet door hardware so screw does not loosen when handle Is rotated to operate the door and so rattle Is eliminated. Status: Complete. A third metal ring was Installed on metal vertical bar to act as third fastener, eliminating rattle. Hardware tightened. 0190? - Punch List — Item #8 9 EFTA00308290 JP MOLYNEUX STUDIO LTD. Mw Ara ••.0 "A. .1? %to • • nes1.4. • •NJ- TMw tkos,te z ,& ?,. ;•:: ".: Request: Supply and Install two new turtle pulls. Status: Complete. 0.1901— Punch Lii4t — Item #9 10 EFTA00308291 JP MOLYNEUX STUDIO LTD. orAWAFATTOSivgavIA Ava iggallegeMYS Vfik WavATTV q !AT' War9 7 .4 )0%* • it ' l a. rt. Non-damaged bamboo grille. Damaged bamboo grille. Request Riplace bamboo mash at all cabinet dos* with metal mesh In a dark color that will not rust. Status: New metal grilles are not in agreement 'Fancelli has repaired damaged grilles and will provide 8 new framed grilles for future use. 01901 — Punch List — Item #10 ••••••••••••616 • • Damaged bamboo grille. ll EFTA00308292 -P MOLYNEUX STUDIO LTD. 4. • e r.a The blackboard works —tested on site. • . Appropriate chalk to use. The blackboard works-tested on site. is The blac board works — teste on site. Request: Replace the non-functioning blackboards with slate that will take chalk. Existing surface does not take chalk satisfactorily. Status: Replacement of blackboard material is not in agreement. Chalk works on existing chalk. Crayo!a chalk not recommended. 01901— Punch List — Item #11 12 EFTA00308293 light bulbs Inside cabinet shelf. JP MOLYNEUX STUDIO LTD. I- LI ht bulbs inside cabinet shelf CM'S': — l*P Request: Provide additional light bulbs for the shelf lights Inside the cabinets and provide the specifications. Status: Fa ncelli 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 13 EFTA00308294 JP MOLYNEUX STUDIO LTD_ Request: Confirm the size of the carpet and provRie under— padding. Status: Carpet padding Is not In the agreement. 01901-• Punch List — Item #13 t4 EFTA00308295 JP MOLYNEUX STUDIO LTD. Cornice light and dark. Request: The staining of the cornice should be like the Escorial library with light and dark. Status: Fancelli will stain the cornice with light and dark after the dehumidifier is Installed and the moisture content of wood is acceptable. 019 01 — Punch List — Item #14 15 EFTA00308296 Highlig ted carvings. JP MOLYNEUX STUDIO LTD. Highlighted carvings - sample finishes, not final. Request: The staining of the columns should highlightthe carvings with light and dark. Status: Fa ncelli will stain the columns after the dehumidifier is Installed and the moisture content of wood Is acceptable. 01901 — Purieb List — Item #15 16 EFTA00308297 Approved and signed finish (at left). JP MOLYNEUX STUDIO LTD. CL771PRfaSTIFIGeg: • -;.,•:-.721,At.,...Ft-g 1:ft. • 7it, ire at i I) , et ire -n h., • ,e, „....,„ A$4. e-s2ultal'g4T-ti ,, "" i't • .<4,74,4.,.- .c..,,fic-, -.,,...&4,,its.+44:3...4.4/..t...4..,/. ..inavi.t.. nis Approve• a n• s gne• Request; All wood surfaces In the room are to be finished: Currently, the undersides of the desk tops are unfinished. Status: Fancelli will stain all wood surfaces after the dehumidifier Is installed and the moisture content of wood Is acceptable. 01901 - Punch List — item #16 17 EFTA00308298 JP MOLYNEUX STUDIO LTD. 4•,4•90.31a: • - : •1 4. 1;417tIr Two finish options within cabinet. 717 TWo finish options within cabinet. Request Interiors of the cabinets are to be stained darker so as not to appear orange when the shelf lights are on. Status: TWo alternatefinishes have been produced on site. JPM and Gary Kerney do not recommend changing the interior finish. H. ONO - Punch List — Item #17 18 EFTA00308299 MOLYNE'UX STUDIO LTD. Approved and signed finish. Approved an• signed nIs Request: All wood sudaFes are to be varnished. --- Status: Fancelll wT gain all wood surfaces after the dehumidifier Is installed and after the moisture content in the wood Is acceptable. 