Case File
efta-efta01121316DOJ Data Set 9OtherNovember 4, 200$
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Unknown
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DOJ Data Set 9
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efta-efta01121316
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36
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0
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November 4, 200$
SITRICIS. AND COMPANY INC.
ttesucanss -Nate=
Roy Block Vag.
oar
Dear Roy:
This fl y, when Kann by you blow oa behalf of leflley Epsom (the •Clleati odd
accepted by Rink Srebniek, Kampen & Snout ('Attorsar), will constitute the unman
with mann to the coenemeal of Sinn And Company fee. a Calibraia amp:salon
CSItrIele) so =pone cooveunkatiors advisee. specialist and non-dmigrinted open
tanultam, with respect to any legal note Anton fa heridlioe br Cent n she following amts
and condemns:
1.
The Claw cad Ationey, eilicliee es of Celebn 21, 2005. have rotund Slide:etc
provide advice and antic relations saviors in cannon with legal have It k
kandlins.
2.
Sind will waive fa annoy ren.refundabk retsina of 540,000 o a °Inma,
menu& fn. hi Hat thereat; Company dud pay Shtick a noo-terendabk swain of
1,30.000 as a minimum, annual ft. Sitrack's ore chews nil be billed nano itt
retainer al the hourly rote range of $165
&mai:Igen :he parson poinsrms the
servitem paraptufuteuestisuituant time is billed st S55.00 ran hour. What the tatttinn
bas but applied slIshwl bac cbareu. additional time darns in any year will d billed
n interred and an rnyAble with's; navy days afta recant. Chats% an computed on a
portal-toponsl basis foe any trawal time for meetly held outside of Sinitic's *noes.
Tnc is billed by Shuck u ICLOCINCYCS Of oneiturst of ac how.
La addition, we custonsuily =ton a 'bans ke if we bellow we have performed
antes fora client which result in aignIfent benefits to the cunt beyond dose we
believe a Atonal public naltaions Orin could achieve. Obviously. we would sit don and
discus; en ouch proposed foe with you If in believe it is nomad. IS such be wind
be subject to your appnwel.
Please review.our trills each morn unto receipt. tf you On any question plow fed
free to call. However, urine you nuke tome pram to Shriek In wnting within twenty
days of receipt of the bill, it will be pretund you have no obeclioro to it end epee to
the reasonableness oldie bill.
3.
The Chat del reimburse Shriek Main meaty bye of invoice date fanny ad all at
of pocka con and Opeosea bound by Sitrick in centirolon with Its engoptment
11.0 ct..,,
....00 .,%wit.210
•Pst
Page 1
EFTA01121316
Scott KornSpeoSIAck,AL,_
aga 21
Normbos, 2005
UTRYCK AND COMPANY INC,
Ø9910/11:41
benonder, includin vridet lirdelim, hel enes, modem« tosti, bong (filliaCt
photocopy Matua and aha oal-of-pocket com and troendes. Reanbursabk east om
not appiied sgainy: tbc ideer and tydl bo lodled mamk/ by blirkit.
4.
Silrkk acknowledges thai Is seren bes pedal pnuent to this Irer no ment n
for the borefil
eken ed thart Anarney, w Clienrs oxel, gall oul be reptetble fo,
an le, emu or expeoses inetrred io cor.oectim tiribh Sades satt
5.
&hick AM Comprny's 'mango-lent Imentex my be termionted Weitber paily a, 30
din prior eden nOtiCe. All proviiiens of dyk eter Molns to the myntan of fcer end
aperturs and ioderelkodon vill eye any ter0/01100/1 or the enormt by eke
peny, All the provision of Ibit lotter ronexd la pirogrophs 4. 5. 6 and 7 avin amin
for a pxiod of bro yran following the dan of *ny termlintion of the ensaganeal by
either party.
6.
In do evrnl cny <eke of Siirlek, a my 1411e is tennind or remented lY parucipric or
remi& tentimony, demenonta or aber ealdonce in my nØn. 411Otralion CC other
poeten Malins dandy or inta:cc/ly. to oir enusoment. Enbet or rot mer
engagement hes been namnet dm Client Del pay Sarick for the te neon In
penning-kr and pulvret Mab parricipotion or testimony. nl Sinich thai mode
halling ran, and for my nona and tweas, Melodins Manen fm. inmotad in
cortmaxim Manet.
7.
.Obst ave to indemnify end bold tumlett Sittlek, irs Marcheenr offieers, duplo,
entployea ord asen (asch peb encity or peson bes tefund bre
'intleninIned
Panna, from and agning isny ed ell beses, eke ten
liabilitie cent and
experten fineludiny, ban r( liieixd to, rettvable romgys fe) exharry Indermified
Person any be teet to or blarr in reamodon wish the tenvien moderod by Stick to
Client and/ox Anomey. This nerrunnit stoll w oppy lo on adr kam ekons,
denn, liabiallied tons w trema of cay Indemnifi d Person dal ve Penny
determined lo have mule fen Sker: or sunt other ledentified Paros's rom
rulle« w ?MALI mienduer,
8.
Lut of tha pankt baeto alpen to kem this letter asmement, and tha termo end
Ixreot Melodin; biting natemeds and tie altars, artad)/ conftderahal
egot nnly se ny be necnlaiy to enforte 100 kror. Al communkations.
000100000cracc. ifilkumaYs ond a/riktigs been Sitrick edd Alme? Mall be dismad
to corathuit attorney we•prodain and 04icneme prated by tho nuomonlicat
pivdne. Esch of the parties egen not to solkit for et rployment, nor anploy. my
ernpinyte of dm ohm durhyr tbc prelins of Sitrickt engagement and fora pedal of hvo
yen Viceallor.
9.
An ave not old to Skria purtutint lo thIc Gafttlikti
within ten dop we duc Mall
ban eden at the nie of ler parant per onatur,. if action be oommenced to enfant *ny
2
040 Cennuy P
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A i).E. TT..<
90:67 :MY
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a) ”7.7.799
EFTA01121317
Scott Kom,s2an • RRItleck.ady
sumac AND COMPANY INC
ta MLF ty taYtaot
November 4, 2005
proviricui of Ibis Mier agreement, the enviable pony shell be emitkd lo reasonable
inorney feu. My COnIZOW rry, claim or dispute rebuke no Ibis loner nerecixar Abell bo
resolved by binding re-bin-a:ion io anon:knee with the rules of the Ammad Arbitration
Association pursuant w an arbitration randkind in Lai Angeles Comfy, CallfOrMå
lodgment upon such arbitration may be catered in any cowl avios jutadicuss Kato(
This lame ngrttment daft be interpreted and cgisi ix/1 in men/ante with the substannve
brae of the State of Callihan' aggitatde to nelniets urode =Hobe pertonned Merck.
Arced to add accepted this
"
&ri d
Pitivfot6er
"Moony"
Very Holy your.
brick
ulk
Clubman mad Oder Davin Officer
COessolloChest
Stya ,P444 Kuv..„ 4~±5 el.4-0 ;^)
Piefrker •P' 0. leak, tich n. €44-, IC 4.4srps-.
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EFTA01121318
[Scott Korptipan - RoyBlack.pdf
_ Page 41
Nomabor 1, 2005
MYRICK AND CQMPANY INC.
