Case File
efta-efta01083960DOJ Data Set 9OtherDARREN IC INDYKE
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DOJ Data Set 9
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efta-efta01083960
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2
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DARREN IC INDYKE
Darren K. Indyke, PLLC
301 East 66th Street, 10B
New York, NY 10065
Telephone:
Telecopier:
email:
September 1, 2011
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Mr. Nick Lambros
Sound X
360 Northwest Highway
Barrington, IL 60010
Dear Mr. Lambros:
As you know, I represent Jeffrey Epstein and L.S.J., LLC. I am writing in
connection with claims they have against you regarding high-end, professional
audio-visual equipment and installation services you held yourself out as being able,
but failed, to provide.
You falsely held yourself out to Mr. Epstein and his representatives as being a
knowledgeable and experienced professional provider and installer of the highest
quality audio-visual equipment for large-scale, high-end applications. On the basis
of your misrepresentations, Mr. Epstein paid to fly you numerous times to his Island
in St. Thomas and his New York property to provide professional technical
purchasing and installation recommendations for several different sites at those
properties. Based on numerous misrepresentations you made to Mr. Epstein and
his representatives regarding your knowledge of and experience with particular
audio-visual equipment, you persuaded Mr. Epstein to pay you over $135,000 for
equipment that you had never previously purchased or installed or with which you
had no prior experience.
Your installation of this equipment was generally sloppy and unprofessional,
and in many instances improper, so that it did not operate as specified. This
required costly project delays and return trips to the properties to bring your work
into conformity with even minimal standards. Moreover, much of the equipment
that you recommended with the highest possible praise performs poorly and has
been subsequently discovered to be of substandard and inappropriate quality for its
intended high-end application. As a result, several pieces have not even been
installed in the multi-million dollar locations for which you recommended them.
EFTA01083960
Mr. Nick Lambros
Sound X
September 1, 2011
Page 2
Countless hours of costly and valuable time of Mr. Epstein and his paid
representatives have been expended to address the many issues created by the
deficiencies in your performance and equipment. To this day, not a single location
operates at the level of performance and quality that you lead Mr. Epstein to believe
it would. Yet, the total estimated cost to Mr. Epstein for payments to you, his
representatives, travel and numerous other expenses necessitated by your failings
exceeds well over $200,000.
All this being said, Mr. Epstein is seeking a resolution of this matter that will
avoid undue hardship on you, but at the same time provide him with some minimal
recompense for the costs he has incurred. He is willing to accept a one-time
payment of $35,000 to put the matter behind you. Considering the costs he has
already incurred and those he has yet to incur to correct your failures, this offer is
both generous and more than reasonable. Be advised, however, that should you fail
to accept Mr. Epstein's offer within ten days of the date of this letter, Mr. Epstein will
have no choice but to take more formal action against you to recover the full extent
of his damages, including but not limited to commencing legal action against you in
the Virgin Islands.
I await your prompt reply.
This letter is without prejudice to the rights and claims of Jeffrey Epstein and
L.S.J., LLC against Nick Lambros and Sound X, all of which are hereby expressly
reserved.
Sincerely,
Darren K Indyke
EFTA01083961
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