01901 — Punch List — Item #18 19 EFTA00308300 MOLYNEUX STUDIO LTD. Shutters. Shutters. • Rejected leather for shutter Insert. Request: The sliding panels are unfinished plywood. How are they to be finished? Status: Not In agreement 01901 •- Punch List — Item #19 20 EFTA00308301 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 1. Plaintiff Juan Pablo Molyneux is a citizen of the State of New York. 2. 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 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). D s-al D[ .\ \yr< 3 1 —iFseile112--, .1-P EFTA00308302 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.On 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 1 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. 2 EFTA00308303 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 agetit 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. 3 EFTA00308304 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; 4 EFTA00308305 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 fiirther relief as the Court deems equitable and just. Respectfully Submitted, Rosh D. Alger Esquire, LLC Attorneys 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 5 EFTA00308306 Case: 3:10-ct-00034 -CVG - RM Document #: 8-1 Filed: 06/11/10 Page 1 of 1 RI/S44 guy NO.) CIVIL COVER. SHEET TaJS 44 ti-4 Cato am sza Or inf.:ntal conaned herein neither replaa nor suppiesent the Alin/ trod orrice ofpkodias or Ma Mars /4~try Im mat providocE by (cal Ma of met. Ilia 10441/4 IISPNOVOdby Confenna of she VMS Shin in Saambool 974. is requital la Ne use of On CktE el' Carl for Itt porascol Mating Fie Mil data Met (3111, 41100410144144 THE REVERSE OF THE Wan) I. (a) PLAINTIFFS DEFENDANTS M0lyneux Studio, Ltd. and Juan Pablo Molyneux Jeffrey Epstein and LSJ , Lt.c (b) cow« Itedemea aria tas wont New York. NY I County etReakkret «First Liked Cecikrtdant senor:0.15,w ~Taus PLAINTIST CASES) ON U.S. PLROMFF CASES 0/41.Y) MOM R4 LARD CCIRDEMNA TEN CASES. VS E THE LOCETb3)4 OF THE LAND INVOLVED. (c) Afloat(' Warty... I US. Ttkptsc ebaréct) Rosh D. Alger. Esq, PUB 10 Royal Dane Mall Sea IL HASS OP JURISDICTION "ark one thm oriyi O1 O2 Osawast 0 3 hard Qarogot Maktit (U.& CetVITTPOSIC Not hazy) us paknaad 044•14•4 0 4 DA.07;0 (Wks Camas of P.m lo Ism D1) Ancerneys utraemd Denise M. Francois, Esq., Hodge tt Francois, in. CI Irk Car Onko PPP DU O 1 01 Otas ofTaits Cron orAnecher Sun Mew eor Skink af • Fkittrereetwo 02 O 2 4404.4 lee Ay Pelf esdOse y ke 0~41 PIT DU 444'eperned Er hindod he* 0 4 Oa of Ileeinna be WE Sta 31~.a •,..ffirinc4•1 kwa et Basked tre Analcr Sute O 1 0 3 114~14•11141 5 .0 1 IV. NATURE OFT SMT Nknaye-kh.Kadd.1 Tons O 110 Ineronoo O /20 14kin O 130 Mkt Act O 14014agalkio O 150 Rec~0.4~ Fateramow «Merck O 151 Medlar Ace 0 131Itearray ofD4Fsked Roam tam (PM Yuma) O 153 PaPPIPPJ dOnrperscot a Vanes Papa ( )160 3e~ 34144 • . 150 Ober Cana 195 Coon< Prtdoel Elk», 0 196 Fradir L RUL mortal O 210 Lad CeRdcwasen O 220 Pncloorn 0 230 Rem Lea et tram 0 240 Tole 14 lad O 245 Ton Proket ~Sly O 290 M Diatitod ho)e" PERSONAL POUR? O 3I0 Aktitat O ns mram. Rama O LIS» 120 Axe" tad tt Oaks O DO Feder:~ WSW O 344 USE O MI /4.ekehothR Vag O 324 Mow Vde4de O O5 Men YdVele hale~ O 344 Mot Pam( Way CTYt4R.OMa O 441 Webs • O 40 Dnployeart IO 41.18~4.44 Aossrosa CI 444 1441Se O 40 Arat wirDimbakiee • D•Phrs444 0 400a 44124546144. CA« o 440 01~041~ PERSONAL INJURY O 362 Pt:~ Wry - Med. 404proete O 345 Perm Wory • Uday O 361 Attain Pawl >jay hodijk Lisbilky PERSONAL PROPERTY O 370 Oita read O 37/ Teak 44 imam O 3100304 hems, Prneeyr4444~ O SO Papa, ~tope Tediset Lab0ity PRISOPHER PETTTIOP3 510Medeab Vuur Swam &boas Corpen 150 Omni 333 Otate Pardo 540 1.4444ows .4t 05.4. 550 Cir3 Pad. 555 Maa Ceno46c4 Env« LTT O Ws M:toba O CO ~FM Doss 0 475 Doc RAS Wave •1~21 (ACM a es Li4Pat Ian n 4$014.