Ia AMBIT • /111 /
Hoy Black, krq
Black, Srebneck. Korn:pan& Stumpf
201 3. Blicayne B1, 8:300
Muted. 01. 33/31
Re:
/slimy Ectrusio
INVOICE
Helaine, for me period beginning:
TOTAL DUE
-035.000.00
Plaue win wand« Runde io:
CITY NATIONAL BANK
CREDIT ACCOUNT OP: &TUG( AND COMPANY
ABA ROUTING NO.: 122 016 066
CREDIT ACCOUNT NO.t 112204510
ATTN: DAVE NATHAN
or
Plow mnkc check ~No la
STUCK AND COMPANY INC.
IMO ~Hy Pork FAN. Sake 800
4
II* Croy
IOU • Leta Am*. CA t
).110.
14:« pie) ?S9»
EFTA01121319
From. Darren Indyke
Subject: Confidential
Date: March 7,
•"
To: Mike Sitrick
At JE's request I am forwarding contact info from he forowing reporters who have contacted Jeffrey's Lawyer's over the past few weeks:
1.
Sharon Churcher (NY office of the Mail) contacted Jeffrey's attorneys leaving Ihe lollowing contact info:
PhoneNumber
email:
Jeffrey's lawyers also received a call from Anna Witheridge of the NY office of the London Mail. I am obtaining her contact into as well and wilt
forward that to you as soon as I gel it.
2
Both Jon Swaine and Neal Tweedie from the Daily Telegraph of London also called Jeffrey's awyers.
Jon Swarm appears to be from the NY Office. The contact into Swain° loft was:
The Daily Telegraph of London
584 Broadway 0601. New York,
NY 10012.5243
email.
Mobile
Oltice
Neal Tweedle left only a London tetephone No •
3
Daniel Foggo from the Sunday Times in England also contacted Jeffrey's attorneys leaving the following contact into
Telephone Nos.:
I whi fc•warrt to yrs: additional reporter contact trio as I gel it
Please confirm receipt. Thanks.
Darren K. Indyke
Darren K. Indyke, PLLC
301 East 66th Street, 10B
Now York, New York 10065
•••••••••••••••••••••••••••*****
nor*
***tun
-us ones *Ire
Mtr IM111MIM• MS •
The information contained in this communication is confidential, may be attorney-client
privileged, and is intended only for the use of the addressee. It is the property of
EFTA01121320
Vail VII IN. InUyR 's. rt_Lu. VIIdVOlV11LVU UbV, LII*4.4VbUltl VI IAJWyllIti VI Ullb
or any part thereof is strictly prohibited and may be unlawful. If you have received this
communication in error, please notify us iur■Ilbdately by return e-mail, and destroy this
communication and all copies thereof, including all attachments.
Copyright of Darren K. Indyke, PLLC - @ 2011 Dan-en K.
Indyke, PLLC — All rights reserved.
....
. en NMI. • I tent
en***
*****
***tin*
.M.«.......
EFTA01121321
From Darren Indyk
Subject Re: Confident)
Date March B, 2011 at 8:56 AM
To Mike Sitrick
Here is Witheridge info as promised:
Annette Witheridge:
Remember, she is from the NY office of the Mail.
Darren
On Mar 7, 2011, at 10:51 PM, 'Mice Bartok
Thank you
ote:
EFTA01121322
From: 1.1.ke
Subleci RE; E
teller
Dole: May 11, 2011 1:50748 PM EDT
To: Darin Inelyse <mosso fleacorra
Cc. Jetty Epstein <jeevacagoneilgenal.corn>
Darren
The engagemen: lens I sent co March MI lame same as the one Roy
Sleek area In 2005 as beer or Jellrey, urn the excepmen el re
roles (M4X11 MVO C1101900) and me wryer Deena Jay LigkOWIth (e1
-,etreys request) That 2005 teller erd anew:rent was never
laminated I em ens entratng sexier he *roc engagement leaer will.
tie rote weaken. CAA X souk, be Telpti I you could tee we eny
you tank ‘shy the Wei you reviewed IS uneaten-4CM rd Vaal Is
uneccepable Coal I.
Mae
—Orin Alcamo.—
rran: Damn Wyse
Sot rnlay. Mq 06, 2u1 I
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ASA
To bake Steck
Cc Miley 4111111
&elect Engagement Leber
I have $dl maid your en2agernem tenet axle's trateceptaa
MAIM K Inclyke
Darren
adylle.PLLC
a01 Ea fah Si,.,, too
Newt 0
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Meet
Fes:
OXII
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The euomunkn centered m tie oannturealbon Is conrdentlek may be
allornerelenl
refined. one le Mended arty for the use of the addressee. h Is U.S
WCOMIY ol
Darren K erdyke. PU.0 UneulhOnte0 use. Olselems• or cooing et Hs
commun.:aeon
a any pert thereof Is seta y peat ted and may be oriel/At II you
have received els
conenuitteOcntn error, pease early us Immo leery by 'than ern*
sit destroy ids
commurbaslas ern
copies ewe* Irate. Y anactenenta
Ospyilottel Doren KAMA,. el.L.0 - (e) 2011 Darren K
Wyk', PISC • Al tights moved.
...............
••••••••••
44444 Fee••••••••••••••••••••••••••••••
EFTA01121323
From: Ma Sleek
SoOket RE: Canll0n
Cult June 2. 2011 9: 15 PM DT
To: Darren indyts
agitated beta ta ~owner< /Baer I sent Jay ern Jay ran: you -s
our stamen, engagement letter. kW manly the same !ever as the
one sewn was WOCUted tn 2005vels Roy '3, a;:c. nth o1O exospdon rut
the billing mica al oxen have changed Over sto pew an yews
NYi respell to yr.: role, goo fee fame Is stead In the engagement
leder: horn SI 85 en haw tar assecto tam $895 an hour torros rya
win a egredule or van tals at what (O. *fowl te racy to proeide
I. Meta our ohnetnna Ill as the later stales to provide
console; adVIOB and public relearns ~Ian.
*Mich ounces are
Warded to Wane Toga *dew being gran ba Company and plodded
by AttOtney.' I ward JeWey N he wanted telo operave MOW 210 old
loner bal will ow new lees and he said ha pre:fired lard Na new
laser lo Jay, Meld. I die
Aa you way I» ream, Jeffrey called me out re Me blue. asked fee my
Rep On Ole malts we I dropped eveinhing ~jumped n. Iced not
wag-as we ueualy do-ta get a signed Ongagemern bider rd
reamer because (a) we had vented cotta balas and Memo did not
allow a FlaTitge aces was WIN% when Jetty called and Marla
argon win required.
I have Flotta If hens we be yet mother wave restating From an
plant" ~yea (It I wen 60vinep Oxen - with of muse I an not
- lensed nave 01a gult Cr: Nlotrine, 00 /Mules (when n reptre fro
In fa tie Today Snow or ellatey« /40petully: any won't go that
Ir )
Rtgarreesa a la starer teen Jeffrey Omni went to men the
lottor. 1 maid ifk bat he just WOO= M Invokes we have sent for
walk ve have don. One of en meln urposes Mahe letter • as I know
you are aware - Is to ~kb
insim the protect:as of °Milano tor
ourcommatellm
nook Conned to hearing korn you soon
Best regards.
