EFTA00308279

Document #013 Sent from my Blacknerry wireless device Meeting August 20th 2010 From: Doug Schoettle Date: Wed, id—iiaivZele 0?:58:56 -0800 (PST) To: cji5G6929@ao16.Com> • Cc: <'eevacati il_com›; Rowles<w C ; William Subject: Fanc nch List FAHCELLI PUNCH LIST Wood Paneling at LS) Office . _ LI: Complete the installation of the toe molding at the baseboard. 2. Install closure trim piece of oak.beloWthe picture windo Matecial*site. w sill to f8l WI:approx. . cm high, the length of the window. • Finish rough, unfinished end condition at the sliding panel s at the2pictere window. or: Drill, file and sand perforations at tilt dawn' desk panels to removtrodikand ragged edges. sr Glue and clamp open joints in paneling through out the room. .4": Generally sand rough finishes and raised grain at panel ing through out the room. LTC Replace tortise shell inlay where it is pieced or flaking and 4elaminatinge 1-8: Repair cabinet door hardware so that the screw does not loosen when the handle rotated to operate door and so the hardware does is not rattle. Supply and -install two turtle pulls at tilt down desk panels. arkeplate-bambas-atesh at all cabinet doors with metal mesh in a dark color not rust. that will 11. Replace the non functioning blackbOards with slate that will existing surface has been wiped clean with take chalk. . The wax' and dried. The surface does satisfactor/y. not take chalk Pill. Provide additional light bulbs for the • shelf lights inside the cabin the specification. ets and provide /20-poily 'de-under_padding. .=-14. The staining of the cornice shoul d be like the Escorial Library dark. with light and /A/7-1S.The staining of the columns pittoir- iG.An wood surfa should highlight the carvings with ces in the room are to be finished, light and dark. desk tops are unfinished. currently the undersides of the lu7-17.Interiors of the cabinets are to be stained darker so as not to the shelf lights are on. appear orange when 7/1/4/08. All wood surfaces are to be varni shed./ 19. The sliding panels are unfinished plywood, how are they to be 20. finished? NIL - WO) WORK It Dou e o Ai rile L. I sr o -77-1-Eg-- ft-t-AIJ Repk1 1. 5(10 3 .,1/4113 u6 irc gc , (-es •Sr\ it> a S rwA (14 o c‘o 6-zyt 1 -e f4 541:4 3. arc-Atc-K-so Age, 3fr <AP/o qbEFENDANT'S 4 EXHIBIT ts, ft Ailimploinewisearamin, EFTA00308279 Document #014 Meeting August 20th 2010 t'T:O'.:h 23. 2O1 WORK APPRoval Mot .nen..: Stud° St. Limes (sr ICE Fotloicing the on Site meeting March 2.2*: - 23-; 2010, among: The client RePresentative Gary Kerney, AI 31/5/23 ( 0 Molyneux Studtol JuanPablo Molyneux. 0P6 t MciaS Fancelli Panehng: Jean Pierre Fanelli,4 (sEtib7, t( -&)(..-6...0 office/go:0 In regard of the tittle Saint lames Othce project: WoodivOrk, 2 sEt-th 0130.) 624Lc Motyneux Studio Purchase Order =2680 Fanceb Paneling Invoice =1024 LI 4th fe StiAtt IJernn Officejron p eL Molyneux Stocko Purchase Order =8321 (-3 — er7LACK, 30A2b FanceltiPaneting Invoke 31098 The work executed by FanCelli Paneling tOt106.ving the project designed by Ho)yneux Stuck, and corrections executed March 19- 23'i are approved and accepted by the client representative and by MOlyneuX Studio. Balance on completed work is now due. St James Island, USVI, March 23, 2010 Client Representative Oestgner F3Ilteni Contractor Gary KCCOAY Juan Pablo (z),21.113Zix lean Pierre F.an,C,CP EFTA00308280 Cr.t.Stk Kristen Goff cram: tot 11W11edne11sd11ay111111 so: , March 17, 2010 8:33 AM Subject; Kristen Goff-, Filar Motyneux Fw. ' . Categories: Red Category From Date: , 17 Ma • • To: Aurelien Subject: Fw: Suit from my BlackBer ry0 wireless device From: Jeffrey Epstein <jee vacationggmailcom> Date: 7:14:35-0400 To: jp Cc; Dou Indyke Subject: jou are only to communic Gary Kane ate with gary keamey, m )SI ; Darren the facts. e or through your attnys to damn, Doug does no t have all The information containe d confidential, may be atto in this communication Is rney-client privileged, constitute inside informat may ion, and is intended on the use of the addressee. ly for It is the property of Jeffrey Epstein Unauthorized use, disclo sure or copying of this communication or any part thereof is strictly pr and may be unlawful. If oh you have received this ibited communication in error, please notify us immed return e-mail or by e-mail iately by to ieevacation@gmail.c destroy this communicat om, and ion and all copies thereo including all attachmen f, ts. EFTA00308281 EFTA00308282 Ckv-olno 113 Document #015 Meeting August 20th 2010 OH' 12.Y • Little St. James Punch List Report March 22, 2010 7 EFTA00308283 MOLYNEUX STUDIO LTD. With toe molding Request: Complete the Installation of toe molding. Status: Toe molding Is on site and will be Installed week of March 22-26. N. 01901 — Punch UGC - Item #1 2 EFTA00308284 JP MOLYNEUX STUDIO LTD. Gap underneathwindow sill Request: Install closure trim piec e of oak belo w the pict ure window sill to fill gap approx. 3cm high, the Stall's: The gap mus t rem length of the window. ain. The sliding shu tter track is located here —the gap needs to be open to function properly. 01901 -- Punch List — Item #2 3 EFTA00308285 JP MOLYNEUX STUDIO LTD. Top right— finished end Top right— finished end Bottom left— unfinished end Bottom right — unfinished end Request: Finish rough unfinished end condition at the sliding panels at the picture window. Status: Two finis hed end s as of March 22, two more to be finished week of March 22-26. 01901 — Pttnth List — Item #3 4 EFTA00308286 JP MOLYNEUX STUDIO LTD. Oat %Lt. 'F..i/a ^ . . . . "i• V et •r • FC yr Mb S ; • . IP i• i Wret • r iNC .. 0;e4s.QX • • .4.; "„:1 • ..4....:•4:••••0•:r;'''''' ....'%:•ntr- • I • •:•';' :• Drilled, filed and sanded holes Drilled, filed and sanded perforations Request: Drill, file and sand perforations at tilt down desk panels to remove Status: Complete. rough and ragged edges. 01901— Punch List — Item #4 EFTA00308287 JP MOLYNEUX STUDIO LTD. Corner miter Joint glued and clamped. Wall edge at window seat glued and clamped. Request: Glue and clamp open joints In paneling throughout the room. Status: Complete. 01901 — Punch List — Item #5 EFTA00308288 JP MOLYNEUX STUDIO LTD. Inner edges of wood profiles cleaned through out. Request: Generally sand rough finishes and raised grain at paneling throughout the Status: room. Initi al requ este d finis h was distr esse d, salvaged from sea and weathered. San ding is complete in small crevices throughout. 