± Tod O I» Aides Rep a HO 0topelked 34f- O 03 Oeto 1.610OR O III hi laberaolarie Aa a 7» 1.4~1tRodor O 734LotoMpaRepres k Oktic..4444 O He R443417Lebe Act O 790 Oda Leber Wpcies O 791 cam Rabe • Sotoas Au OAR lodirierf 0433 Anal» WC 1St 0 C3 141chdreved 21 WC 152 PROPERTY 10111-8 Coprleks O ISO 'wet O 410 Tredornple noes* i.ssysotar 516; saa 03950) 0 K2 1114.4 tag (nl) 0 BO DINC/DMIV(4413(0) 0 la WWII& XVI 0 1413.1t1405M1 57.2~ TAX turrs O 470 T4444 ors. nuts *r O hay 26 WC WI ~ STAMPS 0. 400 544« 11.444404~ O /10 Mane O 00 Win opattne O 00 Cement . O eifloprosea 4101seltea }anted Ernie 0.4~4444 a 410Cormer CHM O 00 Cdokrad TV O 1103~ 54.44 A4 O tO0Amedetke 0.1.110“6.1 tka" twijesa Work» O 15410/Siak Suns. VI- CAUSE OP ACTION W atl yicio of mesa Judgment ~tell* District V. ORIGIN Inman -x• be Or be Daly) tg ( or;cris O2 Reniond Dam 03 lamamad Gm( O 4 Reitatted or 0 3 T4110011T ardrand0O14141 4" "lie IS Licirm S2 ion Proceed:4w Sae coun Aimeatte Court Reamed a 7 mk4=4.4°4. hikonea 91/ ifyikirándir which yam Nita (Do at at ItradIc("cri ttojr !Nato mans ~It» ID VII. REQUESTED IN COMPLAINT: Yu/. RELATED CASE(S) Olat IF IRIS IS A CLASS ACTION DEMAND S UNDER F.R.C.P. 23 CHECK YES My ifdteranded LiRyldnt JURY DEMAND: - a Yes cati. (in kansilent> IF ANY RIDGE DOOM,' NVMDISI OATS 06/1.1/2010 S/ONATUAR OF ATTORNEY Of RECORD s/Rash D. Alger PO* Olrg.c uSs aus RECOPY I ?MOUNT Arrtvihro 31./DOE NI332 EFTA00308307 . Case: 3:10-cv-O0034-CVG-RM Document #: 8-2 Filed: 06/11/10 Page 1 of 6 THIS AGREEMENT, entered into this 15th day of May, 2009, by and among Juan Pablo Moiyneux ("JP"), Molyneux Studio, Ltd. ("Studio", and together with JP,Nolyneux,") LS.J., LLC ('LSJ") and Jeffrey Epstein (`Epstein"). WHEREAS, disputes have arisen between Molyneux, cm the one hand, and 135 and Epstein, on the other hand, relating to payments and deliverables in connection with design and related services by Molyneux for LSJ and/or Epstein with respect to Little St. James Island and other properties beneficially owned by Epstein (the 'Disputes"); and WHEREAS, the parties hereto desire to settle all Disputes as provided In this Agreement; NOW, THEREFORE, in consideration of the foregoing premises and the mutual agreements, promises and other provisions contained herein, JP, Studio, LSJ 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 (51,200,000) 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 SettlernentAgreernent, and shall not be treated as an inducement to the execution of the Settlement Agreement. 3. (a) Epstein and 131 and each of their successors, assigns, heirs, executors and administrators (collectively, the 'Epstein Releasors") hereby fully and irrevocably release each of JP and Sttidio, and each of their successors, assigns, principals, heirs, executors, and administrators (collectively, the "Molyneux 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, 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 EFTA00308308 Case: 3:10-cv-00034-CVG-RM Document #: 8-2 Filed: 06/11/10 Page 2 of 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 Moly-neux 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 LS), and each of their successors, assigns, principals, heirs, executors, and administrators (collectively, the "Epstein Releasees"), of and from any and all manner of claim's, 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 unaccrtied, apparent or not apparent, foreseen or unforeseen, matured 6r 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 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 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 entering into this Agreement for the purpose of settling certain disputes between them and to avoid furthet expense with respect to those disputes. 