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Park Avenue Suite 2020 New York, New York 10177 Re: Agreement for Design Services dated May 15, 2009 ("Design Services Agreement") by and among Juan Pablo Molyneux, Molyneux Studio. Ltd_LS.L. LLC and leffrey Epstein Dear Jay: The characterization in your February 24, 2010 letter of Mr. Epstein's legitimate r
nd, in lieu thereof, Mr. Molyneux prepared Exhibit B to provide an indication of the items required for completion of the office/library portion of the Office Pavilion. Moreover, Section 11 of the Design Services Agreement is clear that "the prior drafting history of this Agreement shall not be used to construe an
EFENDANT IS SUBJECT TO INQUIRY In their First Amended Complaint, it is alleged "[i]n 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
n contracted with Molyneux for the architecture and design of the interior and exterior of a separate building on Little Saint James Island known as the Office Pavilion." FAC„ para. 4, p. 2. They also state that Plaintiff L.S.J., LLC, is the owner of Little St. James Island. See Neitzke v. Williams, 490 U.S. 319, 3
and communications, and 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
ettlement Agreement between our respective clients, all of which are hereby expressly reserved. There are numerous uncorrectable issues relating to the Office Pavilion, which remains unfinished almost a full year after the parties entered into their settlement agreement and more than four years after Mr. Molyneux
York 10006 Dear Mr. Indyke: TELEPHONE 12121963.0000 TELCCOPIER c212/1063.6000 As per the Design Services Agreement dated May 15, 2009, signed by Juan Pablo Molyneux and Jeffrey Epstein, $250,000 was allocated to items purchased for the Office Pavilion. As the budget spreadsheet used to create Exhibit B notes, t
the Design Services Agreement dated May 15, 2009, signed by Juan Pablo Molyneux and Jeffrey Epstein, $250,000 was allocated to items purchased for the Office Pavilion. As the budget spreadsheet used to create Exhibit B notes, the approved items included in the $250,000 are intended for the Office/Library. Only if
sideration should be granted. I. BRIEF STATEMENT OF RELEVANT FACTS AND PROCEDURAL HISTORY OF CASE In 2005, Plaintiffs contracted with non-parties Juan Pablo Molyneux, a resident of the State of New York, and his company, I. Molyneux Studio, Ltd. (collectively "Molyneux"), a New York corporation, to design a resi
f the Project, Plaintiffs contracted with Molyneux to design the interior and exterior of a separate building on Little Saint James Island known as the Office Pavilion. Molyneux contracted with Fancelli Paneling, Inc. ("Fancelli" or "Defendant"), a New York corporation, to custom make the cabinetry, bookshelves, c
ument #: 8 Filed: 06/11/10 Page 1 of 5 DISTRICT COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN X J.P. Molyneux Studio, Ltd. and Juan Pablo Molyneux FIRST AMENDED COMPLAINT -against- Case No. 3:10-cv-00034 Jeffrey Epstein and L.S.J., LLC. X PLAINTIFFS, by and through the undersigned counse
rnish and cause to be properly installed and completed at the Office Pavilion by January 2, 2020 all of the items listed on Exhibit hereto and that the Office Pavilion will be completed to Epstein's reasonable satisfaction by January 1, 2010, Molyneux agrees that the' aggregate amount to be applied against the Cre
ument #: 8 Filed: 06/11/10 Page 1 of 5 DISTRICT COURT OF THE VIRGIN ISLANDS. DIVISION OF ST. THOMAS AND ST. JOHN X J.P. Molyneux Studio, Ltd. and Juan Pablo Molyneux FIRST AMENDED COMPLAINT -against- Case No. 3:10-cv-00034 Jeffrey Epstein and L.SJ., LLC. X PLAINTIFFS, by and through the undersigned counsel
ish and cause to be properly installed and completed at the Office Pavilion by January 1, 2010 all of the items listed on Exhibit B hereto and that the Office Pavilion will be completed to Epstein's reasonable satisfaction by January 1, 2010. Molyneux agrees that the' aggregate amount to be applied against the Cre
Entities connected to both Juan Pablo Molyneux and the Office Pavilion

Jeffrey Epstein
PERSONDarren Indyke
PERSONJay Goldberg
PERSONFancelli
PERSONthe State of New York
LOCATIONJ.P. Molyneux Studio
PERSON
U.S. Virgin Islands
LOCATIONDoug Schoettle
PERSONStudio
PERSON
Saint James
LOCATION
Prince Charles
PERSONRoyal Dane
ORGANIZATIONFanceli
LOCATIONthe Exhibit B Services
ORGANIZATIONMolyneux Studio, Ltd.
ORGANIZATIONDenise Francois
PERSONDesign Services
ORGANIZATIONMOORE DODSON & RUSSELL
ORGANIZATIONSt James Island
LOCATIONVI Bar No
ORGANIZATION