01901— Punch List — Item #6 7 EFTA00308289 JP MOLYNEUX STUDIO LTD. Repaired tortoise shell Inlay— pre-Install Repaired tortoise shell Inlay Request: Replace tortoise shell Inla y where it Is pieced or flaking and dela minatIng. Status: Will be completed week of Mar ch 22-26. Tortoise shell for repair 619(11— Punch List — Item #7 EFTA00308290 MOLYNEUX STUDIO LTD. New middle ring fastener (back of door). Vertica ar top, ml.d a new anal bottom fastener. New middle ring (above shell handle) Installed . Request: Repair cabinet door hard war e so scre w doe s not loos en whe n handle Is rotated to operate the doo Status: Complete. A third met r and so rattle Is eliminated. al ring was Insta lled on metal vertical bar to act as third fastener, eliminating rattle. Hardware tightened. 0190? - Punch List — Item #8 9 EFTA00308291 JP MOLYNEUX STUDIO LTD. Mw Ara ••.0 "A. .1? %to • • nes1.4. • • NJ- TMw tkos,te ?,.z ,& ;•:: ".: Request: Supply and Install two new turtle pulls. Status: Complete. 0.1901— Punch Lii4t — Item #9 10 EFTA00308292 JP MOLYNEUX STUDIO LTD. orAWAFATTOSivgavIA Ava iggallegeMYS Vfik WavATTV q !AT' War9 7 .4 )0%* • itl ' Damaged bamboo grille. a. rt. • • ••••••••••••616 Non -damaged bamboo grille. Damaged bamboo grille. Request Riplace bamboo mash at all cabinet dos* with metal mesh In a dark Status: New metal grilles are not in color that will not rust. agreement 'Fancelli has repaired damaged grilles and will provide 8 new framed grilles for future use. 01901 — Punch List — Item #10 ll EFTA00308293 -P MOLYNEUX STUDIO LTD. The blackboard works -tested on site. is • . 4. e r.a • Appropriate chalk to use. The blackboard works —tested on site. The blac board works — teste on site. Request: Replace the non-functioning blackboards with slate that will take chalk. Existing Status: Replacement of blackboard surface does not take chalk satisfactorily. material is not in agreement. Chalk works on existing chalk. Crayo!a chalk not recommended. 01901— Punch List — Item #11 12 EFTA00308294 JP MOLYNEUX STUDIO LTD. I- CM'S': light bulbs Inside cabinet shelf. — l*P LI ht bulbs inside cabinet shelf Request: Provide addition al ligh t bulbs for the she lf ligh ts Insid e the cabinets and provide the specifications. Status: Fa ncelli will provide the specific ations for the ligh t bulb s. Ord erin g the bulb s is not In the agreement and must be paid for by client 01901 — Punch List — Item #12 13 EFTA00308295 JP MOLYNEUX STUDIO LTD_ Request: Confirm the size of the carpet and provRie under— padding. Status: Carpet padding Is not In the agre ement. 01901-• Punch List — Item #13 t4 EFTA00308296 JP MOLYNEUX STUDIO LTD. Cornice light and dark. Request: The staining of the cornice shou ld be like the Escorial library with light and dark. Status: Fancelli will stain the corn ice with ligh t and dark afte r the dehumidifier is Installed and the moi sture content of wood is acceptable. 019 01 — Punch List — Item #14 15 EFTA00308297 JP MOLYNEUX STUDIO LT D. Highlig ted carvings. Highlighted carvings - sample fini shes, not final. Request: The stainin g of the col um ns sho uld hig hlightthe carvings with light and Status: Fa ncelli will stain the dark. colum ns aft er the deh um idif ier is Installed and the moisture con tent of wood Is acc eptable. 01901 — Purieb List — Item #15 16 EFTA00308298 JP MOLYNEUX STUDIO LTD. CL771 PRfaSTIFIGeg: • -;.,•: -.721,At.,. .Ft-g 1:ft. • 7it, Approved and signed finish (at left). ire at , et i I) A$4..c..,,fic-, .<4,74,4.,.- e-s2ultal' -.,, g -n h., • 4T-ti ...&4, ,, "" ,e, ire „....,„ i't • Approve• a n• s gne• nis its.+44:3...4.4/..t...4..,/. ..inavi.t.. Request; All wood surfaces In the room are to be finished: Currently, the undersides of the desk Status: Fancelli tops are unfinished. will stain all wood surfaces after the dehumidifier Is installed and the moisture content of wood Is acceptable. 01901 - Punch List — item #16 17 EFTA00308299 JP MOLYNEUX STUDIO LTD. 4•,4•90.31a: •- : •1 4. 1;417tIr Two finish options within cabinet. 717 TWo finish options within cabinet. Request Interiors of the cabinets are to be stain ed dark er so as not to appear orange when the shelf ligh Status: TWo alternatefinishes have ts are on. bee n prod uce d on site . JPM and Gary Kerney do not recommend chan ging the interior finish. ONO - Punch List — Item #17 H. 18 EFTA00308300 MOLYNE'UX STUDIO LTD. Approved and signed finish. Approved an• signed nIs Request: All wood sudaFes are to be varnished. --- Status: Fancelll wT gain all wood surfaces after the dehumidifier Is installed and after the moisture content in the wood Is acceptable. 01901 — Punch List — Item #18 19 EFTA00308301 MOLYNEUX STUDIO LTD. • Rejected leather for shutter Insert. Shutters. Shutters. Request: The sliding panels are unfinished plywood. How are they to be finished? Status: Not In agreement 01901 •- Punch List — Item #19 20 Case: 3:10-cv-00034-CVG -RM Document #: 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 counsel, for their First Amended Complaint allege as follows: JURISDICTION AND AMOUNT IN CONTROVERSY 1. Plaintiff Juan Pablo Molyneux is a citizen of the State of New York. 2. Plaintiff J.P. Molyneux Studio, Ltd. is incorporated in the State of New York and maintains its principal place of business in the State of New York. 3. Defendant Jeffrey Epstein is a citizen of the Territory of the U.S. Virgin Islands. 4. Upon information and belief, the remaining Defendant, L.S.J., LLC, is organized in the State of Delaware and maintains its principal place of business within the U.S. Virgin Islands. 5. This Court has original jurisdiction over this matter pursuant to 28 U.S.C. § 1332(a) because the amount in controversy exceeds $75,000, exclusive of costs, interest and disbursements and the Plaintiffs and Defendants are citizens of different states. 6. Venue is proper in this Court pursuant to 28 U.S.C. § 1391(a), (c). D s -al D[ .\ \yr<3 1 —iFseile112-- , .1-P EFTA00308302 Case: 3:10-cv-00034-CVG -RM Document #: 8 Filed: 06/11/10 Page 2 of 5 FACTS COMMON TO ALL COUNTS 7. Juan-Pablo Molyneux is a world-renowned interior designer. 8. Jeffrey Epstein, via his company L.S.J., LLC, is the owner of Little Saint James, a 70-acre island within the U.S. Virgin Islands. 9. In 2005, the parties entered into an agreement whereby the Plaintiffs would provide design services for the residential compound Epstein was constructing on Little Saint James. 10.Subsequently, disputes arose between the parties with respect to the design services to be provided by Plaintiffs. 