EFTA Document EFTA01298009

OPERATING AGREEMENT THIS OPERATING AGREEMENT OF NEPTUNE, LLC (the "Company"), dated December/1 , 2011, is adopted and executed by Jeffrey E. Epstein ("Member"), as the sole member of the Company. ARTICLE I. Organization LI. Formation. The Company has been organized as a Delaware limited liability• company by the filing of a Certificate of Formation of the Company (the "Certificate") with the Delaware Secretary of State pursuant to the Delaware Limited Liability Company Act, 6 Del. C. §§ 18