Mss
Original Menage--
From: Darren entail j
Solt Tandsy. May Si.
Ter MIS Seek
Staid . Conederdel
I just seamed Iron vacation and will get back to you win oornreenis
One endel the week In gene's! boart. there la no detail whatsoever
In the ergs ornat Mar, inch4ng but ra uneed to detail re rm.
approvals or otligaikna and U.S Is ant for stain
Curren K tclyire
Curren K My**. PLLC
301 East Nth Einel. 100
New rak
•
•
Fax:
mat
.
.
.
.
.
.
.
.
.
.
.
.
.
.
P ia Information contained In ash cominatmeon b wade neat may oa
albomey-disnt
pewieged. sid Is Intended only for the use of the addressee. It es the
Progeny°,
Darren K belyke. PUG Unnenorlzed use, dallotus or coping re thle
a
Cernmunkeden
sty pal ~pot ts *logy prceibited and may be unlawful
you
have weaved CM
cornmunkadas n error, please notify U5 Mellansly by taken amen
EFTA01121324
and 6141rOy 145
commultaiion ard ell cop45 threat Including all anathinents
Copyright ol Damn K
PU.0 • (e) 2011 Doren K
Indyke. RIC • Al tights ressived
EFTA01121325
From. Mee SiWO
Subject: RE: PRIVILEGED Attorney Client COmmunIcatIon • NY Thee art:e on D 01Y
Dale: .Mn 5.2011 1
Cc:
Roy
BlaM
Wart:erg rah
inerfa a.
Jay Lerma
Co:
vuy
Java° Pair.,
eitaschMentS.54.5KII
The attached article which was on the front page of the Style section of today's NY Times. Fortunately, the reporter - whom I know but d'd not speak with
about this story -Ignored what Sarah said in the UK and Jost treated her association wth Jeffrey in brief passing —and not by name.
Mike
.ta-seth .21 NVIIreencm
nett:, flork gimeis
Fashion & Style
•
Saving Sarah From Herself, Oprah Style
Garr Ou,04 ale Pry-Ina
, ••• haskthal P. Ss
ODYSSEY Frac Seth; a sa•pan aocureseery abaal Semh Fe/9,
e minsfonneloo
NI Liven on Dow Wekvis neck
By LeaLLICLEN
runes Ansa 2011
CHICAGO
Related
Times TsPie:SaltikZE:11120
fddrittlattac
EFTA01121326
HENNIGAN DORMAINT LLP
LAWYERS
865 SOI,TH FIGUEROA STREET
SURE 2900
LOS ANGELES, CALIFORNIA 90017
TELEPHONE
FACSIMILE 273 694.1234
Mater PHONZIM
[email protected]
July 12,2011
VIA EMAIL
Mr. Roy Black
Black, Srebnick, Komspan & Stumpf
201 S. Biscayne Blvd.
Suite 1300
Miami, FL 33131
Dear Roy and Jay:
Mr. Jay Lcflcowitz
Kirkland & Ellis LLP
601 Lexington Avenue
Our firm represents Sitrick And Company.
In early March of this year, your client Jeffrey Epstein called Michael Sitrick to ask for
his and his firm's help in stemming a tsunami of negative publicity resulting from a photograph
of Prince Andrew and Mr. Epstein walking in Central Park. The focus of the publicity, as you
are aware, was that Prince Andrew was friends with Mr. Epstein who the British press called a
pedophile. Mr. Epstein said this was not only disturbing, but threatening the viability of his
business.
At the onset of this engagement, Mr. Sitrick asked if he should have Black Srebnick sign
a new engagement letter. As you know, the Black Srebnick firm signed the 2005 letter (which
by the way was never terminated and therefore is still in effect). Mr. Epstein responded that the
letter should be sent to Jay Lefkowitz of Kirkland & Ellis. On March 11, Mr. Sitrick sent
Mr. Lefkowitz a copy of Sitrick And Company's standard engagement letter.
Given the urgency of the situation and his prior relationship with Mr. Epstein, Mr. Sitrick
and one of the firm's senior partners Tony Knight dropped everything, got up to speed and
immediately began to work with Mr. Epstein and his attorneys. This was despite the fact that
they had not received either a retainer or a newly executed engagement letter. (You both were
involved in the work that Sitrick did and were part of many, many email chains reflecting same.)
ManageN1756557.1
EFTA01121327
HENNIGAN DORMAN LLP
July 12, 2011
Page 2
The media frenzy, again as you both are aware, required Messrs. Sitrick and Knight to
work days, nights and weekends. When the Duchess of York, who said she had considered
Mr. Epstein a friend, chimed in and also called Mr. Epstein a pedophile, the already frenetic pace
of media hysteria accelerated. News publications from The Daily Telegraph to Newsweek
jumped on the story.
Despite the salaciousness of the coverage in both the U.K. and the U.S., Mr. Sitrick and
his team were able to stop stories that would have aired on TV and in the mainstream media in
the U.S. Among the media outlets that discussed the "story" with Mr. Sitrick were "60 Minutes"
and "Piers Morgan." While they mitigated the damage as much as could be done, Mr. Sitrick
and his team believe they would have been able to do a great deal more
particularly with
respect to the pedophilia allegations — if what they had been told by Mr. Epstein agreed with
what they were told by the attorneys representing him with respect to the ages of the girls who
provided the massages and other facts of the case. Because the lawyers involved disputed
Mr. Epstein's version of the facts, the lawyers intervened and told Sitrick not to move forward on
their plan. Sitrick also believes the media allegations about Mr. Epstein being a pedophile could
have been put to a stop earlier if thcir advice had been heeded earlier with respect to forcing the
Duchess of York to retract her statement calling Mr. Epstein a pedophile. (Getting this term out
of the headlines and the stories was, as you are aware, Mr. Epstein's top priority.)
Mr. Sitrick has repeatedly tried to get a signed copy of his new engagement letter
returned and his invoices paid, but to no avail.
On March 31, Mr. Sitrick wrote Darren Indyke of Mr. Epstein's office stating that he
understood that Mr. Lefkowitz had forwarded him a copy of the Sitrick engagement letter and
that he would appreciate getting it executed and returned. On Saturday April 30 (while
Mr. Sitrick was working on a project for Mr. Epstein and in the midst of several email
exchanges, he wrote Mr. Epstein that he had not received a response back from Mr. Indyke on
his letter. Mr. Epstein apologized and said he would check on Monday. On May 6, Mr. lndyke
finally responded with one sentence: "I have reviewed your engagement letter and it is
unacceptable." When Mr. Sitrick responded that this was exactly the same letter which was
executed in 2005, except for an adjustment in billing rates (a letter which he pointed out was still
in effect, since it had not been cancelled) and asked what was unacceptable about it, Mr. Indyke
responded that Mr. Epstein was traveling and he would have to wait until Mr. Epstein returned.
Once again several weeks passed. On Tuesday, May 31, Mr. Indyke wrote, "1 just returned from
vacation and will get back to you with comments at the end of the week. In general, however,
there is no detail whatsoever in the engagement letter, including but not limited to detail re fees,
approvals, or obligations, and that is just for starters." Mr. Sitrick responded that in fact the
engagement letter does include detail about the fees and obligations, but if they wanted more he
would be happy to provide it. Mr. Indyke never did get back to Mr. Sitrick.