11.On May 15, 2009, the parties entered into a Settlement Agreement, annexed hereto, whereby the Defendants released all claims they might have had against the Plaintiffs in exchange for $1.2 million. 12.Following the Settlement Agreement, the parties entered into a written contract on May 15, 2009, entitled Agreement for Design Services ("Design Services Agreement"), annexed hereto, wherein the parties agreed that the Plaintiffs would perform certain design services related to the office pavilion being constructed by Defendants on Little Saint James, for which Plaintiffs would credit Defendants' account with Plaintiffs in the amount of $250,000 to be applied toward such services. The specific services to be provided were itemized on Exhibit B to the Design Services Agreement (the "Exhibit B Services"). 13.The Settlement Agreement specifically provides that the Design Services Agreement "shall not be treated as an inducement to the execution of the Settlement Agreement." Settlement Agreement at 1 2. 14.Subsequent to the execution of the Design Services Agreement, Plaintiffs, with the assistance of an internationally-known woodworking craftsman, undertook to and did perform the Exhibit B Services, thereby satisfying their obligations pursuant to the Design Services Agreement. 2 EFTA00308303 Case: 3:10-cv-00034-CVG -RM Document #: 8 Filed: 06/11/10 Page 3 of 5 15.On January 26 and 27, 2010, Plaintiffs travelled to Little Saint James to supervise the final stages of the work pursuant to the Design Services Agreement. It was agreed that Epstein would be present in order to give his approval of the work. Epstein, however, failed to attend this agreed meeting. 16.On March 10, 2010, Defendants' agent created a Punch List cataloguing certain tasks remaining to be completed pursuant to the Design Services Agreement. 17.On March 22, 2010, Plaintiffs again travelled to Little Saint James to meet with Epstein in an effort to finalize the work performed by Plaintiffs pursuant to the Design Services Agreement. Epstein again failed to attend the agreed meeting. In an effort to perform their obligations under the Design Services Agreement, Plaintiffs and their representatives, nevertheless, undertook to complete, and did complete, the Punch List items falling under the Design Services Agreement. 18.On March 25, 2010, Defendants' agent signed off on all items enumerated on the Punch List by signing it and noting that all the woodwork on the list was done with the exception of three minor items, none of which was specified in Exhibit B to the Design Services Agreement. 19.Although their agetit had signed off on the Punch List, Defendants' counsel sent a letter to Plaintiffs on April 15, 2010, claiming that Plaintiffs had failed to perform their obligations pursuant to the Design Services Agreement. 20.In the letter, Defendants' counsel also claimed that the Plaintiffs fraudulently induced Defendants to enter both the Settlement Agreement and the Design Services Agreement. 21.In an effort to resolve the dispute, Plaintiffs' representatives once again traveled to Little Saint James on April 29, 2010 to meet with Defendants' representatives. The meeting was unproductive and Defendants' counsel continued wrongfully to insist that Plaintiffs had not satisfied their obligations with respect to the Design Services Agreement. 3 EFTA00308304 Case: 3:10-cv-00034-CVG -RM Document #: 8 Filed: 06/11/10 Page 4 of 5 FIRST CLAIM DECLARATORY JUDGMENT 22. Plaintiffs repeat and reallege the allegations contained in paragraphs one through 21 above. 23. There are justiciable controversies with respect to the following issues: a. Whether the Plaintiffs substantially performed their duties as required by the Design Services Agreement; b. Whether Defendants violated their duty of good faith and fair dealing under the Design Services Agreement by engaging in conduct that was inconsistent with the terms and purpose of that agreement and the reasonable expectations of the parties by, among other things: (a) wrongfully rejecting the Plaintiffs' work with respect to the Exhibit B Services; and, (b) absenting themselves from the meetings between the parties which were held to resolve their differences, thereby interfering with and failing to cooperate with Plaintiffs in the performance of their obligations; and c. Whether, as alleged in Defendants' April 15, 2010 letter, Plaintiffs fraudulently induced Defendants to enter the Settlement Agreement and the Design Services Agreement. 24.A declaration of the rights among the parties is warranted pursuant to 28 U.S.C. § 2201. WHEREFORE, Plaintiffs demand judgment against the Defendants as follows: a. Adjudging and declaring that Plaintiffs substantially performed their duties as required by the Design Services Agreement; 4 EFTA00308305 Case: 3:10-cv-00034-CVG -RM Document #: 8 Filed: 06/11/10 Page 5 of 5 b. Adjudging and declaring that the Defendants violated their duty of good faith and fair dealing under the Design Services Agreement; and c. Adjudging and declaring that Plaintiffs did not fraudulently induce Defendants to enter the Settlement Agreement or the Design Services Agreement, and that the Settlement Agreement and Design Services Agreement are valid and enforceable; and d. Awarding such other and fiirther relief as the Court deems equitable and just. Respectfully Submitted, Rosh D. Alger Esquire, LLC Attorneys for Plaintiffs DATED: June 11, 2010 St. Thomas, U.S. Virgin Islands By: s/ Rosh D. Alger Rosh D. Alger, Esq. VI Bar No. 932 Tel. Fax 5 EFTA00308306 Case: 3:10-ct-00034 - CVG - RM Document #: 8-1 Filed: 06/11/10 Page 1 of 1 RI/S44 guy NO.) CIVIL COVER. SHEET TaJS 44 ti-4 Catoam sza Or inf.:ntal conaned herein neither by (cal Ma ofmet. Ilia 10441/4 IISPNOVOdby replaa nor suppiesent the Alin/ trod orrice ofpkodias or Ma Mars Confen /4~try Im mat Fie Mil data Met (3111, 41100410144144 THE REVERSE OF na of she VMS Shin inSaambool 974. is requital la Ne use of On CktE el' Carl for Itt porasco providocE THE Wan) lMating I. (a) PLAINTIFFS DEFENDANTS M0lyneux Studio, Ltd. and Juan Pablo Molyneux Jeffrey Epstein and LSJ , Lt.c (b) cow« Itedemea aria tas wont New York. NY I County etReakkret «First Liked Cecikrtdant senor:0.15,w ~Taus PLAINTIST CASES) ON U.S. PLROMFF CASES 0/41.Y) MOM R4 LARD CCIRDEMNA TEN CASES. VS E THE LOCETb3) 4 OF THE LAND INVOLVED. (c) Afloat(' Warty... I US. Ttkptsc ebaréct) Ancerneys utraemd Rosh D. Alger. Esq, PUB 10 Royal Dane Mall Denise M. Francois, Esq., Hodge tt Francois, Sea IL HASS OP JURISDICTION "ark one thm oriyi in. 