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FIRST CLAIM FOR RELIEF 5. On or about May 15ih, 2009, plaintiffs and defendant Jeffrey Epstein, among others, entered into a certain Agreement for Design Services (the "contract"), a copy of which is annexed hereto as Exhibit A. 6. Each of the parties was obligated by the implied covenant of good faith and fa
Studio, Ltd. and Juan Pablo Molyneux, complaining of the defendant, Jeffrey Epstein, by their attorney Rosh D. Alger, herein allege: I. Plaintiff, J.P. Molyneux Studio, Ltd. is a corporation organized and existing under the laws of the State of New York and maintains its principle place of business within the Stat
009 the parties entered into a Settlement Agreement to resolve their pending disputes. That same day, the parties also entered into an Agreement for Design Services to further resolve the many issues Epstein had with Molyneux and Molyneux's services. The Agreement for Design Services required Molyneux to credit
fenses in the action and of the legal issues in the case: In 2005, Epstein engaged the architectural and design services of Juan Pablo Molyneux and J.P. Molyneux Studio, Ltd. ("Molyneux") to design a large-scale, multi-structure, multi-million dollar residential project to be constructed on Little St. James Island
strued as a waiver by my clients of any rights they may have, including, without limitation, any rights, claims or defenses under the Agreement for Design Services or the Settlement Agreement between our respective clients, all of which are hereby expressly reserved. There are numerous uncorrectable issues rel
d shall not be admissible for any purposes in any litigation or other proceedings involving any of Mr. Epstein, L.S.J., LLC, Juan Pablo Molyneux or J.P. Molyneux Studio, Ltd., among others. Please be advised that nothing provided by this letter is intended or should be construed as a waiver by my clients of any rig
Entities connected to both Design Services and J.P. Molyneux Studio

Jeffrey Epstein
PERSONJuan Pablo Molyneux
PERSONDarren Indyke
PERSONRoyal Dane
ORGANIZATIONEl Escorial
LOCATIONthe Office Pavilion
ORGANIZATIONRosh D. Alger
PERSON
Prince Charles
PERSONMolyneux Studio, Ltd.
ORGANIZATION
Little St. James
ORGANIZATION