MUmagel756557A
EFTA01121328
HENNIGAN DORMAN LLP
July 12, 2011
Page 3
Given Mr. Sitrick's long relationship with Mr. Epstein, he is hopeful that Mr. Epstein will
sign the letter and, that if he does not want to sign it, that he will just pay Sitrick's invoices and
Messrs. Sitrick and Epstein can just part friends. The amount due is $103,518. As stated,
Mr. Epstein is obligated to pay both on the basis of the earlier letter, an implied contract and
quantum meruit.
Mr. Sitrick does not want to have to pursue legal remedies and turn what has been a good
relationship into an adversarial one. Thank you for your attention to this matter.
JMH/ebm
cc [via email]:
Michael Sitrick
iManagal 756557.1
EFTA01121329
SUMMONS
(CITACION JUDICIAL)
NOTICE TO DEFENDANT: JEFFREY EPSTEIN; an individual
;
(AV7S0 AL DENIANDADO): arid DOES 1 through 20, inclusive
YOU ARE BEING SUED BY PLAINTIFF: MUCK
AND COMPANY, a
(LO ESTA DEMANDANDO EL DEMANDANTE): division
of SITRICK
SRINCKO GROUP, LLC
SUM-100
FORCOURTUSE
Ora° PARA tee CC LA CORM
MAR 0 7 2013
Idea. Calk;
re
,
Offica/Clea
' NOTICE! You have been suet The owl may dedde against you *those your being heard tans you respond wPEi 30 days. Read the Infonastkin
below.
You hem 30 CALENDAR DAYS Sr this summon sad legit papers we served on you to file • written response at Oa tarn and him a con
served on the pandit A letter or phone called not protect you. Your %wItten respect. newt be In proper anal 'ono f you want the court b hear your
case. There may be • court form that you can use for your response. You can find those omit forms and more information at tne Caron* Courts
Online Sell-Help Center (wisw.courtinfo.cagovisehhe0), your county law Foray, or lie courthouse nearest you. If you cannot pay the dire tee, ask
the court dark formless waiver form. If you do not ell your response on lbws, you slay lose the case by default. and your se.% more's,. one property
may be taken without further waning twin the court.
There we other legal requirements. You may want to ad an attorney right away. If you do not know an attorney. you rosy want to cab an farrow
referral service. If you cannot afford an attom• , you may be deb. for See legal services from a nonprofit legal services progrwn. You can locate
these nonprofit groups et the Cattromia Legal Services Web sas (www./awhetoceabmfe.orca, the Calton*, Courts Online Sell-Help Center
(ninv.courarleacagovlsoffholp), a by contacting your local court a county bar association. NOTE: The court has a statutory Oen for waved foes and
costs on any seamed or arbitradzi ward cf $10.000 or more b a dvi case. The courts lien must be paid before the court wit dismiss the case.
;AVIS°, Lo han demandedo. Si no responds done() de 30 dies la code puede deddk an so cadre sin isseucher au vwsdn. Lea la informacion a
continuo:ion
Nem 30 DIAS DE CALENDARIO despuds de qua ki entreguen eats clad* y pepeles Nadu pare presenter cane respueste pa escmo en este
code y MatereNe as *nevem una cope al dennurdante. Una season Ilamede talelordca no to proteges. Su revues). For °sato gene qua ester
en tomato lNeggaela:enact Sl *sea due process') so cast en le oats. Es posfiga qua hays can forandedo quo usted pueda user pare m tsepuests.
Puede sncanbar rates formulados do la coda y mar Informacidn en el Centro de Ayuda de las Codes de Co6lornia towwouttittotgoV), en le
Soria do byes de so condedo o en le curt° qua b oxide may coma St no puede *gar la cools de ProserAloNo. Pao el seclersde do ta cats
qua le di lift /enmity fo de emcee de pogo de octet Si no preemie su mounts a /tempo. puede perderel an pa krotreadenlerdene cora N
padre gutter au sualdo, diner* y Penes sin mss adyertanda.
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caso.
l he name and anus of as court is
(El ameba, y direction de le cone as):
Los Angeles Superior
Court
central
District
111 North Hill
Street
Los Angeles,
California
90012
The name, address, and telephone number of ptaintffs attorney, or plaintiff without an attorney, Is:
JONATHAN B. COLE (70460) VINCENT S. GREEN (231046)
(El WTI" le direction y fel Malmo ale Wawa del abogado dot damendente, ode/ demandante cos no donee
ado, es).
NE74B01K & COLE
15260 Ventura Blvd.
Sherman Oaks, CA 91403
John A. Ciaise
Clerk, by
, Deputy
(Feche)
(Secratatiq
(Acyunto)
(For proof of service of this summons use Proof of Service of Summons (form POS-010).)
(Pare Nue* de enbege de este *slide use el fonnulado Proof of Sundae of Summons. (P05410)).
NOTICE TO THE PERSON SERVED: You ere served
MOO
1. E es en Individual defendant
2.
as the potion sued under the fictitious name of (specify):
3. 1:71 on behalf of (specify):
undo':
CCP 418.10 (corporation)
n
CCP 416.80 (m'nor)
=
CCP 418.20 (defunct corporatkm)
In
CCP 418.70 (conservatee)
I=
CCP 416.40 (association or partnerantp) ED CCP 418.90 (authorized person)
C=3 other (sPecfrY):
4. CI
by personal delivery on (date):
SUMMONS
cat. d chi Moods ff 412 20. S
8. •
tgkolt'
Fs Mc:~ • x tardsiot too
Judicla/ Wel d Cass
SISICO
a01 I. 27001
era raawoc
igg02448
c.susTINA GR1JALVA
EFTA01121330
y
SUM_ A COURT OF CALIFORNIA, COUNTY i. .AS ANGELES
NOTICE OF CASE ASSIGNMENT - UNLIMITED CIVIL CASE (NON-CLASS ACTION)
Case Number
.
37118 10111,4113 TO BE SEEYED ?MOTU SIMMONS AND COMPLAWI BC 5.0 2 4 4R
Yoe: as IS itliettd tor an purports m th Ingdal Meer hullca tea below (Local Rule 35(e)). That Is arMielonal catorinnon on tee reveme xi Oa r• &re fore.
ASSIGNED /EDGE
DEPT
ROOM
ASSIGNED JUDOS
DEPT
ROOM
Non Daniel Duty
1
534
Hon, Debra Sets Weintraub
47
507
Hme. Micheal e. Lirdeld
10
631
Hen. Elizabeth Allen Wbita
48
506
Hon. Barbara A. Matra
12
636
Hon. Dclidre NM
49
509
Hoo. Terry A. Omen
14
300
Ma john L Scgal
50
508
Hon Richard PmIn
. 15
307
lion Abraham Shim
51
511
Hon. Rita Ma
16
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Hon. Sawn B1310tDOOSOtt
52
510
Hon. Richard E. Rico
17
309
lion. Strifes J. KIeMel4
53
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Hem. Kevin C. Badly
20
10
Hon. Ernest M. Iftroshige
54
512
. .
Eton Robed L Hos
24
314
Hart. MaIrolm IL Mackey
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515
Ike. May Ann Mmyby
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Eon MIciuri Tolman
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114
Nan James K Duna
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Flan Mob W. Do
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517
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Hoe. Yrtte M. Pelammloa
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318
Hon. Rolf M. Two
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516
Non. Barbara Sacra
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400
Hon. David I.. Mining
.