5. The Parties agree that the existence, terms, and consideration paid pursuant to this Agreement are strictly confidential and that this Agreement will not be filed in any court, except in proceedings to enforce this Agreement or the Design Services Agreement. No Party may reveal any facts about this Agreement or the terms of this settlement 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, 2 EFTA00308309 Case: 3:10-cv-00034-CVG-RM Document ft: 8-2 Filed: 06/11/10 Page 3 of 6 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 (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 tents of this confidentiality provision and shall take reasonable measures to ensure that the receiving party agrees not to make further disclosures 6f the requested information. M least five business days prior to disclosing any facts about the settlemau under provisos (iii) or (v) above (other than in connection with proceedings to enforce the provisions of this Agreement or the Design Services Agreement), to the extent permissible by law, regulation, rule of 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 disclosure 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 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 indiiiduals are signing hereby 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 . the claims to be released in paragraphs 3(a) and 3 (b) to any other person or entity, norshall they hereafter do so. 9. Each Party agrees that this Agreement shall be binding upon the heirs, successors, and assigns of each Party. 10. Each Patty represents and agrees that such Party: (I) 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 understands the terms of this Agreement and has entered Into this Agreement voluntarily without any coercion or duress on the part of any person or entity; and (iii) was 3 EFTA00308310 Case: 3:10-cv-00034-CVG-RM Document 8-2 Filed: 06/11/10 Page 4 of 6 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 counterpa rts, 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. 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 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 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 notice of any change of person to be notified or change of address is forwarded to all Parties: (a) For Epstein and LSI: Darren K Indyke, Esq. (b) For JP and Studio: Jay Goldberg, Esq. IMP 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. 4 EFTA00308311 Case: 3:10-cv-00034-CVG-RM Document #: 8-2 Filed: 06/11/10 Page 5 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 hereof shall be effective service of process for any action, suit or proceeding brought In any such court. Each . Party irrevocably' and' oraitTdifii5billflahierany Objection to the laying of venue of any such suit, action or proceeding brought in 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 besenforced In any other courts to whose jurisdiction such Party is or maybe subject, by suit upon judgment • 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, as of the date of the day and year first above-written. J.P. MOLYNEIDC STUDIO, LTD. it ) By: JEFFREY EPSTEIN L.SJ., LLC By: JEFFREY EPSTEIN. Member EFTA00308312 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 hereof shall be effective service of process for any action, suit or proceeding brought in any such --court-• Each Party-irrevocably-and-onconditIonally- waives—any-abfectIOn- VS the laying of venue of any such suit, action or. proceeding brought in any such court and any daira 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 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 be executed by themselves or their duly authorized representatives, as the case may be, is of the date of the day and year first above-written. J.P. MOLYNEUX STUDIO. LTD. By: Juan Pablo Molyneux President JUAN PABLO MOLYNEUX LSJ, Lie Member S EFTA00308313 Case: a:10-cv-00034-CVG-RM Document it 8-3 filed: 06/11/10 Page 1 of 8 AGREEMENT FOR DFSiGN SERVICES Tills AGREEMENT FOR DESIGN SERVICES, is entered into this 15th day of May, 2009, by and