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D•Phrs444 550 Cir3 Pad. tka" twijesa 0 400a 44124546144. 555 Maa Ceno46c4 Work» CA« O 15410/Siak o 440 01~041~ Suns. V. ORIGIN Inman - x• be Or be Daly) tg ( or;cris Proceed:4w O2 Reniond Dam 03 lamamad Gm( O 4 Reitatted or 0 3 4 T110011T ardrand0O141 4" 41 "lie IS S2 ~tell* District a 7 km4=4.4°4. Sae coun Aimeatte Court Reamed Licirmion ID91/ ifyikirándir hikonea which yam Nita (Do at at ItradIc ("cri ttojr !Nato mans ~It» VI- CAUSE OP ACTION W atl yicio ofmesa Judgment VII. REQUESTED IN Olat IFIRIS IS A CLASS ACTION DEMAND S CHECK YES My ifdteranded LiRyldnt COMPLAINT: UNDER F.R.C.P. 23 Yu/. RELATED CASE(S) JURY DEMAND: - aYes cati. IF ANY (in kansilent> RIDGE DOOM,' NVMDISI OATS S/ONATUAR OF ATTORNEY Of RECORD 06/1.1/2010 s/Rash D. Alger PO* Olrg.c uSs aus RECOPY I ?MOUNT Arrtvihro 31./DOE NI332 EFTA00308307 . Case: 3:10-cv-O0034-CVG-RM Document #: 8-2 Filed: 06/11/10 Page 1 of 6 THIS AGREEMENT, entered into this 15th day of May, 2009, by and amo Juan Pablo Moiyneux ("JP"), Molyneux Studio, Ltd. ("Studio", and ng JP,Nolyneux,") LS.J., LLC ('LSJ") and Jeffr toge ther with ey Epstein (`Epstein"). WHEREAS, disputes have arisen between Molyneux, cm the one hand, and 135 and Epstein, on the other hand, rela ting to payments and deli connection with design and related serv verables in ices by Molyneux for LSJ and/or with respect to Little St. James Island and othe Epstein r properties beneficially owned by Epstein (the 'Disputes"); and WHEREAS, the parties hereto desire to settle all Disputes as provided In this Agreement; NOW, THEREFORE, in consideration of the mutual agreements, promises and othe prov foregoing premises and the r isions contained herein, JP, Studio, and Epstein (the 'Parties"), intending to LSJ be bound, hereby agree as follows: 1. The Parties agree to settle the Disputes accordance with the provisions of this Agr , upon, subject to and in eement 2. On or before May 15, 2009, Molyneux shal Two Hundred Thousand Dol l pay Epstein One Million lars (51,200,000) by wire transfer of that account designated in writing by Epstein amount tq an to Molyneux not later than May 15, With the payment of this amount, all claim 2009. s shall be released and extinguishe except for claims to enforce the provisio d, ns of this Agreement or the Design Agreement of even date herewith. Said Desi Serv ices gn Services Agreement provides its remedies for any breach thereof, shall own not affect the release provisions of SettlernentAgreernent, and shall not be trea this ted as an inducement to the exec the Settlement Agreement. ution of 3. (a) Epstein and 131 and each of their executors and administrators (collectivel successors, assigns, heirs, y, the 'Epstein Releasors") hereby fully irrevocably release each of JP and Sttid and io, and each of their successors, principals, heirs, executors, and adm assigns, inistrators (collectively, the Releasees"), of and from any and all manner "Molyneux of claims, demands, rights, liabi losses, obligations, duties, damages, deb lities, ts, expenses, interest, penalties, sanction fees, attorneys' fees, costs, actions, s, potential actions, causes of action, agreements, judgments, decrees, matters, suits, issues and controversies of any nature or description whatsoever, kind, whether known or unknown; disclose undisclosed, accrued or unaccrued, d or apparent or not apparent, foreseen unforeseen, matured or not matured, or suspected or unsuspected, liquidated liquidated, fixed or contingent, whe or not ther direct, derivative, individu representative, legal, equitable, or of al, any type, or in any other capacity; whe based on state, local, foreign, federal, stat ther utory, regulatory, common, or othe for, upon or by reason of any matter, caus r law, e, or thing whatsoever in any way relating to, involving, referring to, arising out of, or based upon, directly or indirectl y, any 1 EFTA00308308 Case: 3:10-cv-00034-CVG-RM Document #: 8-2 Filed: 06/11/10 Page 2 of 6 actions, transactions, occurrences, statements, representations, misrepresentations, omissions, allegations, facts, practices, events, claims or any other matters or things whatsoever, or any series thereof, existing -or occurring on or prior to the date hereof relating in any way to the Disputes, Anything to the contra ry In this Section 3(a) notwithstanding, nothing herein shall release the Moly-neux Relea sees from any of their respective joint or several obligations under this Agreement or the Design Services Agreement (b) JP and Studio and each of their successors, assigns, heirs, executors and administrators (collectively, the "Molyneux Releasors") hereby fully and irrevocably release each of Epstein and LS), and each of their successors, assigns, principals, heirs, executors, and administrators (collec tively, the "Epstein Releasees"), of and from any and all manner of claim's, demands, rights, liabilities, losses, obligations,.duties, damages, debts, expenses, interest, penalties, sanctions, fees, attorneys' fees, costs, actions, potential actions,, causes of action, suits, agreements, Judgments, decrees, matters, Issues and contro versies of any kind, nature or description whatsoever, whether known or unkno wn, disclosed or undisclosed, accrued or unaccrtied, apparent or not appare nt, foreseen or unforeseen, matured 6r not matured, suspected or unsuspecte d, liquidated or not liquidated, fixed or contingent, whether direct, derivative, individual, representative, legal, equitable, or of any type, or In any other capacity, whether based on state, local, foreign, federal, statutory, regulatory, comm on, or other law, for, upon or by reason of any matter, cause, or thing whatsoever in any way relating to, involving, referring to, arising out of, or based upon, directly or indirectly, any actions, transactions, occurrences, statements, representations, misrepresentations, omissions, allegations, facts, practices, events, claims or any other matters or things whatsoever, or any series thereof, existing or occurring on or prior to the date hereof relating in any way to the Disputes. Anything to the contrary in this Section 3(b) notwithstanding, nothing herein shall release the Epstein Releasees from any of their respectiVe Joint or several obligations under this Agreement or the Design Services Agreement 4. By entering into this Agreement, the Parties do not intend nor shall they be deemed to have made, any admission of to make, liability of any kind whatsoever. The Parties agree that they are entering into this Agreement for the purpose of settling certain disputes between them and to avoid furthet expense with respect to those disputes. 