61
632
Han. Al S. Romnfletd
31
407
Hon. Mid:lad L Sian
62
600
Non. Mary Et Strobel
32
406
Hon Mack Muting
68
617
Het Clarke P. Primer
33
409
Hon. Ramona See
69
621
Han. Amy D. Howe
34
Pi
Hon. Sousnn G. Brawn
71
729
anoemipat
35
411
Hon.
Karen
72
731
Hon. Gregory Abram
36
410
Hon. Tartan Sanebex.thordan
74
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Hon. Joanna O'Dema11
37
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Hon. Waitron P. Fahey
76
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Non Mama Dutly-Leviis
38
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Hon. Emilie H. Fifes
324
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Hon. MkAs41114.Itoanblait
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Hon. Elam M. Berle
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Hon Mel Rad Room
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Ginn to We PlaIntliFCrons-C-omplainantiAtterrney of Record cc
JOHN A. CLARKE, Extractive Of5catClark
By
, Deputy Clark
LACN CCI-t 180 (Rev. (11112)
LASC Apr roved 05-08
For Oration& Us,
NOTICE Of CASE ASSIGNMENT —
Page 1 at 2
UNLIMITED CIVIL CASE
EFTA01121331
DiSTRUC. NS FOR HANDLING UNLIMITEI. AVM CASES
The following critical provisions of the Chapter Thee Roles, as applicable in the Central Dlealet, are summarized for your assistance.
APPLICATION
The Ctmpter Throe Rules was effective January 1, 1994. They apply to all general chdl cases.
'wormy OVER MIER RULES
The Chapter Three Rules shall have priority over all other Local Roles to the extent the Mhos,: are inconsistent
CHALLENGE TS) ASSIGNED JUDGE
A challenge under Code of Civil Frooecture section 170.6 must be made within 15 days eller notice of assignee:lit for all purposes to
a judge, or if a party has not yet appeared, within 15 days of the fret appearance.
TWEE STANDARDS
Cases animielto the Inefividoel Calendering Court will be subject to processing uncles the following time etindards:
COMPLAINTS: All complaints shall be served within 60 days of filing and proof of novice shell be filed within 90 days of filing.
CROSS-COMPLAINTS: Without leave of court first being obtained. no oressoomPlablt may be Sled by any patty dm their
amuses is bled. Cross-cmnpleints shall be saved within 30 days of the filing date and a proof of service Bled within 60 days of the
filing date.
A Status Conference will be schetinled by the assigned independent Calendar Judge no It than 270 days after es filing of the
complaint. Counsel must be dilly prepared to Mamas the following imam till:tardy', dispute resolution, bifntBtlm, settlement,
tria' 1 date, and war witneaus.
FINAL STATUS CONFERENCE
The Court will require the parties at a status conference not men than 1 0 days before the trial to have timely filed and served all
monana In !intim, bifurcation motions, statements of meilar ovidandsry itattel, diapositive motions, requested jury inetructions, and
special jury teeing:0one end special jury verdicts. These matters may be hard and resolved ss this conference. At lent 5 bye
before this conference, counsel must also have exchanged lleb of exhibits and witnesses and have rutrmitoxl to the court a brief
statement of the case to be read to the jury panel as required by Chapter Eight of the Los Angeles Superior Court Mies
SANCTIONS
The coati will impose appropriate emotions for the failure or tend to comply wit Chapter Three Roks, ceders made by the Cott,
and time standards to deadlines established by the Court or by the Chapter Thee Roles Such sanctions may be an a peaty a if
mproprIate on counsel for the party.
This Ls not a complete delineation of the Chapter Three Rolm, and adherence only to the above provisions is therefore
testa guarantee against the imposition of scuict1ons Tender Trial Co'urt Delay Reduction. Careful reading and
compliance with the actual Chapter Rules is absolutely imperative.
LACN 0:11100
01/12)
NOTICE OF CASE ASSIGNMENT —
Page 2 of 2
tASC Aporond 05-013
For Optional Una
UNLIMITED CIVIL CASE
EFTA01121332
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JONATHAN B. COLE (70460)
VINCENT S. GREEN (231046)
NEMECEK & COLE APC
1526O Ventura Boulevard, Suite 920
Sherman
A 91403
Tel:
/ Fax:
Attorneys for Plaintiff SITRICK AND COMPANY,
a division of SITRICK BRINCKO GROUP, LLC
CONFORMED COPY
ORIGINAL FILED
surtitiOR (CURIO? CALLFORMA
Courme Or LOSAK ass
APR 08 2013
C
Executivc Office:VC:laic
BY
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNT OF LOS ANGELES - CENTRAL DISTRICT
SITRICK AND COMPANY, a division of
SITRICK BRINCKO GROUP, LLC,
Plaintiff,
vs.
JEFFREY EPSTEIN, an individual; and
DOES 1 through 20, inclusive,
Defendants.
Case No. BC502448
FIRST AMENDED COMPLAINT FOR
DAMAGES BASED UPON:
(1) BREACH OF CONTRACT;
(2) BREACH OF ORAL CONTRACT;
(3) COMMON COUNTS;
(4) ACCOUNT STATED;
(5) OPEN BOOK ACCOUNT; AND
(6) QUANTUM MERUIT
DEMAND FOR JURY TRIAL
Plaintiff, SITRICK and COMPANY, a division of.SITRICK BRINCKO GROUP, LLC
("Plaintifr) complains and alleges as follows:
GENERAL ALLEGATIONS
1.
Plaintiff is and at all times herein mentioned was, a limited liability company
organized and existing under and pursuant to the laws of the State of California and
doing business in the State of California, with its principal place of business located in
Los Angeles County.
24860034, i corn
FIRST AMENDED COMPLAINT FOR DAMAGES, ETC.
EFTA01121333
1
2.
Plaintiff is informed and believes, and thereon alleges, that defendant
2
JEFFREY EPSTEIN ("Epstein") is, and at all times relevant hereto was, a citizen of either
3
Florida or New York
4
3.
Epstein has engaged in the necessary minimal contacts with the State of
5
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California for this Court to entertain personal jurisdiction, including, but not limited to,
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entering into a contract in California with a California limited liability company, phone calls
8
and emalls to Plaintiff In California for strategy and advice, and paying for services -
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delivered from California.
10
•
4.
On or about November 4, 2005, Epstein entered into a written contract
11
(the "Contract') with Plaintiff to provide advice and public relations services. The
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Contract provides it may be terminated with 30 days written notice by either party. The
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Contract has never been terminated. A true and correct copy of the contract is attached
15
hereto as Exhibit 1.
16.
5.
On or about March 11, 2011, Epstein entered an oral contract with Plaintiff
17
(the 'Oral Contract') to provide consulting advice and public relations services concerning
18
Epstein's relationship with Prince Andrew of England.
19
6.
The true names and capacities of Defendants DOES 1 through 20,
20
inclusive, whether individual, corporate, associate, or otherwise, are unknown to Plaintiff
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at this time, who therefore sues said Defendants by such fictitious names, and when the
23
true names and capacities of such Defendants are ascertained, Plaintiff will seek leave of
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Court to amend this Complaint to insert same. Plaintiff is informed and believes and
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thereon alleges that each Defendant named as a DOE is responsible for each and every
26
act and obligation hereinafter set forth.