among Juan Pablo Molyneux ("JP"), J.P. Molyneux Studio, Ltd. ("Studio', and together with JP, "Molyneux,") L.S.J., LLC ("LSI") and JeffLeLEpstein ("Epstein"-)r _Each-of-the-partter hereto ((the 'Pardee), intending to be bound hereby, hereby agrees as follows; 1. Upon execution of this Agreement by the parties hereto, in return for good, valuable and sufficient consideration, Molyneux shall credit Epstein's account with Studio In the amount of Two Hundred Fifty Thousand Dollars (5250,000) (the *Credit') to be applied against future services provided by, and out of pocket disbursements and expenses incurred by, Studio, to and for the benefit of Epstein and/or LSJ, as determined by Epstein in his reasonable discretion (the "Covered Service?). 2. With respect to actual services rendered as part of the Cohered Services, Studio shall bill Epstein and apply such billiagainst the Credit at a rate equal to Five Hundred Dollars (5500) per hour for services rendered by JP and Eighty Dollars ($80) per hour for Studio staff. 3. Without in any way limiting the foregoing, the Covered Services shall Include those services, disbursements and/or expenses reasonably determined by Epstein to be necessary or appropriate to complete the design, construction, and exterior and interior design and decoration, including furniture and furnishings, of the office pavilion currently under construction on Little St. James Island (the "Office Pavilion"), and will further Include provision of the skilled labor and supervision, and the payment of all expenses and disbursements in connection therewith, necessary for the proper installation, restaining and refinishing of the cabinetry already delivered to Little St. James byAtelier Fanceill. .4. Notwithstanding the provisions of Section 3 hereof, the parties acknowledge that the labor charges for the installation of such cabinetry 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 Molyneuxwithout application of the Credit against the same. 5. It is a material term of this agreement that as pan of the.Covered Services Molyneux shall furnish and cause to be properly installed and completed at the Office Pavilion by January 2, 2020 all of the items listed on Exhibit hereto and that the Office Pavilion will be completed to Epstein's reasonable satisfaction by January 1, 2010, Molyneux agrees that the' aggregate amount to be applied against the Credit for the provision, installation and completion of all such items shall riot exceed the amount of the Credit and that neither Epstein nor LS) shall have any liability to make any payment to Molyneux in respect of any such items. EFTA00308314 Case: 3:10-cv-00034-CVG-RM Document #: 8-3 Filed: 06/11/10 Page 2 of 6. in the event that by the fifth anniversary of the date that this Agreement Is executed by all of the parties hereto, Studio shall not have provided Covered 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 an account designated in writing by Epstein to Molyneux (the "Designated Account") tendays-priortSfiftlfMnIversary date. In die event that Molyneux Is deemed in breath of this Agreement in accordance with the provisions of Section 8 hereof, then, effective as of the date that Molyneux Is in breath under Section 8 hereof, the 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 transfer to the Designated Account specified in such demand. (-) 7. In the event that• Molyneux should breath 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 a 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 S250,000 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 Is 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 dreumstances, the amount of these liquidated damages Is fair and reasonable. 9. JP. states that neither he nor Studio is an architect and have not held themselves out as same regarding the services to be rendered under this Agreement Further, Epstein and ISJ 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 the-provision 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. 