Epstein Secrets

August 3, 2012 Via E-mail: KELLERHALS FERGUSON FLETCHER KROBLIN LLP Jeffrey Epstein ATTN: Darren Indyke St. Thomas, VI RE: Jeffrey Epstein, et al v. Nick Lambros, et al. Civil No. 2012/ 21 Our File No. 00324.030.001 Dear Mr. I

t Superior Court CA . CLARKE Court Clerk II D03211.301 EFTA00296752 IN THE SUPERIOR COURT THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN JEFFREY EPSTEIN and L.S.J., LLC, ) ) ) Plaintiffs, ) CASE NO. ST-12-CV-21 ) v. ) ) NICK LAMBROS and ACLC, LLC, d/b/a SOUND X, ) ) Defendants. ) ) O

ter in order to properly respond to the allegations of the Complaint, and given that extensions of time to respond to complaints are EFTA00296753 Epstein, et al., v. Lambros, et al. Case No. ST-12-CV-21 Order, March 20, 2012 Page 2 of 2 routinely agreed to by counsel in this jurisdiction as a profe

illpIpeiR 360 WESTPCSMNIEErfErAliSNY 8ANONGTONOLUNCIE 0909 847-3&249II (*nee 6477381-1107 FAX nskasolusemalin can NAide Aaron gReSt. PARA** Jentsy Epstein SW: . EINEM ,SENID I PART, I DESCRIPTION A 14: 2 -is; 2 ell: 1 Vi!i 1 44! I ea. i tit; et, I ea l die I -tia. IlLI. 4*. a MI

-mail: KELLERHALS FERGUSON FLETCHER KROBLIN LLP Jeffrey Epstein ATTN: Darren Indyke St. Thomas, VI RE:

ated December 4, 2010 for a project total of $181,241.80 and accompanying proposals for each individual project. Based upon representations made by Lambros, Plaintiffs paid Lambros One Hundred Thirty-Five Thousand Nine Hundred Thirty-One Dollars and Thirty-Five Cents ($135,931.35) by wire transfer on D

t as an attempt to cause delay, arguing the request is premature, and confirming that service was accomplished on March 10, 2012. Because Defendant Lambros was served outside the Virgin Islands, he has thirty (30) days from the date of service to respond to the Complaint, or until April 9, 2012. Ordinar

EMAIL ( II) AND FEDERAL EXPRESS 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 ("Epstein"). I am writing in connection with claims they have against you regarding high-end, professional audio-visual equipment a

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 ("Epstein"). I am writing in connection with claims they have against you regarding high-end, professional audio-visual equipment and installation services y

hereby expressly Sincerely, 49.3 v ti._ Darren K. lndyke EFTA00299475 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS & ST. JOHN JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, CASE NO. ST-11-CV- -vs- NICK LAMBROS and AVLC, LLC d/b/a SOUND X, Defendants. ACTION FOR BREACH OF CONTRACT AND F

0010 Dear Mr. Lambros: As you know, I represent Jeffrey Epstein and L.S.J., LLC ("Epstein"). I am writin

times to Little St James Island in St Thomas and Mr. Epstein's New York property to provide professional insta

er: email: September 8, 2011 VIA EMAIL ( II) AND FEDERAL EXPRESS 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 ("Epstein"). I am writing in connection with claims they have against you regarding high-

ttle Saint James Island located in the U. S. Virgin Islands, as well as a luxury townhouse in New York City. 8. Based upon representations made by Lambros, Plaintiffs paid Lambros over one Hundred Thirty Five Thousand Dollars to provide to Plaintiffs and install equipment (the "Equipment") of makes an

DEFENDANT’S MOTION FOR RECONSIDERATION AND/OR REQUEST FOR RULE 4 REVIEW AND APPEAL Plaintiff, Jane Doe, hereby files this response to defendant Jeffrey Epstein’s Motion for Reconsideration and/or Request for Rule 4 Review and Appeal of Portions of Magistrate’s Order (dkt. #477). The motion should be denie

al of Portions of Magistrate’s Order (dkt. #477). The motion should be denied in its entirety. As the magistrate judge correctly found, defendant Epstein has no valid Fifth Amendment objection to refusing to turn over materials and information already in the Government’s possession. Moreover, the ot

irety. As the magistrate judge correctly found, defendant Epstein has no valid Fifth Amendment objection to refusi

Jane Doe, hereby files this response to defendant Jeffrey Epstein’s Motion for Reconsideration and/or Requ

venth Circuit’s ruling in Maddow and treat the tax return information as discoverable under ordinary standards. See also Shearson Lehman Hutton v. Lambros, 135 F.R.D. 195, 198 (M.D.Fla.1990) (ordering disclosure of tax returns because such information was relevant to the parties claims and defenses, r

IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS & ST. JOHN ****************************** JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, -vs- NICK LAMBROS and AVLC, LLC d/b/a SOUND X, Defendants. TO: Venetia H. Velazquez, Esq. Clerk of the Superior C

via first class mail, postage prepaid, upon: Nick Lambros EFTA00298126 In Te District Court of The Virgin Islands Division of St. Thomas & St. John JEFFREY EPSTEIN AND LS.J., LLC Plaintiff v. NICK LAMBROS AND AVLC, LIE D/B/A SOUND X Defendant ) Case No.: ST-12-CV-21 ) Court Date: at ) ) ) ) ) ) ) A

, • "OFFICIAL SEAL" DEBORAH A. MILLER Notary Public, Staled Minds My Commission Expires Apra 5,2014 ID:12-047131 Cleat Refer we: Milk/notary Epstein vs !tick Lasalatos, a AI EXHIBIT EFTA00298127 Lt Te District Court of The Virgin Islands Division of St. Thomas & St. John JEFFREY EPSTEIN AND