27
7.
Plaintiff is informed and believes and thereon alleges that each Defendant
28
named in this Complaint was at all times herein mentioned and now is the agent, servant
2
209003P 1.com
FIRST AMENDED COMPLAINT FOR DAMAGES, ETC,
EFTA01121334
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and employee of the other Defendants herein, and was at all such times acting within the
course and scope of said agency and employment and with the consent and permission
of each of the other co-Defendants, and each of the Defendants herein ratified each of
the acts of each of the other co-Defendants, and each of them.
8.
The obligation sued upon herein was incurred in and is payable in the
County of Los Angeles, State of California.
9.
Said obligation is commercial in nature, not based upon a retail installment
sales contract or a conditional sales contract, and not subject to the provisions of Civil
Code §§1812.10 and 2984.4.
FIRST CAUSE OF ACTION
(Breach Of Written Contract as Against Epstein and Does 1 through 20, and Each
of Them)
10.
Plaintiff repeats, realleges and Incorporates herein by reference the
allegations of paragraphs 1 through 4 and 6 through 9, inclusive, as though set forth at
length.
11.
Pursuant to the terms of said Contract, entered into by and between
Plaintiff and Epstein on or about November 4, 2005, Plaintiff agreed to provide advice
and public relations services to Epstein, and Epstein agreed to pay for these services.
12.
Plaintiff has sent written statements of account to Epstein listing the
amount of its indebtedness to the Plaintiff and requesting payment therefore from
Epstein.
13.
On or about July 8, 2011, Epstein breached the Contract by failing to pay
Plaintiff for the advice and public relations services rendered.
14.
Plaintiff has performed all conditions, covenants and promises required on
its part to be performed in accordance with the terms and conditions of the Contract
except as excused by the breach of Epstein
3
24890O3.P.1.com
FIRST AMENDED COMPLAINT FOR DAMAGES, ETC.
EFTA01121335
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15.
Pursuant to the terms of said Contract, and as a result of Epstein breach of
said Contract, the Plaintiff has been damaged in the sum of $103,517.82, together with
Interest thereon at the legal rate from the date the obligations were due, and said sum is
now due and owing.
SECOND CAUSE OF ACTION
(Breach of Oral Contract as Against Epstein and Does 1 through 20, and Each of
Them)
16.
Plaintiff repeats, reatleges and incorporates herein by reference the
allegations of paragraphs 1 through 3 and 5 through 9, inclusive, as though set forth at
length.
17.
Pursuant to the terms of said Oral Contract, entered Into by and between
Plaintiff and Epstein on or about March 11, 2011, Plaintiff agreed to provide advice and
public relations services to Epstein, and Epstein agreed to pay for these services.
18.
Plaintiff has sent written statements of account to Epstein listing the
amount of its indebtedness to the Plaintiff and requesting payment therefore from
Epstein.
19.
On or about July 8, 2011, Epstein breached the Oral Contract by failing to
pay Plaintiff for the advice and public relations services rendered.
20.
Plaintiff has performed all conditions, covenants and promises required on
its part to be performed in accordance with the terms and conditions of the Oral Contract
except as excused by the breach of Epstein.
21.
Pursuant to the terms of said Oral Contract, and as a result of Epstein
breach of said Oral Contract, the Plaintiff has been damaged in the sum of $103,517.82,
together with interest thereon at the legal rate from the date the obligations were due,
and said sum is now due and owing.
4
2489003P.1.corn
FIRST AMENDED COMPLAINT FOR DAMAGES, ETC.
EFTA01121336
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THIRD CAUSE OF ACTION
(Open Book Account For Reasonable Value Of Services Rendered as Against
Epstein, and Does 1 through 20, and Each of Them)
22.
Plaintiff repeats, realieges and incorporates herein by reference the
allegations of paragraphs 1 through 9, inclusive, as though fully set forth at length herein.
23.
Within the last four years, at Los Angeles County, California, Epstein,
became indebted to Plaintiff in the sum of $103,517.82 as and for the balance due upon
an open book account for advice and public relations services provided by Plaintiff to
Epstein based upon the Contract and Oral Contract. Pursuant to the Contract and Oral
Contract, payment was promised and agreed by Epstein to be made. Billing records of
legal fees and costs Incurred by Epstein, including debits and credits, were kept in the
regular course of business by Plaintiff and kept in a reasonably permanent form reflecting
an open book account In the aggregate reasonable value of $103,517.82.
24.
No part of said sum has been paid, although demand therefore has been
made, and there remains due, owing and unpaid from Epstein to Plaintiff the sum of
$103,517.82 together with Interest thereon at the legal rate from the date the obligations
were due.
FOURTH CAUSE OF ACTION
(Open Book Account, For Agreed Value Of Services as Against Epstein, and Does
1 through 20, and Each of Them)
25.
Plaintiff repeats, realleges and incorporates herein by reference the
allegations of paragraphs 1 through 9, inclusive, as though fully set forth at length herein.
26.
Within the last four years, at Los Angeles County, California, Esptein
became indebted to Plaintiff for legal services provided by Plaintiff to Epstein at its
specific instance on an open book account in the agreed value of $103,517.82.
27.
No part of said sum has been paid, although demand therefore has been
made, and there remains due, owing and unpaid from Epstein to Plaintiff the sum of
5
2469061P.1.corn
FIRST AMENDED COMPLAINT FOR DAMAGES, ETC.
EFTA01121337
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$103,517.82, together with interest thereon at the legal rate from the date the obligations
were due.
FIFTH CAUSE OF ACTION
(Account Stated Against Epstein, and Does 1 through 20, and Each of Them)
28.
Plaintiff repeats, realleges and incorporates herein by reference the
allegations of paragraphs 1 through 9, inclusive, as though fully set forth at length herein.
29.
Within the last four years, at Los Angeles County, California, an account
was stated by and between Plaintiff and Epstein, wherein and whereby it was agreed that
Epstein was Indebted to Plaintiff in the sum of $103,517.82, which sum Epstein agreed
and promised to pay, and that no part of the same has been paid.
30.
No part of said sum has been paid, although demand therefore has been
made, and there remains due, owing and unpaid from Epstein to Plaintiff the sum of
$103,517.82, together with interest thereon at the legal rate from the date the obligations
were due.
SIXTH CAUSE OF ACTION
(Quantum Nierutt Against Epstein and Does 1 through 20, and Each of Them)
31.
Plaintiff repeats, realleges and incorporates herein by reference the
allegations of paragraphs 1 through 9, inclusive, as though fully set forth at length herein.
32.
Between on or about November 2005 through June 2011, Plaintiff
performed public relations services on behalf of Epstein for which Epstein promised to
pay Plaintiff at its fair and reasonable value.
33.
Demand for payment for these services has been made by Plaintiff to
Epstein, but Plaintiff has not been paid.
34.
The fair and reasonable value of said services equals not less than
$103,517.82 or an amount to be proven at trial.
35.
Epstein has failed and refused, and continues to fail and refuse, to pay
6
2489CCP.1.corn
FIRST AMENDED COMPLAINT FOR DAMAGES, ETC.
