DS9 Document EFTA00758611

From: To: Jeffrey Epstein [email protected]> Subject: FW: Complaint aganst Date: Tue, 18 May 2010 02:20:09 +0000 Attachments: Summons.ZIP Forwarded Message From: Jeff Fuller < Date: Mon, 17 May 2010 15:36:01 -0400 To: Jeffrey Epstein <[email protected]>, Jeffrey Epstein <[email protected]> Cc: jeanluc brunel Subject: FW: Complaint aganst From: Sent: Sun ay, une , : To: SAME . 75Thrairarnst Dear Jeff: Sorry to hit you with so much reading material while you are supposed to be relaxing a bit, but here is the initial Complaint I have prepared, with the Summon and Lis Pendens. Later we will amend the Complaint to add some thing claims (such as the statutory action called "Civil Remedy for Theft" -- which provides for triple (3x) damages, but requires a demand to be sent to the Defendant and give 30 days to come up with the money/property taken). There are a lot of other considerations, including whether to bring 2 separate actions, one for the NY entity and one for Miami; how to deal with embezzlement committed before these MC2 (previously Karin) LLC entities existed (were the all of assets of the previous Karin companies assigned to the new Karin entities?). In any case, our short term goal is to get the case filed to create security against her house, and the specific allegations of the lawsuit can be changed later, and as more factual developments are uncovered. I'll call in the morning. Jonathan No virus found in this incoming message. Checked by AVG - www.avg.com Version: 8.5.437 / Virus Database: 271.1.1/2688 - Release Date: 05/17/10 06:26:00 End of Forwarded Message EFTA00758611