11. 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 2 EFTA00308315 Case: 3:10-cv-00034-CVG-RM Document ft 8-3 Filed: 06/11/10 Page 3 of 8 hereof will not be construed for or against any such Party as the principal drafter of this Agreement. 12. The individuals signing this Agreement and the Parties on whoSe behalf such individuals are signing hereby represent and warrant that they are empowered and authorized to sign on behalf of and bind the Parties for: whom they have signed. 13. . Each Party agrees that this Agreement shall be binding upon the heirs, successors, and assigns of each Party. 14, Each Party represents and agrees that such Party: (I) 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 understands the terms of this Agreement and has entered into this Agreement voluntarily without any coercion or duress on the part of any person or entity; and (Ili) was given adequate time to 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 sa me instrument Signatures of this Agreement transmitted by fax shall have the same effect as original signatures 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. 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 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. 17. Any demands, 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 notice of any change of person to be notified or change of address is forwarded to all Parties: (a) For Epstein and IA: Darren K. Ind ce Es 3 EFTA00308316 Case: 3:10-cv-00034-CVG-RM Document 4: 8-3 Filed: 06/11/10 Page 4 of 8 ( (b) For JP 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 ;mks. 19. 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 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 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 other courts to whose jurisdiction such Party Is or may be subject by suit upon judgment 20. The Parties agree'that the existence, terms, and consideration paid pursuant to this Agreement are strictly couGdential and that This Agreement will not be filed in arty 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 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 disclocing any facts about the settlement under provisos (i) or (ii) above, the party making the disclosurd 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 than in connection with proceedings to enforce the provisions of this Agreement or the Design Services Agreement), to the extent permissible by law, regulation, rule of 4 EFTA00308317 Case: 3:10-cv-00034-CVG-RM Document #: 8-3 Filed: 06/11/10 Page 5 of 8 a court or court agency or court order, the Party making or asked to make the disclosure shall Inform each of the other Partite of the proposed disclosure or request for information, and shall, at the request of any Party and a tthe cost of such requesting Party, file any disclosure or response to the request for information about the•setilement 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 seaL IN WITNESS WHEREOF, theparties hereto have caused 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, LID. By: Juan Pablo Molyneux President JUAN PABLO MOLYNOUX Member 5 EFTA00308318 Case: 3:10-cv-00034-CVG-RM Document #: 8-3 Filed: 06/11/10 Page 6 of 8 I 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 disclosure or request for information, and shall, at the request of any Party and at the cost of such requesting Party, Me 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 mused 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. MOLYNEITX STUDIO, LTD. •By: Juan Pablo Molyneux Pres • LO MOLYNEUX JEFFREY P.PSTEIN L.$.1.,LLC By: JEFFREY EPSTEIN Member EFTA00308319 Case: 3:10-cv-00034-CW-ITNIbifor ernent #: 83 Filed: 06/11/10(1PagerlQuisfenrit MOL,N1 %.4 t33C 71 06 29 FAST 69 I k STIZEI-rT Vi‘‘ rortu.yan yew); icon no 0i:I 6.3IXDO pm JON 737 ea 11. 