EFTA01121338
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Plaintiff for said services, leaving a balance immediately due to Plaintiff according to
proof, but in no event less than 5103,517.82, together with interest thereon at the rate of
10% per annum from the date saki sum became due.
WHEREFORE, Plaintiff prays judgment against Epstein, and Does 1 through 20,
and each of them, as follows:
1.
For damages in the sum of $103,517.82, together with interest thereon at
the legal rate from the date the obligations were due;
2.
For reasonable attorneys as provided for by the Contract;
2.
For costs of suit incurred herein; and,
3.
For such other relief as the Court deems just and proper.
Dated: April 5, 2013
NEMECEK & COLE
By:
J
THAN B. COLE
VINCENT S. GREEN
Attorneys for Plaintiff
SITRICK AND COMPANY,
a division of SITRICK BRINCKO GROUP, LLC
7
2439003P.1 can
FIRST AMENDED COMPLAINT FOR DAMAGES, ETC.
EFTA01121339
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DEMAND FOR JURY TRIAL
Plaintiff SITRICK and COMPANY, a division of SITRICK BRINCKO GROUP, LLC,
demands a trial by jury on all claims.
Dated: April 5, 2013
NEMECEK & COLE
Br.77.4M4
-04
//L_
JONATHAN B.
VINCENT S. GREEN
Attorneys for Plaintiff
SITRICK AND COMPANY,
a division of SITRICK BRINCKO GROUP, LLC
8
2489003P.I.eam
FIRST AMENDED COMPLAINT FOR DAMAGES, ETC.
EFTA01121340
EXHIBIT A
EFTA01121341
I Scott Kornspen - FtoyEilackydf
SITRICIANDOMMANYTIC
tr011iCELIS•Npl
Knot= 42005
Fag,
Mack, Slant*. Koosspan
&w pt
20i S. Disowns BL, fl300
MS .P. 33111
Dim Mr
Utz Mort elm warned by yes Woo Watt or lelThey Epstein (the tilers and
abeRfieby Bieck, Imbrick, [angora C Stoop( ralttbatter), w1E tastle0e tb win,
arlit sweat a tba ayOmsel of Ritrick Asti OararstlY lm, a CAWS C0WICkg
('ltilltle) a
oorpasto tic=
advbee. /Padang
ceewthenl, wit typos Way kap/ Rasa Atoms; is band Sag Rs ales ante following tams
and ocomessons:
1.
Tie Mot ad Attonay, etkethe la etOolobs 2I, 0005, S.eawahwd linkt OP
=MOM
tad *lie telstRsit aavioiteosawodas whit legal lm h b
.
1.
SIbleir si0 warn b cowy sionfoxlablc runes of $60$O a s
5lc
lberv4- CselPasY Wall pay &Oa a noo-telunektde =Wire of
ISO,C00 as a =WC, rasa exs Sitrices titre chairs *Cl imb:fled /vine: Cto
awns at the boorly rata men a $165 m $650 depsnalia• on the ponce parfornaais
taviceg parapsofboisuallsoiamat dos Is billod in 155.00 pa ban. Wiwi the rosince
Ws bee spoked valor Wm data" Satin' time dna Is any yen will Is baled
'incurred end an payable witbin Cy
Woe a0a Co.
Charges tie ccespuid an •
Fortalavpartil basis for sy panel dew rot most*" bald outside or Sio*k. OTC
Theo la 51)5 by Wok a incense of onsgesc &
boa.
W isIdItiCa, w custom:WV moues. a - tic
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lurks, As • clime which mob la alculbcart beneflia os to thong bcyoal dal we
turban a oars] pubtlo stadwas dsn mild beam Obviously, we "odd et dew, and
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sulqcri to you avowal
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swim our bob oath cr. 'urge Cob If you barer), wssloss. please fad
Ws to nIL Elcavesci, ads you isoks some promo la Sttsick in wrba..tg within Cy
Si of swiss of to bill, it will be prwomod yo• bare no **odor* bit and afya m
tboreaamblcress adze NIL
3.
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of sad posb sod crycnaes tasinol b9 nrick In connection ebb In ewpserd
Iwo CksayPteia Gat • Si MO* Lam Mgt. Cn ICOIT-SCS
00) MOW Pao 04 MSS]
EFTA01121342
srnuat AND cainbrr INC
lannolin
lniernatto 4, 2003
Octodbawitbok uwiØ b■adcoa cextrana mats, laa &mot mad
pleemeopy cturgn, sod abet onef-pooloat eon ad imams. Rsistaabh corn an
not mailed apart fbe Manor lad crab* billed matey by Stutok
4.
Kind Monocrtedges that ht torrloa Wog Peorlded anima to 4th has wan
in
for du Iambi of CiOnt and diet Attorney, ea Cann coutud, tWU out be tramaibh for
aø aa, maw omens hound lo amitectioo win SSW' Ravin
5.
SOntek AM Company's ongatanaa berounikis tidy be baminad by
pert( Is Xi
don prior tericen notim. AU ~dam Meth Mae anti... to to primal of fan rad
mainibt aqt ladamilloaka w0 who s7 itrarbake of due awarnical by tift•
pry. All tho perndzion of titia Mix anisical In manic 4 5. 6 ad 7 MI ore
fix s pnod of ton sari Moving dit dale at eery ØØ
d ta t mesa
by
direr Ø.
6.
ID me and any =pays, idShick o any ciao la tmoired or tma:and to ~it
Ot
~do mtbnoy, demean 4X otba 'Ada
an adm orbit/Mon or odor
pwarahm main. directly a lallmaly, to an ensidirsta, abeam or eat or
crosemi bra has tomenoted, the Client doll pay Snick for ta dam tØ b
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EFTA01121343
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EFTA01121345
1 JONATHAN B. COLE (70460)
DAVID A. MYERS (140181)
2 NEMECEK & COLE
A Professional Corporation
3
15260 Ventura Boulevard, Suite 920
ShewapislaigLgji fom
4
Tel. a
/ Fax
5 Attorneys for Plaintiff SITRICK AND COMPANY,
a division of SITRICK BRINCKO GROUP, LLC
6
7
8
9
Fiat
Court of Cathorria
Stsgutty of Los Angeles
APR 15 2014
Sherri
Carter,
scueve Off icercler
By 9,1%—s
h.
osrlr
Deputy
Borne, G
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT
10
s
SITRICK AND COMPANY, a division of
) Case No. BC502448
I
II SITRICK BRINCKO GROUP, LLC
.....1
)
) [Assigned to the Hon. Kevin C. Brazile:
W OE 12
Plaintiff.
) Dept. 20)
_I
)
-vs-
) [Diteite€41D] ORDER
)
O
14
JEFFREY EPSTEIN, an individual; and
)
o
15 DOES 1 through 20, inclusive,
le ga
) (Lodged Concurrently with (Proposed]
) Judgment By Court By Default)
mal.,'
x gat 16
Defendants.
)
E,S If
)
l7
) )
C
)
?