5. The Parties agree that the existence, terms, and consid pursuant to this Agreement are strictly confidential and that this eration paid Agreement will not be filed in any court, except in proceedings to enforce this Agreement or the Design Services Agreement. No Party may reveal any facts about this Agreement or the terms of this settlement without the prior, written consent of each of the other Parties; provided, however, that a Party may disclose facts about the settlement (i) to its or his employees, 2 EFTA00308309 Case: 3:10-cv-00034-CVG-RM Document ft: 8-2 Filed: 06/11/10 Page 3 of 6 accountants and attorneys who require the same for the purpose of performing their employment duties or providing professional services to such Party; (ii) to its or his insurers or re-insurers; (iii) as required -by any law, regulation, or rule of a court or court agency; or (iv) in response to a duly authorized subpoena or court order. Before disclosing any facts about the settlement under provisos (i) or (ii) above, the Party making the disclosure shall inform the receiving party of the tents of this confidentiality provision and shall take reasonable measures to ensure that the receiv ing party agrees not to make further disclosures 6f the requested information. M least five business days prior to disclosing any facts about the settlemau under provisos (iii) or (v) above (other than in connection with proceedings to enforce the provisions of this Agreement or the Design Services Agreement), to the extent permissible by law, regula tion, rule of a court or court agency or court order, the Party making or asked to make the disclosure shall inform each of the other Parties of the proposed disclosure or reques t for information, and shall, at the request of any Party and at the cost of such requesting Party, file any disclosure or response to the request for information about the settlem ent or the terms of this Agreement pursuant to a motion or other formal reques t that the information be maintained in confidence and/or held under seal. 6. The Parties agree that the prior drafting history of this Agreement shall not be used to construe any term of this Agreement. This Agreement has been negotiated by each Party and such Party's respective attorn eys, and the language hereof will not be construed for or against any such Party as the principal drafter of this Agreement . 7. The Individuals signing this Agreement and the Parties on whose behalf such indiiiduals are signing hereby represent and warrant that they are empowered and authorized to sign on behalf of and bind the Parties for whom they have signed. 8. The Parties represent and warrant that, as-of the Effective Date of this Agreement, they have not assigned, conveyed, or otherwise transferred the rights to any claims, demands, causes of action, rights, or obligations related in any way to . the claims to be released in paragraphs 3(a) and 3 (b) to any other person or entity, norshall they hereafter do so. 9. Each Party agrees that this Agreement shall be binding upon the successors, and assigns of each Party. heirs, 10. Each Patty represents and agrees that such Party: (I) has fully reviewed this Agreement and has had the opportunity to seek advice by independent counsel of its choosing with respect to the same; (ii) fully understands the terms of this Agreement and has entered Into this Agreement voluntarily without any coercion or duress on the part of any person or entity; and (iii) was 3 EFTA00308310 Case: 3:10-cv-00034-CVG-RM Document 8-2 Filed: 06/11/10 Page 4 of 6 given adequate time to consider all implications of this Agree ment prior to entering into it. 11. This Agreement may be executed in any number of counterpa of which shall be deemed an original, but all of which together rts, each shall constitute one and the same Instrument Signatures of this Agreement transm itted by fax shall have the same effect as original signatures. 12. This Agreement may not be amended or modified except by a written instrument executed by the duly authorized representatives of all of the Parties. Any waiver of any provision hereof must be in writing and signed by the party to be charged with such waiver. Any such waiver shall be effect ive only in the specific instance and for the specific purpose for which such waiver Is given. No failure on the part of any Party to exercise, and no delay in exercising, any right, power or privilege under this Agreement shall operate as' a waiver thereo f; nor shall any single or partial exercise of any right, power or privilege under this Agreement. preclude any other or further exercise thereof or the exercise of any other right, power or privilege hereunder. 13. Any statements, communications or notices to be provided to this Agreement shall be In writing and sent by hand pursuant delivery or by reputable Overnight courier to the attention of the Parties indicated below, until such time as notice of any change of person to be notified or change of addre ss is forwarded to all Parties: (a) For Epstein and LSI: Darren K Indyke, Esq. (b) For JP and Studio: Jay Goldberg, Esq. 14. IMP This Agreement shall be governed by and construed in with the laws of the Virgin Islands applicable to agreement accordance s entered Into entirely within the Virgin Islands, without regard to the principles of Virgin Islands law regarding conflicts of laws. 4 EFTA00308311 Case: 3:10-cv-00034-CVG-RM Document #: 8-2 Filed: 06/11/10 Page 5 of 6 15. Each Party irrevocably and unconditionally submits to the jurisdiction of any court sitting in the Virgin Islands over any exclusive suit, action or proceeding arising out of or relating to the Disputes. Each Party agree s that service of any process, summons,notice or document as provided in Section 13 hereof shall be effective service of process for any action, suit or proceeding broug ht In any such court. Each . Party irrevocably' and' oraitTdifii5billflahier any Objection to the laying of venue of any such suit, action or proceeding broug ht in such court and any claim that any such suit, action or proceeding brought in such court has been brought in an inconvenient forum. Each Party agrees that a final, non -appealable judgment in any