HOMAS & ST. JOHN ****************************** JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, -vs- NICK

ght Port of Sale, Suite 15-16 St. Thomas, USVI 00802 Telephone: (340) 779-2564 Facsimile: 888 316-9269 Email: EFTA00298125 Epstein, et al. v. Lambros, et al. Civil No. 2012/ 21 Notice of Service of Process Page 2 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the day of March, 2012, I caused

THOMAS/ST. JOHN Plaintiff CASE NO. ST-I2-CV-2I JEFFREY EPSTEIN and LLC Vs. t ACTION FOR: NICK LAMBR

IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS/ST. JOHN Plaintiff CASE NO. ST-I2-CV-2I JEFFREY EPSTEIN and LLC Vs. t ACTION FOR: NICK LAMBROS and ACLC, LW, d/b/a SOUND X Defendant JURY TRIAL DEMANDED NOTICE OF ENTRY OF A(N) ORDER TO:GREG J.,

t Superior Court CA . CLARKE Court Clerk II D03211.301 EFTA00308364 IN THE SUPERIOR COURT THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN JEFFREY EPSTEIN and L.S.J., LLC, ) ) ) Plaintiffs, ) CASE NO. ST-12-CV-21 ) v. ) ) NICK LAMBROS and ACLC, LLC, d/b/a SOUND X, ) ) Defendants. ) ) O

ter in order to properly respond to the allegations of the Complaint, and given that extensions of time to respond to complaints are EFTA00308365 Epstein, et al., v. Lambros, et al. Case No. ST-12-CV-21 Order, March 20, 2012 Page 2 of 2 routinely agreed to by counsel in this jurisdiction as a profe

t as an attempt to cause delay, arguing the request is premature, and confirming that service was accomplished on March 10, 2012. Because Defendant Lambros was served outside the Virgin Islands, he has thirty (30) days from the date of service to respond to the Complaint, or until April 9, 2012. Ordinar

IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS & ST. JOHN ****************************** JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, CASE NO. ST-12-CV- 21 NICK LAMBROS and AVLC, LLC d/b/a SOUND X, Defendants. ACTION FOR BREACH OF CONTRACT AND FR

lic record, book, or document used as evidence on the trial; and (6) Attorney's fees as provided in subsection (b) of this section. EFTA00622679 Epstein, et al. v. Lainbros, et al. Case No. ST-12-CV-21 Motion for Award of Costs and Attorneys' Fees Page 2 (b) The measure and mode of compensation of

HOMAS & ST. JOHN ****************************** JEFFREY EPSTEIN and L.S.J., LLC, Plaintiffs, CASE NO. S

r, Civ. No.1990-200, 1993 WL 661181, at '2 (D.V.1. Dec. 30, 1993); sec also Marcher v. Nash, 32 F.Supp.2d 239, 241 EFTA00622680 Epstein, et at v. Lambros, et at Case No. ST-l2-CV-2l Motion for Award of Costs and Attorneys' Fees Page 3 (D.V.I.1998). Reasonable attorneys' fees may include charges for

C, LLC d/b/a Sound X Location: 2775 ALGONQUIN RD STR 250, Roiling Meadows, IL 60008 Received: 2/11/2012 Completed: 2/17/2012 1:20 PM Reference: Mier/Jeffrey Epstein vs Item Qty. Unit Total 6. National P3 Fuel Surettaige National 1 $120.00 5120.00 $9.90 $9.9C Sub-Total $129.90 Thank Vont TERMS: °NET

judgment hearing. Accordingly, a total of an additional 4 hours is added to the instant fees sought but not contained in Exhibit A. EFTA00622684 Epstein, of al. v. Lambros, et al Case NO. ST-12-CV-21 Affirmation Paget 4. Based on my review of the.file and the underlying bills, the total and reason

12/10112 01/12/2012 BG 01/13/2012 CK 01/17/2012 BC 9100 Havensight, Port of Sate Suite 15/16 St. ThoS Phone: KELLERHALS7FERGUSON Epstein, Jeffrey Invoice 22414 Date Feb 08, 2012 Terms Service Thru Jan 31, 2012 Date By Services Hours Rates Amount 01/04/2012 01/05/2012 01/06/2012 0

Accordingly, a total of an additional 4 hours is added to the instant fees sought but not contained in Exhibit A. EFTA00622684 Epstein, of al. v. Lambros, et al Case NO. ST-12-CV-21 Affirmation Paget 4. Based on my review of the.file and the underlying bills, the total and reasonable amount of att

from my iPad Begin forwarded message: From: Nicole Miller < Date: August 3, 2012 3:1 1 :27 PM EDT To: Darren Indyke Cc: Chris Kroblin Subject: Epstein, et al. v. Lambros, et al.- CLIENT COPIES Good afternoon Darren, Please see attached correspondence enclosing client copies for your records. Best

From: Darren Indyke < To: Lesley Groff Subject: Fwd: Epstein, et al. v. Lambros, et al.- CLIENT COPIES Date: Fri, 03 Aug 2012 19:23:23 +0000 Attachments: Cover_Letter 08.03.12.pdf For Lambros file Sent from my iPad Begin for

Subject: Fwd: Epstein, et al. v. Lambros, et al.- CLIENT COPIES Date: Fri, 03 Aug 2012 19:23:23 +0000 Attachments: Cover_Letter 08.03.12.pdf For Lambros file Sent from my iPad Begin forwarded message: From: Nicole Miller < Date: August 3, 2012 3:1 1 :27 PM EDT To: Darren Indyke Cc: Chris Kroblin