18
)
S
0
19
)
20
On April 10, 2014, during the 8:30 a.m. calendar, in Department 20 of the Central District of
21 the Superior Court of California, County of Los Angeles, the Request for Judgment of Plaintiff
22 SITRICK AND COMPANY, a division of SITRICK BRINCKO GROUP, LLC ("SITRICK") in the
23 total amount of $170,983.22 against Defendant JEFFREY EPSTEIN ("EPSTEIN") came on for
24 hearing before the Hon. Kevin C. Brazile. David Myers, Esq. of Nemecek & Cole appeared on behalf
25 of SITRICK. There were no other appearances. The Court, after due consideration of the papers and
26 evidence submitted regarding the matter, and oral argument orders as follows:
27
1.
Certain costs requested by SITRICK are disallowed including the "Arbitration Filing
28
Fce" in the amount of $2,850 (SITRICK's Memorandum of Costs dated March 17,
—I-
24119003P 10 Proposed Orderupd
ORDER
EFTA01121346
10
11
12 IT IS SO ORDERED.
13
14 Date: April L. 2014
15
16
17
18
19
20
21
22
23
24
25
26
27
28
2014 at 7.d) and other arbitration fees in the amount of $1,850 from the $3,328.52 in
2
"Other" costs (SITRICK's Memorandum of Costs dated March 17, 2014 at 7.c.,
3
Attachment l). As such, the total amount of costs in the "Other" costs section that are
4
allowed is $1,478.52 ($3,328.52 less 51,850).
5
2.
As to attorneys fees, the Court awards a total of 520,000 (510,819 less than the
6
530,819 SITRICK requested).
7
3.
The Remainder of SITRICK's Request for Court Judgment is GRANTED and as such
8
a JUDGMENT in favor of SITRICK AND COMPANY, a division of SITRICK
9
BRINCKO GROUP, LLC and against JEFFREY EPSTEIN shall be issued in
the total amount of $155,464.22 ($170,983.22 - $2,850 - $1,850 - $10,819).
EVTN C. BRAZ1LE, Judge,
California, County of Los An
—2—
nor oun of
2489003P.10 Proposed Order.wpd
ORDER
EFTA01121347
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
JONATHAN B. COLE (70460)
DAVID A. MYERS (140181)
NEMECEK & COLE
A Professional Corporation
15260 Ventura Boulevard, Suite 920
d
f 9
Tel /
fax
Attorneys for Plaintiff SITRICK AND COMPANY,
a division of SITRICK BRINCKO GROUP, LLC
CFN 20140318368
OR PK 27003
PG 1065
RECORDED 98/27/2914 08:08:15
Pals Beach County, Florida
Sharon R. Bock, CLERK 8 COIIPTROLLER
Pon 1065 - 1067; (3pgs)
SUPERIOR COURT OF TIIE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES - CENTRAL DISTRICT
SITRICK AND COMPANY, a division of
SITRICK BRINCKO GROUP, LLC
Plaintiff,
-vs-
JEFFREY EPSTEIN, an individual; and
DOES I through 20, inclusive,
Defendant.
Case No.: BC 502448
[Assigned to the Hon. Kevin C. Brazile:
Dept. 20]
AFFIDAVIT IN SUPPORT OF
FOREIGN JUDGMENT IN FLORIDA
DAVID A. MYERS, declares:
I.
I am an attorney licensed to practice law in the State of California. I am a member of
Nemecek & Cole, a Professional Corporation, the attorneys of record for Plaintiff/Judgment Creditor,
SITRICK AND COMPANY, a division of SITRICK BRINCKO GROUP, LLC ("SITRICK"). I
have personal knowledge of the following facts and could and would competently testify thereto if
called as a witness in this action.
2.
The judgment creditor's name is SITRICK AND COMPANY, a division of SITRICK
BRINCKO GROUP, LLC and the business address is 11999 San Vicente Blvd., Penthouse, Los
—1-
2489003P I I Allictral %.pd
EFTA01121348
1 Angeles, CA 90049.
2
3
3.
The judgment debtor is known to me as JEFFREY EPSTEIN and was last known to
4 reside at 358 El Brillo Way, Palm Beach, FL 33480.
5
I declare under penalty of perjury under the laws of the State of California that the foregoing is
6 true and correct.
7
8 Dated: 0 1/2
:0
9
10
11
12
13
05 ApeefeS
14 State of California2
County of
16 O
,7el%
before
15
me/rnyineMate9tlihS01//Ani
o tcer)
(insert name an Mit of the
_)
_
17
18
19
20
21
22
23
24
25
26
27
28
personally appeared
CI A. M ti" S
ry
who provided to me o
e basis of satisfacto eiidence to be the person(s} whose names} is/are-
subscribed to the within instrument and acknowledged to me that h qui/they executed the same in
his/W*4140i, authorized capacity(ies)-, and that by his/Ivarliheir signature(*on the instrument the
person(a); or the entity upon behalf of which the persons)-acted, executed the instrument.
I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing
paragraph is true and correct.
WITNESS my hand and official seal.
(Seal)
YVONNE M. MAGHSODi
Commission • 2042160
Wiry Public • Cattalo
tab •••••1 County
Cara E
tin Sn 20, 2011
-2-
2489003P I I Allithvit wpd
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EFTA01121350
•
PLAINTIFF: SITRICK AND COMPANY, a division of SIIRICK BRINCKO
- GROUP, I.,LC
DEFENDANT: JEFFREY EPSTEIN; an individual; and DOES 1-20
CASE *SK*
BCS02448
JUDGMENT IS ENTERED AS FOLLOWS BY:
al
THE COURT
ED THE CLERK
4. Q
Stipulated Judgment. Judgment Is entered according to the stipulation of the parties.
5. Parties. Judgment Is
a. cri for plaintiff (name each): Sitrick And Company, a
division of Sitrick Brincko Group, LLC
and against defendant (names): Jeffrey Epstein, an
individual
CI Continued on Attachment 5a.
b. C
for defendant (name each):
6. Amount
a. ED Defendant named In Item Sa above must
pay plaintiff on the complaint
(1) OD
(2) OD
(3) OD
(4) OD
(5) n
Damages
Prejudgment
Interest at the
annual rate of
10
%
Attorney fen
Costs
Other (specify):
$ 103,617.82
$ 29,652.93
$ 20,000.00
$
2,293.47
shoo
(6)
TOTAL
$155,464.22
b. CD Plaintiff to receive nothing from defendant
named in item 5b.
Defendant named In item 5b to recover
costs $ 0.00
and attorney fees 3 0.00
7. C
Other (specify):
Dale:
;be.ti,ejr.44)
C. C
for cross-completnent (name each):
and against cross-defendant (name each):
Continued on Attachment Sc;
d. C
for cross-defendant (name each):
c. C:l Cross•defendant named In item 5c above must pay
cross-complaInant on the ups...complaint
(1) CD Damages
0.00
(2) ED Prejudgment
interest et the
annual rale of
S4
0.00
(3)l)
Attorney fees
0.00
(4)O
Costs
0.00
(5) Ej
Other (specify):
0.00
(6)
TOTAL
0.00
d. O
Crose-complainant to receive nothing from
cross-defendant named in item 5d.
CI Cross-defendant named In Item 5d to recover
Is 3 0.00
L...1 and attorney fees $ 0.00
CLERK'S CERTIFICATE (Optional)
I certify that this is a true copy of the original judgment on Me In the court
Dale:
AUG 1 5 2014
Clerk. by
JUDGMENT
Deputy
Peesitsfi
EFTA01121351
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273 694.1234Phone
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