such suit, action or proceeding brought In any such court shall be conclusive and binding upon such Party and may besenforced In any other courts to whose jurisdiction such Party is or maybe subject, by suit upon judgm ent IN WITNESS WHEREOF, the parties hereto have caused this • be executed by themselves or their duly authorized representati Agree ment to ves, as the case may be, as of the date of the day and year first above-written. J.P. MOLYNEIDC STUDIO, LTD. By: it ) JEFFREY EPSTEIN L.SJ., LLC By: JEFFREY EPSTEIN. Member EFTA00308312 Case: 3:10-cv-00034-CVG-RM Document #: 8-2 Filed: 06/11/10 Page 6 of 6 15. Each Party irrevocably and unconditionally submits to the exclusive Jurisdiction of any court sitting In the Virgin islands over any suit, action or proceeding arising out of or relating to the Disputes. Each Party agrees that service of any process, summons, notice or document as provided in Section 13 hereof shall be effective service of process for any action, suit or proceeding brought in any such --court-• Each Party-irrevocably-and- onconditIonally- waives—any -abfectIOn- VS the laying of venue of any such suit, action or. proceeding brought in any such court and any daira that any such suit, action or proceeding brought in such court has been brought In an inconvenient forum. Each Party agrees that a final, non-appealable Judgment in any such suit action or proceeding brought In any such court conclusive and binding upon such Party and may be enforced in any other shall be whose Jurisdiction such Party is or may be subject by suit upon Judgm courts to ent IN WITNESS WHEREOF, the parties hereto have caused this be executed by themselves or their duly authorized repres Agreement to entatives, as the case may be, is of the date of the day and year first above-written. J.P. MOLYNEUX STUDIO. LTD. By: Juan Pablo Molyneux President JUAN PABLO MOLYNEUX LSJ, Lie Member S EFTA00308313 a Case: :10-cv-00034-CVG-RM Docum ent it 8-3 filed: 06/11/10 Page 1 of 8 AGREEMEN T FOR DFSiG Tills AGREE N SERVICES MENT FOR 2009, by and a D ESIGN SER mong Juan P VICES, is en and together ablo Molyne tered into th ux ("JP"), J.P is with JP, "Moly neux,") L.S . Molyneux Stu 15th day of May, .J., LLC ("LSI" dio, Ltd. _Each-of-the ) and JeffLeLE ("Studio', - partter he p s tein ("Eps hereby agrees reto ((the 'P tein"-)r as follows; ardee), inte nding to be bound here 1. Upon execu by, valuable and tion of this sufficient co A g reement by Studio In the nsideration the parties h , Molyneux s ereto, in re amount of hall credit E turn for go *Credit') to Two Hund pstein's ac od, be applied red Fifty Th count with disbursemen against futu ousand Dolla ts and expen re s rs and/or LSJ, ses incurred ervices provided by, a (5250,000) (the as determin b nd out of ed by Epste y, Studio, to and for th p Service?). in in his re e benefit of ocket asonable dis cretion (the Epstein 2. "Covered With respec Studio shall b t to actual se ill Epstein an rvices rende Hundred Do d apply suc red as part llars (5500) p h billiagains of the Coh t the Credit ered S ($80) per hou r for Studio er hour for services ren at a rate eq ervices, staff. dered by JP ual to Five and Eighty 3. Without in an Dollars those servic y way limitin es, disburse g the to be necess ments and/o foregoing, the Covered S ary or appro r expenses ervices shall and interio priate to co reasonably Include r design and d mplete the d determined pavilion cu e coration, in e s ign, constru b y Epstein rre cluding furn ction, and Pavilion"), a ntly under constructio iture and furn ishin exterior nd will furt n on Little and the pa her Include p St. James Is gs, of the office yment of a ro vision of the land (the necessary fo ll expenses skilled labo "Offic r the proper and disburs e m r and supervis e already deliv in stallation, e nts in conn ion, ered to Little restaining a ection the St. James by nd refinish rewith, Atelier Fan ing of the c .4. ceill. abinetry Notwithstan that the lab d in g the provis or charges fo ions of Sect existing purc r the installa ion 3 hereof, hase order b tion of such the parties and agree th etween Stu cabinetry w acknowledg at such labor dio and Eps ere included e of the Cred charges sha tein, attache in a pre- ll be paid fo dh it against the s ame. r by Molyneu ereto as Exhibit A, xwithout 5. application It is a mate Molyneux s ri a l term of th ha is agreemen Office Pavilio ll furnish and cause to t that as pa n of the n by January be properl the Office P 2, 2020 all o y installed a .Covered Services avilion will nd complete be completed f the items listed on Ex d 1, 2010, M olyneux agre to Epstein's hibit hereto at the Credit for e s that the' a re a s a nd that the provisio n ggregate am onable satisfaction by Ja exceed the , installation ount to be a nuary amount of th and comple pplied aga liability to m e Credit and tion of all inst the ake any paym that neither such items ent to Molyn Epstein nor shall riot eux in resp LS) shall ha ect of any su ve any ch items. EFTA00308314 Case: 3:10-cv-00034-CVG-RM Document #: 8-3 Filed: 06/11/10 Page 2 of 6. in the event that by the fifth anniversary of the date that this Agreement Is executed by all of the parties hereto, Stud io shall not have provided Cov Services in an amount equal to the Credit, ered then On the date of such fifth anni Molyneux shall pay Epstein the unapplied bala versary, nce of the Credit by wire transfer an account designated in writing by Epstein to to Molyneux (the "Designated Account" tendays-priortSfiftlfMnIversary date ) . In die event that Molyneux Is deem breath of this Agreement in accordance with ed in the provisions of Section 8 here then, effective as of the date that Molyneux Is of, in breath under Section 8 here unapplied balance of the Credit as of such of, the date shall be due and payable to Promptly upon demand by Epstein to Molyneu Epstein. x, Molyneux shall pay Epstein unapplied balance by wire transfer to the such Designated Account specified in demand. such 7. In the event that• Molyneux should brea th any term of this Agreem Epstein shall give him written notice and ent, ten days' opportunity to cure befo Molyneux shall be deemed to be in breach. re 8. In the event of breach of a material term of this Agreement, Including, without limitation, a failure to complete the provision and' proper installation and • completion of any one or more of the items on Exhibit B by January 1,2010 failure to complete the Office Pavilion or the to Epstein's