4D IN il^4 Pnl,RellTaSI Fill ale. VENDOR: ARCHITECTURAL INSIt/RS k DECORATION FANCELU PANELING 4 Rut:: C11, P()N -RDA P ARM FRANI no I It. too /4 ono.; on • o• I in oil 44 YJ De 44 in no pro.. Deal, DruweaKe 10/14/2008 2124354537 212-9354538 Fax A•LI MIN N.% Inhunin . nsscrturnot; UNIT ORWE EWE-NINO) Can Woodworking FABRICATION & NSTALLATION of light oak with waxed fioishtabinetry per JPM design. Will include survey, shop drawings, moldings of bate, lower cabintcry with doors and upper bookshelves 3 hidden cabinet doors sod atcrior window shutter columns with bases and crown. Will include packing insurance and waterprottcontainer to St. thomas and crew travel. Cost will not inclade 2 globes, fiat base (stone) trinspaudon of goods to St. James, scaffolding, local rues. customer or workman's accomodatioas NOTE: THIS PO REPLACES P092680 Deposit Required: S Payments: S 780,000.00 Account I: Terms: 100% Deposit 730,000.00 780,000.00 • 0.00 TMakS 780,000.00 MI NOT PROMS TOO DOIDIX IINLESS SPIU3P/C*Alli /KS AM) ENLICT ARK CRIPAREr auxuasfilvl / LSI-OFFICE / OFFICE/ EURO: [SY-OFFICE OFFICE . WPM AMU .... ATELIER FANCF7 T 63 RUE ALBERT DMILENNE DAIL PROAILNIOi ixoNT3T Dui i Tamen IR ORDRII ..1 'WIRD Valet >Dna ta ikn :IN% MO. RI i a IITIDID1 Ot it cotagsSOMDta V'It.\IIon EIMI RACIORT, IS II Et 1K1Ort I RP 1 lib lilt U. SOYAR voil lie • mei PIP IF Non rail- 7 u DOI R VI ions MOO VORDDCD'S t TDOPLNIA DUN I' RAM I De • I AM UM% CV. RESAI.K / 114104128 • nonnew. o: Inc 9 .1 MINOS RV: 29764 . 31 TUMOR OCDRIGNA Et 'KR EFTA00308320 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 refer to Juan Pablo Moiyneux and the words "you" and "your" shall refer to Jeffrey Epstein. I propose to include all of the following services and items for the $250,000 that we have agreed: The Office/ library: Fancelli will complete the installation at no cost to you. This means that you will not be responsible for any Fancelli Installer expenses including travel, lodging, food, incidentals, etc. After Fancelli finishes the Installation., I will decide if the color of the paneling is adequate for the overall ambiance. If It Is not, I will select color with your approval and restain and refinish cabinetry as part of the services I will provide and at no cost to you. The desk I will include will be a bronze contemporary' desk (Design JPM) with a modern swivel desk chair. I will also Include a guest desk chair and a desk set. The desk lamp I will include will also be contemporary. I 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, l will include four large scaled club chairs upholstered in a cut cotton velvet (Bevilacqua Fabric), two contemporary reading lights, a coffee table (Design 3PM) with a unique tiger coral parquetry top, a pair of contemporary Celestial and Terrestrial Globes (Design WM, from the movie by John Ford). I will provide with your approval the design (which includes selecting, but not purchasing the materials) for the floor of the structure. I 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. I will also provide lighting and ceiling design with your approval for the structure. I will provide the ceiling Painting which was previously ordered which I Will have delivered to St. Thomas and oversee the proper Installation of the same on the ceiling.) will provide back-up documentation to you for the prices and billable hours (at the rates in the Design Services Agreement) for the above Items and services and if the total amount falls short of $250,0W, I will provide other items at my reasonable discretion to complete the Office Pavilion so that the total amount equals $250,O00. will make two trips /visits to Little Saint James Island on dates determined by me in my reasonable discretion to be necessary or appropriate to oversee, perform and complete the above work. EFTA00308321