reasonable satisfaction January 1, 2010 which Is not cured by by Molyneux, Molyneux shall pay Epst liquidated damages S250,000 within 30 days ein as . of the expiration of Molyneux's ten (-) opportunity to cure. The parties hereto day understand and agree that such $25 payment Is in addition to the payment 0,000 of the unapplied balance of the pursuant to Section 6 hereof. The parties here Credit to agree that in the event of such material breach, the actual amount of dam a ages sustained by Epstein and LS) be difficult to ascertain and, under would the dreumstances, the amount of liquidated damages Is fair and reasonable. these 9. JP. states that neither he nor Studio is an architect and have not th emselves out as same regarding the held services to be rendered under Agreement Further, Epstein and ISJ ackn this owledge that JP and Studio have themselves out as an architect regardin not held g the services to be rendered und Agreement er this 10. This Agreement constitutes the entir e agreement between the Part regarding the-provision of the Covered Serv ies ices. Each Party acknowledges Party has not executed this Agreem that such ent in reliance on any repr inducement, promise, agreement, or esentation, warranty that is not contained in Agreement or the Settlement Agreem this ent. 11. The Parties agree that the prior drafting hist ory of this Agreement shall not be used to construe any term of this Agreement This Agreement has negotiated by each Party and such Part been y's respective attorneys, and the language 2 EFTA00308315 Case: 3:10-cv-00034-CVG-RM Document ft 8-3 Filed: 06/11/10 Page 3 of 8 hereof will not be construed for or against any such Party as the principal drafter of this Agreement. 12. The individuals signing this Agreement and the Parties on whoSe behalf such individuals are signing hereby represent and warrant that they are empowered and authorized to sign on behalf of and bind the Parties for: whom they have signed. 13. . Each Party agrees that this Agreement shall be bindin g upon the heirs, successors, and assigns of each Party. 14, Each Party represents and agrees that such Party: (I) has fully reviewed this Agreement and has had the opportunity to seek advice by independent counsel of its choosing with respect to the same: (II) fully understands the terms of this Agreement and has entered into this Agreement voluntarily witho ut any coercion or duress on the part of any person or entity; and (Ili) was given adequ ate time to consider all implications of this Agreement prior to entering into it 15. This Agreement may be executed in any number of count erparts, each of which shall be deemed an original, but all of which together shall constitute one and the sa me instrument Signatures of this Agreement transmitted by fax shall have the same effect as original signatures 16. This Agreement may not be amended or modified except by a written instrument executed by the duly authorized representatives of all of the Parties. Any waiver of any provision hereof must be in writing and signed by the party to be charged with such waiver. Any such waiver shall be effective only In the specific instance and for the specific purpose for which such waiver is given. No failure on the part of any Party to exercise, and no delay in exercising, any right, power or privilege under this Agreement shall operate as a waiver thereof; nor shall any single or partial exercise of any right, power or privilege under this Agreement, preclude any other or further exercise thereof or the exercise of any other right, power or privilege hereunder. 17. Any demands, statements, communications or notices to be provided pursuant to this Agreement shall be in writing and sent by hand delivery or by reputable overnight courier to the attention of the Parties Indica ted below, until such time as notice of any change of person to be notified or change of address is forwarded to all Parties: (a) For Epstein and IA: Darren K. Ind ce Es 3 EFTA00308316 Case: 3:10-cv-00034-CVG-RM Document 4: 8-3 Filed: 06/11/10 Page 4 of 8 (b) For JP and Studio: Jay Goldberg, Esq. 18. This Agreement shall be governed by and construed In accordance with the laws of the Virgin Islands applicable to agreements entered Into entirely within the Virgin Islands, without regard to the principles of Virgin Islands' law regarding conflicts of ;mks. 19. Each Party irrevocably and unconditionally submits to the exclusive jurisdiction of any court sitting in the Virgin Islands over any suit, action or proceeding arising out of or relating to the Disputes. Each Party agrees that service of any process, summons, notice or document as provided in Section 17 hereof shall be effective service of process for any action, suit or proceeding brought in any such court Each Party irrevocably and unconditionally waives any objection to the laying of venue of any such suit action or proceeding brought in any such court and any claim that any such suit action or proceeding brought in such court has been brought in an inconvenient forum Each Party agrees that a final, non-appealable judgment in any such suit, action or proceeding brought in any such court shall be ( conclusive and binding upon such Party and may be enforced in any other courts to whose jurisdiction such Party Is or may be subject by suit upon judgment 20. The Parties agree'that the existence, terms, and consideration paid pursuant to this Agreement are strictly couGdential and that This Agreement will not be filed in arty court, except in proceedings to enforce, this Agreement or the Settlement Agreement. No -Party may reveal any facts about this Agreement or the terms of any settlement of which this Agreement is part without the prior, written consent of each of the other Parties; provided, however, that a Party may disclose facts about the settlement (i) to its or his employees, accountants and attorneys who require the same for the purpose of performing their employment duties or providing professional services to such Party; (ii) to its or his insurers or re-insurers; (iii) as required by any law, regulation, or rule of a court or court agency; or (iv) in response to a duly authorized subpoena or court order. Before disclocing any facts about the settlement under provisos (i) or (ii) above, the party making the disclosurd shall inform the receiving party of the terms of this confidentiality provision and shall take reasonable measures to ensure that the receiving party agrees not to make further disclosures of the requested information. At least five business days prior to disclosing any facts about the settlement under provisos (iii) or (iv) above (other than in connection with proceedings to enforce the provisions of this Agreement or the Design Services Agreement), to the extent permissible by law, regulation, rule of 4 EFTA00308317 Case: 3:10-cv-00034-CVG-RM Document #: 8-3 Filed: 06/11/10 Page 5 of 8 a court or court agency or court order, the Party making or asked to make the disclosure shall Inform each of the other Partite of the proposed disclosure or request for information, and shall, at the request of any Party and a tthe cost of such requesting Party, file any disclosure or response to the request for about the•setilement or the terms of this Agreement pursuant inform ation to a motion or other formal request that the information be maintained in confidence and/or .held under seaL IN WITNESS WHEREOF, theparties hereto have caused this Agree ment to be executed by themselves or their duly authorized representatives, as the case may be, as of the date of the day and year first above-written. J.P. MOLYNEUX STUDIO, LID. By: Juan Pablo Molyneux President JUAN PABLO MOLYNOUX Member 5 EFTA00308318 Case: 3:10-cv-00034-CVG-RM Docume nt #: 8-3 Filed: 06/11/10 Page 6 of 8 a court or court agency or court order, the Party making or asked to make I disclosure shall inform each of the other Part the ies of the proposed disclosure or request for information, and shall, at the requ est of any Party and at the cost of such requesting Party, Me any disclosure or resp onse about the settlement or the terms of this Agreem to the request for information ent pursuant to a motion or othe formal request that the information be maintained r in confidence and/or held under IN WITNESS WHEREOF, the parties hereto have executed by themselves or their duly authoriz mused this Agreement to be ed representatives, as the case may be, as of the date of the day and year firs abo t ve-written. J.P. MOLYNEITX STUDIO, LTD. •By: • Juan Pablo Molyneux Pres LO MOLYNEUX JEFFREY P.PSTEIN L.$.1.,LLC By: JEFFREY EPSTEIN Member EFTA00308319 Case: 3:10-cv-00034-CW-ITNIbifor ernent #: 83 Filed: 06/11/10(1PagerlQuisfenrit 71 06 MOL,N1 %.4 t33C 29 FAST 69 I k STIZEI-rT ARCHITECTURAL INSIt/RS k DECORATION 4 Rut:: C11, P()N Vi‘‘ rortu.yan yew); icon -RDA P ARM FRANI no 0i:I 6.3IXDO no I It. too /4 ono.; on pm JON 737 ea 11. • o• I in oil 44 YJ De 44 4D IN il^4 Pnl,RellTaSIFill ale. in no pro.. Deal, DruweaKe FANCELU PANELING 10/14/2008 VENDOR: 2124354537 A•LI MINN.% 212-9354538 Fax Inhunin . nsscrturnot; UNIT ORWE EWE-NINO) Can Woodworking 730,000.00 780,000.00 FABRICATION & NSTALLATION of light oak with waxed fioishtabinetry per JPM design. Will • include survey, shop drawings, moldings of bate, lower cabintcry with doors and upper bookshelves 3 hidden cabinet doors sod atcrior window shutter columns with bases and crown. Will include packing insurance and waterprottcontainer to St. thomas and crew travel. Cost will not inclade 2 globes, fiat base (stone) trinspaudon of goods to St. James, scaffolding, local rues. customer or workman's accomodatioas NOTE: THIS PO REPLACES P092680 Deposit Required: S 0.00 TMakS 780,000.00 Payments: S 780,000.00 Account I: Terms: 100% Deposit MI NOT PROMS TOO DOIDIX IINLESS SPIU3P/C*Alli /KS AM) ENLICT ARK CRIPAREr auxuasfilvl / LSI-OFFICE / OFFICE/ EURO: [SY-OFFICE nonnew. o: 29764 WPM AMU OFFICE . .... Inc9 .1 ATELIER FANCF7 T 63 RUE ALBERT MINOSRV: DMILENNE . ikn DAIL PROAILNIOi ixoNT3T Dui Tamen IR ORDRII ..1'WIRD Valet >Dna ta:IN% MO.RI i a IITIDID1 Ot it cotagsSOMDta 31 TUMOR OCDRIGNA Et 'KR V'It.\IIonEIMI RACIORT,ISII Et 1K1Ort I RP 1 lib lilt U.SOYAR voil lie • meiPIP IF Non rail- 7 uDOI R VI ions MOO VORDDCD'S t TDOPLNIA DUN I' RAM I De • I AM UM% CV. RESAI.K / 114104128 • EFTA00308320 Case: 3:10-cv-00034-CVG-RM Docum ent #: 8-3 Filed: 06/11/10 Page 8 of 8 EXHIBIT B In the following Exhibit B, the words "I," "me" and "mine" sha Moiyneux and the words "you" and ll refer to Juan Pablo "your" shall refer to Jeffrey Eps tein. I propose to include all of the following services and item have agreed: s for the $250,000 that we The Office/ library: Fancelli will complete the install ation at no cost to you. This me responsible for any Fancelli Install ans that you will not er expenses including travel, be etc. After Fancelli finishes the lod ging, food, incidentals, Installation., I will decide if the adequate for the overall ambiance color of the paneling is . If It Is not, I will select color restain and refinish cabinetry as par with your approval and t of the services I will provide The desk I will include will be and at no cost to you. a bronze contemporary' des modern swivel desk chair. I will k (Design JPM) with also Include a guest desk cha a lamp I will include will also be con ir and a desk set. The temporary. I will Include an uph des k cushion for the window seat olstered window sea built into the cabinetry. in Will t with custom tassel trim). For include 4 pillows (silk vel the sitting area, l will include vet upholstered in a cut cotton four large scaled club cha velvet (Bevilacqua Fabric), irs lights, a coffee table (Design 3PM two contemporary reading ) with a unique tiger coral par contemporary Celestial and Ter quetry top, a pair of restrial Globes (Design WM, from Ford). I will provide with your the movie by John approval the design (which purchasing the materials) for the includes selecting, but floor of the structure. I wil not will be a sisal and the hardware for l also include a carpet the cabinetry, which will be wh ich ) marine fauna. I will also provide all bronze with shapes lighting and ceiling design wit of structure. I will provide the h your approval for the ceiling Painting which was pre have delivered to St. Thoma viously ordered which I s and oversee the proper Ins Will ceiling.) will provide back-up doc tall ation of the same on umentation to you for the pric the the rates in the Design Service es and billable hours s Agreement) for the above (at total amount falls short of Items and services and if $250,0W, I will provide oth the discretion to complete the Office er items at my reason Pavilion so that the total amoun able t equals $250,O00. will make two trips /visits to Litt le Saint James Island on dates reasonable discretion to be nec determined by me in my essary or appropriate to ove the above work. rsee, perform and com plete EFTA00308321